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A data processor acting on our behalf, EMIS Health, is changing certain technical aspects of the way in which it delivers services to us (see https://www.emisnug.org.uk/blog/next-generation-emis-x-announced), and as part of this transition it will be moving the data which it hosts on our behalf from its own data centre to a third party data centre, which is owned and operated by Amazon Web Services (AWS). Delivery of the services is subject to the terms of the GP Systems of Choice Framework (GPSOC) which is managed by NHS Digital on behalf of the Secretary of State for Health. The exercise will involve a change to the manner in which data is being processed on our behalf. Although this change does not introduce processing that is likely to result in a high risk to individuals (which would necessitate the undertaking of a DPIA), given that the data includes special category data we nevertheless feel that it is appropriate that we undertake a review. |
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As detailed above, the data (which includes special category data (i.e. health data) which is collected via the processor’s clinical IT system and which forms the patient’s medical record) will be stored in a third party data centre (which will act on the instructions of EMIS Health, who in turn will act in accordance with instructions received from (or on behalf of) ourselves as the relevant controller pursuant to our call off contract under the GPSOC framework or as otherwise documented). Aside from the manner in which the data is being hosted, we have not identified, as part of this change, any material change to the manner in which the data is being processed (in terms of data sharing and/or use). |
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The scope of the data processing is as detailed in the relevant GP Systems of Choice contract (and related call off contract (and deed of undertaking)) or as otherwise agreed in writing between EMIS Health and ourselves. As noted above, aside from the hosting element the manner in which the data is being used or otherwise processed will not materially change as a result of this change. |