The Information Commissioner's Office (ICO) has submitted a response to the Department of Health & Social Care's (DHSC) consultation on the 10-Year Health Plan to build a health service fit for the future.
In its response, the ICO welcomes the development of the 10-year plan and the opportunity to contribute to this consultation.
Overall, the ICO highlights the importance of a privacy-by-design approach to data use in order to build public trust and confidence.
Key points contained in the response:
The ICO calls for a holistic approach to transparency across the health and care system, suggesting clear responsibilities for providing transparent information at various levels to strengthen public trust regarding data usage.
In general, the ICO supports innovative technologies that can enhance patient outcomes and stimulate economic growth, provided they are used transparently and respect individual rights.
On the adoption of new technologies, the ICO recognises the potential advantages for processing health information while underlining the necessity of protecting individual rights and freedoms. In such cases, the use of these technologies should be fair, lawful and transparent, and in accordance with data protection legislation.
This is particularly the case concerning the adoption of artificial intelligence (AI), which must also comply with automated decision-making rules and should be thoroughly tested to ensure decisions are accurate and that the risk of any inherent bias is mitigated.
In addition, the ICO highlights the importance of conducting data protection impact assessments and informing the public about developments in these technologies early on to maintain clear transparency.
Concerning cybersecurity, the ICO highlights the significance of robust cybersecurity measures to protect sensitive data and recommends the adoption of Privacy Enhancing Technologies (PETs) to facilitate privacy-friendly data sharing, especially for public health purposes.
The ICO looks forward to collaborating with NHS England at the early stages of technological innovations to ensure that data protection is prioritised from the outset.
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