We continue to argue for more accurate data to evidence the 'supply' and 'demand' of NHS General Dental Services (GDS). This was made clear in our evidence to the Health and Social Care Committee's consultation on dentistry.
Robust data, showing patient demand and the Whole Time Equivalent (WTE) of NHS dentists, is needed to enable evidence-based policies and decision making.
"Most dentists see these data collection requirements as significantly disruptive."
We welcome the introduction of two new data capture systems to the GDS which will generate accurate workforce data and more trackable patient movements within the service.
Despite this, there are several significant caveats. We have given extensive feedback as the introduction of both systems has been poorly planned within GDS workflows. Feedback from our recent survey and open webinar show that most dentists see these data collection requirements as significantly disruptive, and it is our job to present a better solution to minimize administrative burdens.
Patient NHS numbers
"NHS Business Services Authority can collect 70% of patient NHS numbers."
The NHS Business Services Authority (NHSBSA) can collect 70% of patient NHS numbers from matching databases across the NHS, and plans are in place for the software suppliers to automatically import those numbers into patient records. There are legitimate reasons for collecting patients' NHS numbers and there are no GDPR issues, as patients cannot be readily identified with the information.
This will mean that for 7 out of 10 patients, the data will be collected on our behalf. For the other 30% it is quite simple to do as part of practice administration. Including the website address where patients can request their own NHS numbers in patient communications will assist in adding these to their records. Undoubtedly, however, it will require some additional time to chase the tail of the records.
Wales National Workforce Reporting System (WNWRS)
The concept of accurately reporting NHS dentistry workforce WTE's has been aired for a while. General Medical Practitioners have been using this workforce data-capture system since its launch in 2020.
The Welsh Government has a legitimate reason for introducing the system as knowing the WTE's of dentists working in NHS dentistry will undoubtedly help with workforce planning. In theory, practices could also use it to help manage staff data, although payroll systems will likely do this better.
It is disappointing that we were not consulted on the introduction of this system much earlier. We have also questioned the appropriateness of some of the sensitive workforce data proposed to be captured by WNWRS, as a cookie-cutter approach will not work for everyone.
WNWRS wrote to practices in January, introducing the system and consulted with us after this in three meetings. Most of the supposed benefits to dental practices are of marginal value in the short-term. Our concerns are in three key areas:
- Capturing NHS hours or sessions
- Timing of the roll out
"Practice owners must have a legitimate reason or consent to use staff's personal data."
GDPR means that practice owners must have a legitimate reason or consent to use staff's personal data. Currently, WNWRS are suggesting capturing names, National Insurance (NI) numbers and dates of birth within the system. At present, Shared Services Partnership has not demonstrated any legitimacy for requiring all three items of sensitive personal data.
We have argued that capturing NI numbers as a unique identifier, combined with year of birth, is sufficient for their data requirements. The NI number will allow them to identify staff working in more than 1 practice and together with the year of birth, this is enough information for them to do all the analytics required and workforce planning.
That is GDPR in a nutshell, there must be a legitimate reason and only data sufficient to fulfil the purpose it is provided for. I am hopeful that we will win the argument to not include individuals' names and full birth dates.
Helping WNWRS to understand GDS
The WNWRS system was set up to suit the GMS, so this does not automatically mean the same criteria apply to the GDS. Until our meetings, the WNWRS project manager did not appreciate that general dental practices are not contracted to provide a certain number of NHS sessions.
"General dentistry will now be given due consideration within the WNWRS."
We gave the project manager a simplified synopsis of Units of Dental Activity and contract reform because they couldn't understand how practices fulfil their NHS contracts without counting sessions. So, having demonstrated our completely different operating systems and data needs, general dentistry will now be given due consideration within the WNWRS.
The real challenge for practices will be for staff to separate out the hours for NHS work and private work, but thankfully the system does not require any entry for private activity, which we would have disputed had it been included.
Timing of the roll-out
We explained that since 2006, Q4 of the financial year has been a no-go period for rolling out any new initiatives. Unfortunately, because this had not been initially understood, we all received a letter in January informing us about the system. The letter prompted some practices to request admission to the database while trying to keep on top of paperwork.
"Adjustments to the GDS aspects of the system are required and it's premature to complete any data sets now."
We were asked for our advice on how to manage practices requesting access after we had raised legitimate concerns about the legal basis and quality of data being requested. We therefore cautioned the project manager not to entice practices to unwillingly breach GDPR by allowing anyone to use the system until the issues have been resolved.
It was agreed that the next letter will be sent to us before a formal roll out, however they are committed to a timetable that fits no one's needs. My approach at this stage is to not invest any staff time in entering data into a system that has not yet been finalized and is subject to change. Adjustments to the GDS aspects of the system are required and it's premature to complete any data sets now. If WNWRS can give me a legitimate reason for providing sensitive staff data, then I will do it.
PEC member for Wales