Stuart Bolton, Engagement Manager
Centre of Excellence for Information Sharing
I was recently speaking with a friend who delivers child protection training to local authorities and agencies across the country. He described the approach to understanding risk during these training sessions, as equivalent to determining the length of a piece of string.
When it comes to our personal tolerance to risk, we all have a length that we are prepared to go to before our piece of string ends. This length varies depending on the individual or the organisation and it is shaped by various factors, including past experiences and knowledge.
Similarly, when it comes to information sharing across local places and organisations, there are often key individuals who inform, influence and make decisions around information sharing and these are usually based on the length of their own pieces of string. The decisions they make though, can mean transformational projects either succeed or fail.
Since our work began last year, it has become clear that understanding the culture around risk in relation to information sharing can be a real clincher in the ability to support changes needed to improve approaches to sharing information and in turn, deliver service transformation.
One of the local areas that I am supporting is developing a collaborative approach which aims to reduce the number of frequent callers to blue light emergency services. By identifying high volume callers and using a robust process of monitoring, assessment, information sharing and relevant service referrals, users will receive the support they need without burdening an already overstretched service. Ultimately, with better outcomes being realised for the individual, the demand they place on the emergency services will reduce.
The initial development of the project was going well, with partners fully on board and documentation in place to guide its implementation. One aspect of the scope included the sharing of frequent caller’s telephone numbers between emergency services, enabling better signposting and support.
However, as the project progressed and more details of the processes were planned, one of the partners called a halt to further development. A Caldicott Guardian had raised concerns that telephone numbers were personally identifiable data and as such, the sharing of them was in breach of the Data Protection Act (DPA). Matters were further compounded by the fact that, due to the competing demands of work and other priorities, the key individuals involved were struggling to find the capacity to discuss and challenge these concerns. The way forward appeared very difficult.
Fortunately through the project’s support networks, we were contacted and were able to provide some help and guidance. By sensitively discussing the issue with the Information Commissioners Office (ICO), the ICO was able to clarify and provide guidance as to how the sharing of telephone numbers could occur legally under the terms of the DPA, allowing this critical service development to get back on track.
The ICO issued a clear but detailed guidance note which the project lead was then able to share with all its partners. This included a recommendation to develop a Privacy Impact Assessment (PIA) which would enable partners to have the critical conversations needed to collectively identify, understand and manage the privacy risks of the project, and ultimately, agree on the length of their piece of string. We were able to signpost and support the development of the PIA enabling all partners to develop this important service to provide people with the help and support they need. Partners found the PIA process valuable and meant that, despite concerns over capacity, the issue was overcome by using a tool that enabled conversations and project development to be guided and successful.
So, although we may feel that we have limits to the lengths we can go to, sometimes, by taking guidance, receiving assurance and making time for important conversations, the length of your piece of string might turn out to be longer than you initially believed.