“The new Records Management Code of Practice (RMCoP) is very comprehensive and informative. Particularly the Code of Practice is clearer regarding specific roles”
In 2017 Scottish Government launched the Health and Social Care Records Management Summit.
Over 40 experts participated from local authorities, health boards (territorial and special, such as the Scottish Ambulance Service), GPs, the Scottish Prisons Service, National Records Scotland and other areas of Scottish Government.
Since then, 5 key sub-groups of experts have been working to undertake a deep review and update of the records management code of practice in the following themes:
- Corporate Records
- Health Records
- Integrated Health and Care Records
- Electronic Records
- Archives
The Information Governance and Assurance Team (Scottish Government) supported by the Records Management Forum have lead on this Code of Practice review.
Consultation
- Many core organisations where already involved in the review through their representatives in the summit or within the 5 specialist subgroups listed above.
- The Records Management Forum was also instrumental to communicate and obtain feedback throughout the review.
- Between the 16 December 2019 and the 26 January 2020, a number of relevant groups received an invitation to participate in an extended consultation:
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- NHS Health Boards,
- NHS Scotland ( NHSS) Records Management Forum,
- NHSS Information Governance Leads Group,
- NHSS Caldicott Guardians Forum,
- NHSS Health Records Group,
- Integrated Joint Boards (IJBs),
- Local Authorities.
- Medical Defence Organisations (MDDUS, MPS, MDU, DDU)
- Academy of Medical Royal Colleges and Faculties in Scotland (umbrella body for all the Royal Colleges and their Faculties, which will include Royal College of General Practitioners (Scotland), Royal College of Surgeons, Royal College of Nursing, Royal College of Psychiatrists, Royal Pharmaceutical Society Scotland, etc.)
- General Medical Council (GMC)
- British Medical Association (BMA)(Scottish Council) with an specific request to extend separate feedback from the General Pharmaceutical Council (Scotland)
- COSLA, SOLAR and SOLACE
- National Records of Scotland
- Scottish Social Services Council (Scotland)
- Nursing and Midwifery Council (NMC)
- General Chiropractic Council (GCC)
- General Optical Council (GOC)
- Health and Care Professions Council (HCPC)
- The Information Governance Alliance (England) + our IG core contacts within the 5 Nations.
- Information Commissioner Office (ICO)
- Scottish Prison Service
- COPFS
- SPSO (Ombudsman)
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Received Consultation Responses:
- Information Commissioner’s Office
- Academy of Medical Colleges and Faculties in Scotland
- General Pharmaceutical Council
- BMA Scotland
- Royal College of Physicians and Surgeons of Glasgow
- General Medical Council
- NHS Lothian
- NHS National Services Scotland
- NHS Ayrshire & Arran
Comments Received out with Consultation:
- Royal Pharmaceutical College (Scotland)
- Scottish Clinical Information Management in Practice (SCIMP)
- NHS Lanarkshire
Consultation Feedback
The responses were analysed by the National IG Policy Lead for Health and Care (Scottish Government) and the Chair of the National Records Management Forum. A summary of the feedback is offered below.
General Overview Comments Received:
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- “The new Code of Practice is very comprehensive and informative. Particularly the Code of Practice is clearer regarding specific roles, for example the role of Archive in the management of records.”
- Consultation comments received were supportive of the need for governance and storage of data that relate to patients, and in particular data pertaining to the results of clinical laboratory investigations.
Sectors for consideration to be included within the Code of Practice in future versions:
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- Prevention and healthcare in schools – includes screening for sensory disability, dental inspection, Child Smile, public health records held by public health directorates and local authority environmental health departments
- NHS custody services and Forensic Medical Examinations where the purpose is healthcare.
- Residential and nursing care home records – these records form part of the person journey.
- Reference to medical microbiology, medical virology, clinical biochemistry, immunology and haematology.
Feedback responses that may require a substantial amount of additional work will be considered as part of the “continual update” approach. The Records Management Forum will coordinate short life working groups and further consultations as needed in order to address areas that need substantial work e.g. review of current guidance for the management of transgender information in health and care records.
Return to main page for the Records Management Code of Practice