Examples of our role include:
- restricting access to a patient's record (set Sensitive status or 'S' flagging)
- changes of identity
- NHS Number allocations
- PDS record and batch file reconciliation
Restricting access to a patient's record
We manage the setting of the sensitive status on PDS records.
The status is set to sensitive on request to restrict access to location information on a PDS record. It's removed when the restriction is no longer required.
Some Spine services are not available to patients when a sensitive status is set, because their up-to-date contact information is restricted. This includes the e-Referral Service (e-RS) and the Electronic Prescription Service (EPS). The impact of setting a sensitive status should be explained by the GP to the patient when the request is made.
Changes of identity
Management of PDS records in cases of adoption, gender reassignment and protection of identity.
NHS Number allocations
We allocate NHS Numbers for patients who do not have one and who require NHS treatment. Examples include:
- patients referred from the Channel Islands for treatment in England or Wales
- short-term visitors from abroad who require NHS treatment
PDS records and Batch File Reconciliation
When batch files are processed against the PDS the automatic update of a record may not be successful. This could be due to differences between the data supplied and the data held on the PDS. When this happens, we investigate, confirm the correct record match and manually process the data.
This occurs following the processing of batch files containing:
- civil registrations of birth
- civil registrations of death
- overseas visitors and migrants who have paid the immigration health surcharge
When data is transferred via batch files from systems not linked to PDS, NBO implements manual processes to trigger the movement of paper medical records. This occurs following the processing of batch files containing cross border transfers with Scotland and Northern Ireland.
A number of queries have been raised with GPC regarding the management of patients who present at their general practice with gender identity problems; including questions relating to patient records and confidentiality and, in particular, regarding prescribing and monitoring responsibilities in relation to the gender reassignment process.
In response, we have produced new guidance, which:
- Aims to explain what should be provided in primary care
- Signposts to further sources of guidance
- Highlights some of the underpinning ethical and legal considerations.
A copy of the guidance is attached and can be found on the BMA website.
Legal recognition will only follow after the issue of a full Gender Recognition Certificate by a Gender Recognition Panel. The panel must be satisfied that the applicant:
- has, or has had, gender dysphoria
- lived in the acquired gender throughout the preceding two years.
- intends to continue to live in the acquired gender until death.
In this case, the patient must be supplied with a new identity and the old identity revoked, including transferring all medical records.
Generally, patients will have lived as the alternative administrative gender prior to clinical reassignment.
A patient may request to be known by a different administrative gender without a full Gender Recognition Certificate.
This may be as a result of a clinical intervention or simply a desire to be known by a different gender.
In such cases the patient must be cautioned about the consequences of changing administrative gender, for example, in connection with cancer screening programmes. Both types of request are currently treated identically.
GPs and staff should also be careful that whatever stage of transition the person is at, this information should only be passed on when it is relevent to patient care. With the use of IT systems to help produce referral letters etc it is easy for irrelevent personal information to be included in, for example, an ENT referral, where there can be no clinical reason for sharing those details.
What happens now?
When a patient requests a gender reassignment of either type, the patient's GP or Primary Care Trust must write to the Personal Demographics Service (PDS) National Back Office. The case will then be managed by them.
The National Back Office creates a new identity with a new NHS Number and requests the records held by the patient's GP. These records are then transferred to the new identity and forwarded to the new GP.
The old NHS Number is withdrawn so that it can no longer be used. Questions on the process should be referred to the patient's Primary Care Trust.
The Department for Constitutional Affairs (DCA), which has overall responsibility for the Gender Recognition Act, is working with NHS Connecting for Health to incorporate the new legislation into the NHS Care Records Service.
The advent of the NHS Care Records Service means that there is greater opportunity to extend the policy to the patient's entire clinical record, rather than that just held by their GP.
Please refer to Chapter 7 of the procedures guide for further guidance and informaiton.