Online Access to Medical Records – Safeguarding
Accelerating Patient Access to their GP Held Records
From April 2020 there is a contractual requirement for practices to offer all patients online access to all prospective data on their patient record unless exceptional circumstances apply. (Additionally, patients can also ask for their full retrospective medical record, this will require sensitivity and third-party data checking)
- See Regulation amendment 71ZA & 71ZB.
- Lunch & Learn - Managing Patient Records
There have been a number of dates given for the roll out of this programme only to be suspended.
On 29th November 2022 the BMA reached a negotiated agreement with NHS England and DHSC over halting the mass roll out of the records access programme, for those practices who wish to delay the process, and have published a webpage on the current programme which also includes some useful FAQs (see below) that you may have on the current situation, depending upon what your practice has or has not yet put in place.
BMA FAQs
I have submitted a template letter to my system supplier – what happens now?
Your practice will not see the records programme switched on, regardless of whether you batch coded none, all, or a subset of your patient population.
On your behalf, we will be discussing the next steps with NHSE, system suppliers and others.
I haven't done anything – what happens now?
The inference is that you are happy to proceed with the roll out as planned. We are told your system supplier will be in touch with you to discuss what happens next and when. You can still send in the template letter f you do not want the records programme switched on at this time.
On your behalf, we will be discussing the next steps with NHSE, system suppliers and others.
I have batch coded a certain cohort of vulnerable patients to prevent additional access being provisioned but did not send in a template letter – what happens now?
The inference is that you are happy to proceed with the roll out as planned, with prospective access being granted to those patients who didn't have codes added to prevent access.
We are told your system supplier will be in touch with you to discuss what happens next and when. On your behalf, we will be discussing the next steps with NHSE, system suppliers and others.
I have batch coded all my patients to prevent additional access being provisioned at this time but did not send in a template letter – what happens now?
This question is largely academic as even if the new functionality to provide access were provisioned, no new access could occur due to the presence of batch coding to all your patients.
On your behalf, we will be discussing with NHSE and system suppliers whether an option to restore the medical record to its previous state, through the removal of those batch codes, would be beneficial. This would be on the proviso that the roll out does not proceed and any changes to the medical record had the approval of the data controllers.
A patient has requested access – what should I do?
Patients can still request access to their electronic records, as has been the case for a long time.
Patients should be made aware of the implications of access and GPs should ensure it is appropriate and safe for their patients to have access before it is granted.
Further Guidance
For those practices preparing to proceed, the BMA also have guidance and we would suggest practices might like to use the General Practice Readiness Checklist which is accessible on the FutureNHS platform.
There is a channel on the FutureNHS website dedicated to Accelerating Citizen Access with a wealth of documents and resources that you may find useful.
NHS Digital also have a dedicated webpage with a number of resources including The RCGP GP Online Toolkit .
Accelerated Access to GP held Patient Records A summary for the admin team
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Lisa Harding, Director of Primary Care at Wessex LMCs, talks with Caroline Sims, Information Governance Consultant and Data Protection Officer in the Hampshire & IOW area. Listen to the podcast here |
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Caroline explains:
Further Reading: NHS Digital: https://digital.nhs.uk/services/nhs-app |
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104 and 106 codes
There has been much confusion about what Snomed CT codes can or should be used and what effect they have on the online access if you do. NHSE&I have produced a handy guide that documents these scenarios and this can be downloaded form the FutureNHS website.
Update - system changes for all practices using TPP and EMIS - June 2022
General practices were previously informed that from April there will be system changes for all practices using TPP and EMIS systems to provide all patients with easy access to their future health records. Go-live date is now expected to be 30th November 2022.
For more information please click HERE
There are a number of resources that NHSE&I have published on FutureNHS. This includes a useful FAQ document. we would recommend subscribing to this channel, it is quick and easy to sign up.
Proxy Access
This a topic referred to and the FAQs say that the new changes do not apply to proxy.
The accelerated access program is for those aged 16yrs+. However, we would recommend that this topic is reviewed and details can be found at: -
RCGP https://elearning.rcgp.org.uk/mod/book/view.php?id=13455&chapterid=770
We have raised concerns about certain aspects of this with both NHSD and the BMA, and in particular around safeguarding. We are currently awaiting further guidance on this issue.
In the meantime, we would recommend that practices
- Remember they are the data controller.
- Remember the patient will be able to immediately see any entry that is not redacted from online view.
- The “switch on” of the online access only relates to the GP record (not community modules, for example).
- Ensure all staff and clinicians are fully aware of the importance of what they write in the record and how to “redact” from online view anything that is sensitive and or safeguarding relevant.
- Be aware that all the following will be visible
- Consultations with full text – unless hidden at the time of entry
- Results- once filed in record
- Codes
- Documents – once filed in record
- Appointment Information
- Access to retrospective (historic) records can still be requested by patients.
- If documents are filed into the record, they will be visible to online view.
- Ensure all staff processing documents know how to redact from online view until the document has been reviewed for suitability.
- There is a code that can be added to a record that will hold back online access “Enhanced review indicated before granting access to own health records – Snomed code 1364731000000104. We understand that this code must be added prior to the launch date of 1st November 2022. However there has been confusion about the use of this code, see the section above entitled 104 & 106 codes.
- Possible uses may include but not limited to
- Patients that lack capacity
- Patients with safeguarding protections or concerns in place
- Patients in domestic abuse situations
Clinical System Guides
An EMIS guide for redacting a consultation
A TPP guide for redacting a consultation (Please note that due to the configuration of your system you may not have all 3 processes available to you)
Consider using a test patient in your clinical system and similarly a test patient in the NHS App to see how actions within your clinical system will look to the patient within the App. NHS Digital have full details of how to do this. The NHS App test patient can be set up on a computer or laptop, as well as a smartphone, android or tablet.
With our kind thanks to Dr Michelle Sharma from BSW who has produced 
a crib sheet or all healthcare professionals that shows how to “Redact from online view”.
Further reading
More information can be found on our pages:
Medical Records, Online Access and NHS App
Wessex LMCs: Safeguarding: Children and Storing Information
Information Governance Lunch and Learn
Subject Access Requests & Dealing with Third Party Data recording
Data Sharing Update from Caroline Sims at the PM Conference, June 2022
Information Governance with Adam Horton-Tuckett - from PM Webinar 25 May 2022
NHS Acronyms and Abbreviations:
