If you work in the health and care system and use accuRx, or are considering using our products, you will want to ensure you are doing right by your patients.
We take our responsibility to you and your patients incredibly seriously. This page explains how we keep your patients' data safe, our security credentials, and how we fit with NHS rules and guidance on data sharing.
Typically, the healthcare organisation is the Data Controller. Patients are the Data Subjects. We are the Data Processor (where our services are used). This means that we process data about your patients under the terms in our Data Processing Agreement, to allow you (as a healthcare organisation) to provide a service to your patients.
We have NHS Data Security and Protection Toolkit assurance (under NHS ODS code 8JT17). You can see our full submission here. We also develop software under the principle of ‘Privacy by design'.
Our accuRx servers are hosted in the London Microsoft Azure Data Centre. We follow best practice guidance from NHS Digital, the UK National Cyber Security Centre (NCSC) and Microsoft. See here for detailed information. All data sent is encrypted when in transit (when it is sent) and at rest (when it is stored).
Cyber Essentials is a scheme run by the UK government and the National Centre for Cyber Security to help you know that you can trust your data with us. We have the Cyber Essentials and Cyber Essentials Plus certification.
In order to provide communication with and about patients we process patient data and healthcare staff data to our secure servers. The patient data typically includes name, identifiers, contact details, demographic data, message content (including documents and patient replies to messages either via secure surveys or two-way messaging) and other application-use related data. We only process this data when you send a communication to patients.
We also process healthcare staff data who are users of AccuRx. This typically includes role, organisation, contact details, identifiers including gender and date-of-birth, messages, metadata, signatures, login and other application-use related data.
The video and audio communication of any video consultation is only visible to participants on the call, and is not recorded or stored on any server. The IP address of call participants may be stored as part of metadata stored, however no other personal information of call participants is collected or stored.
No, providing another legal basis is used. This was confirmed by the ICO in a BBC interview (go to 7:55 in).
GDPR allows six different legal bases for processing data, of which consent is one. The Information Governance Alliance advises healthcare organisations to process patient data for the delivery or administration of care under the following legal bases:
6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.
9(2)(h) ‘…medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems…’
The ICO has warned against the use of consent as a legal basis for data processing by public authorities and healthcare providers.
If your practice does choose to gather consent for other reasons, all consent codes found in a patient’s medical record are shown to the user.
When sending an SMS Chain SMS shows all consent codes and dissent codes found in the patient record. If a patient wishes to opt out of receiving SMS messages, you should update their ‘Notification preferences’ in the patient registration dialog.
In short, you can never be 100% confident, and so SMS messages shouldn’t be used for sensitive information (e.g. positive STI test result) or time-critical information (e.g. to book an urgent appointment) without the right safety net or follow up.
There are a lot of steps you can take to improve the quality of your SMS database, including asking your receptionists to confirm mobile numbers on every call, and confirming a patient’s mobile number in a consultation, especially when sending an SMS at the end of the consultation.