The governance model for use of personal data that has undergone pseudonymisation for integrated care utilises the statutory responsibilities of the component organisations in the care system. These statutory duties outline the scope of activities the organisations can undertake and form the basis for what data they can use. Predominantly, commissioners do not provide individual care services and providers do not plan services for the population.

Commissioners, subject to the scope of their statutory duties, typically access personal data that has undergone pseudonymisation to undertake secondary use analysis. Providers predominantly access confidential patient information to support individual care (e.g. clinical interactions). They can also undertake analysis using personal data that has undergone pseudonymisation to perform secondary use activities such as planning and performance analysis to improve services and outcomes for patients for their own organisations.

Where providers are required to undertake wider activities to plan services for the population to support integrated care, they can be contracted as a data processor to do this on behalf of commissioning organisations (be that individually or jointly), utilising the commissioners' statutory duties within agreed contractual arrangements.

This model is depicted in the following diagram;

The SUDGT proposes a model that is underpinned by distinguishing between the statutory responsibilities of commissioners and providers which must be understood before a care system can process data on a wider geographical or organisational basis. Fundamentally, commissioners have no statutory powers to provide individual care services and providers have no statutory powers to undertake commissioning (traditionally a statutory duty of CCGs).

Whilst providers can conduct analysis on their own data for secondary use purposes (such as service and performance management), their legal powers only extend to doing this for their own services and patients and do not permit them to undertake analysis on a wider organisational or geographical footprint. The tool suggests a model that enables providers to support integrated care analysis by undertaking such work on behalf of commissioning organisations (be that individually or jointly) and other providers across an integrated care system.

The tool also describes the governance arrangements required to support intelligence flows across an Integrated Care System. Providers can be contracted to perform activities on behalf of commissioners and where required, this can be across multiple provider organisations.

The general model promoted by the SUDGT is illustrated below: