How to report potential problems with confidentiality and privacy of HIC data

HIC recognises and accepts that it has legal and other requirements for managing all breaches of its SOP and near misses that may threaten the confidentiality or privacy of the data subjects. HIC seeks to establish a balance of proactive and reactive risk management processes to enable early identification of potential problems thus creating prevention cycles to enhance confidentiality and privacy. Our aim is to minimise the risk of problems occurring with confidentiality or privacy and to maximise our opportunities to learn.

HIC's annual audit of compliance with the SOP is one important method for quality assurance. However, we also need to have a pro-active approach to improving systems and practice. The aim must be to improve and NOT to apportion blame. The purpose of this is to encourage HIC staff and users to be open if they feel uneasy about a process not working quite right or being ignored. They should be encouraged to report an incident so that the process can be checked and improved. This should be done in a positive way, the aim being to improve the SOP or the way that they are explained, not to blame people.

The sort of factors that may require improvement include:

Task factors

Is the SOP clear and is there enough supporting information?

Individual factors

Do the users of the HIC SOP have enough training in how to use it?

Team factors

Are you clear about how to communicate with other HIC users or with the HIC Executive? Do HIC users need more supervision? Do you know who to ask for help?

Working conditions

Do you think that HIC has enough support staff with the righ skill mix? Have you experienced problems with equipment or administrative support?

Organisation and management

Does HIC commit enough resources to the implementation of its SOP? Does the SOP receive sufficient priority?

If you experience any problem with implementing the HIC SOP or have any concerns related to confidentiality or privacy of HIC data please report these to Duncan Heather (HIC Operations Manager) in the first instance.

A Significant Event Analysis will be done to record confidentially what happened, why it happened and what the HIC Executive should learn or need to change in order to improve confidentiality and privacy. The results of the Significant Event Analysis will be submitted to the HIC Confidentiality and Privacy Advisory Committee (HICCPAC) and to the HIC Annual Audit.