A First-Hand Account of the Problematic Role of SARs Processing.
It’s widely known that resources within the NHS are stretched. So what happens when an institution that is already buckling under the pressure receives a consistently large volume of SARs with tight delivery deadlines? Now that they’re free of charge for the public to request following the introduction of the GDPR mandate in May, it’s not just the NHS who are struggling to manage the pressure of the increased quantity of SARs. Even large organisations with chunkier department budgets are struggling to maintain their current pace of responding to SARs. However, at Exonar, we believe we have a solution that will dramatically reduce human effort in processing SARs, easing the pressure on admin staff across the globe, in any sector.
To highlight the need for more system automation, we spoke to a former NHS employee who shared their insights in regards to processing requests in a recent exclusive interview with Exonar’s Head of Marketing, Dan Welberry. The following points were discussed during the interview;
- Why do the public need access to their data?
- The SAR process
- Privacy and sensitivity of data handled
- Issues of processing SARs within the NHS
- Size and scale of requests
- Turnaround deadlines
- What would make SARs handling easier?
Why Do the Public Need Access to their Data?
‘Within the NHS, a subject access request is usually raised for one of two main reasons;
- A patient who requires proof of a case for funding purposes.
- A family member trying to bring probate to conclusion on behalf of the deceased.’
‘Before any request for information is considered, the following steps must be taken:
Image source: Black Country Partnership NHS Trust; Subject Access Request Procedure
Since the GDPR mandate was introduced on May 25th, there are now no fees charged to the public for processing SARs.
Privacy, Confidentiality and Sensitivity of Data Handled
‘Whenever assessing a case, the privacy of the individual has always been the most important thing to me. If there was any information required that couldn’t be provided, the request would be declined and I would want to be sure that all the right documents were in place before any records were retrieved. There was always a need to also consider the content with discretion too. There may well be a case where the requested content could contain very private information – information that actually might not be helpful or upsetting to the family and therefore could perhaps be withheld or redacted. Where historical records were requested, there was also a case for reviewing the language used. What might have been appropriate to say a number of years ago may not now be so politically correct today – this too would have to be reviewed.’
Issues With Processing SARs Within the NHS
- Lack of system automation: ‘One of the biggest issues faced was the amount of manual work required to fulfil a request. I believe this is a huge challenge for the NHS going forward as they simply don’t have the capacity to cope now, let alone handle the anticipated increase after the introduction of the GDPR in May, 2018. Where redaction was required to hide any information, this would be done manually using a black felt tip pen which was massively time-consuming in itself.’
- Paper to Digital: ‘Prior to 2007, all records held by the NHS were on paper and from 2007 to date it’s probably around 50/50 – paper/electronic. All paper records were therefore required to be scanned. Any Post-It Notes or other attached notes would also need to be scanned without obscuring any content underneath’.
- Illegible Doctors’ Handwriting: ‘Covering notes present their own set of challenges, particularly when trying to decipher a Doctor’s handwriting!’
- Single Sided Responses: ‘Any documents sent out as part of a response couldn’t be double-sided, so single pages only added to the amount of documentation to be issued.’
SAR Size and Scale
‘To give you an idea of the scale of typical requests, I believe the following to be a fair assessment:
‘When considering the delivery time, you have to take into account a number of factors. Firstly, an FOI must be completed in 20 working days and a SAR will be one month to collate after GDPR is introduced on May 25th (previously 40 days). Crucially, a SAR demanding one month lead time means that all weekends and public holidays are included in the time allowance. Whilst the work is being undertaken, all cases must remain on the premises and locked away when not being reviewed. This can result in a fair amount of late nights which of course can be counterproductive when you really need to be very alert.
It’s my opinion that the ICO (Information Commissioner’s Office) provide very little support other than the information provided on their website. This in itself can be challenging as it’s written in a very ‘legal’ way, so it can often feel like taking guidance rather than knowing confidently that you are delivering what’s required. I recall when I started that very little training was given other than a quick run-through of some legislation. This worried me as I soon realised how forceful lawyers and the general public can be!’
What Would Make the SAR Process Easier Within the NHS?
‘During my time at the NHS, I often thought about how much easier the whole process would be with technology. I accept that the manual process of scanning would still be required, but the reading and redaction process could be completed in a fraction of the time. Consider these further issues once the collation process is complete – all impacting further on time and resources:
- The office printer being out-of-use or out of ink due to the amount of pages being printed and delaying colleagues.
- The need to use courier services to deliver vast amounts of paperwork.
- The need to package up various parcels to be sent via recorded delivery.
- The need to compress files where documents can be sent via email.
- The need to send out multiple emails due to the amount of data being sent.
- Formats and file types that can be read by the user as well as platform compatibility ie Mac v PC.
- Secondment of staff to achieve delivery deadlines.
- FOI requests delayed whilst SARs take priority.
Having watched a product demo, it’s my belief that the NHS and central government would benefit hugely from the Exonar software. I know that from my experience, it would have made my life in SARs delivery so much easier! The initial outlay to install the platform in Trusts across the UK would save the NHS an untold fortune, and it’s here where I believe that Exonar would provide the most value. If SARs can be produced in minutes, not days, this will significantly speed up processes, release some of the burden currently weighing heavily on the NHS and centralise patient documents, allowing for better data security. I can’t think of a single reason why the NHS shouldn’t invest in Exonar – to me, a former data handler on the front line, it’s a no-brainer!’
Do you work in an industry that is buckling under the pressure of SAR requests? We’d love to hear from you. Please reTweet this blog using #SARWars and tell us all about your Subject Access Request woes!