The challenge ​

The government mandated that all NHS health and social care staff were to be offered the COVID-19 antibody test. As part of a national roll out of antibody testing, STP areas were asked to facilitate a high volume of testing through hospital trusts and community providers. Each of the six boroughs under NHS South East London (SEL) Clinical Commissioning Group (CCG) adopted a different approach to antibody testing which required the NEL Information Governance (IG) Team to spend a significant amount of time supporting the CCG to work through the individual processes in each borough, working with a number of staff members across the patch.  

Our approach​

Early on when the outbreak of COVID-19 initially started, a decision was made by the NEL IG team that the Information Governance Subject Matter Expert (IG SME) Manager assigned to each CCG would act as the lead and focal point for supporting the organisation with their COVID-19 response.  As part of providing CCGs with COVID support, the NEL IG team created a COVID-19 specific Data Protection Impact Assessment (DPIA) template which was a short form version of the original DPIA template to be used for new projects which have been set up in response to COVID-19. 

When the IG SME Manager for SEL was first engaged to support the CCG with reviewing their approach to antibody testing, they made the decision to take a collaborative approach of meeting with the antibody testing leads in each SEL borough in addition to the SEL COVID testing team to understand the approach being followed. Additional meetings were also arranged with other organisations that were involved in the antibody testing which included engaging with NHS England and NHS Improvement, GP federations, councils, and NHS trusts.

Once the process being followed was clarified, the IG SME Manager engaged with the SEL Testing Leads, SIRO, Deputy SIRO and Caldicott Guardian to ensure that the CCG were aware of any risks or concerns associated with the approach being taken in SEL and the necessary mitigations that would need to be implemented to reduce any risk to the CCG. 

Following a significant amount of engagement from SEL CCG colleagues, the IG SME Manager was able to complete a detailed and thorough review of the CCG’s approach to antibody testing and identify any risks which required mitigating action. 

The NEL IG Team also drafted a separate privacy notice for the purposes of antibody testing to ensure that all members of staff that undertake the test are fully informed of the process being followed. 

The outcome​

NHS SEL CCG approved the completed DPIA for antibody testing at their Information Governance Steering Committee. The risks identified were noted and proposed actions to reduce the risks were accepted. 

This project was a great opportunity for the NEL IG team to work collaboratively with a range of different stakeholders, supporting with a programme that was fast paced and required strong engagement and communication skills to ensure the programme was thoroughly reviewed.