The following process for the assessment of requests to access GPES data for pandemic planning and research (COVID-19) has been agreed with the British Medical Association (BMA) and the Royal College of General Practitioners (RCGP) with support from the National Data Guardian (NDG). All requests for access to this data collection (referred to in this document as GPES COVID-19 data) will be considered by NHS Digital in accordance with this process. This process is particular to the GPES COVID-19 data and will apply for the duration of the collection, which is until the expiry of the COVID-19 Public Health Direction 2020, which is currently the end of September 2020.
The principles agreed with NHS Digital, IGARD, BMA and RCGP include that:
- all relevant stakeholders want to ensure that comments from RCGP and BMA inform the overall process, and that IGARD has visibility of those comments in reaching a recommendation
- timely, appropriate, proportionate and secure access to data is vital
- RCGP and BMA would comment on applications from the perspective of ethical, clinical and public interest (including clinical risk). They would of course have the right to make any other comments in addition, but are not reviewing the entirety of the application that is seen by IGARD (for example, legal basis, security controls, consent material, consistency of protocol/ethics, compliance with common law duty etc), given IGARD’s wider assurance role.