Dear Colleague 

Wales National Workforce Reporting System and GMPI

Your practice will have received a communication from NWSSP this week which asks you to provide workforce data by 14 June. I’m writing to advise on how you might engage with the data collection tool, and what to bear in mind when doing so.

Firstly, Welsh Government has decided to unilaterally implement completion of a workforce webtool as a requirement for the ongoing provision of the state backed indemnity to practice teams. Frustratingly, this is despite the mandatory completion of the tool remaining part of the ongoing formal contract negotiations for 19/20.

We understand that practices will view this as needing to be completed, given the need for their practice teams to be covered by indemnity. We completely understand and concur with this concern (despite our unhappiness at this being sent out before reaching the end of contract negotiations). 

Whilst Welsh Government cannot mandate practices to provide this data under the indemnity regulations, we don’t think that it would be helpful to refuse it - given that at a practice level it could be useful for workforce planning. However, how this information is provided does not necessarily require completion of the workforce webtool itself, or indeed all parts of it.

When providing the information please give due consideration to the following: 

• Practices only have to fill in the mandatory fields, and none of the optional ones - as some of the optional ones would be classed as protected characteristics and we feel are not relevant to wider workforce planning. For clarity the mandatory fields will be marked on the toolkit page. For ease of reference the mandatory fields are noted at the bottom of this communication.
• Practices need to complete it for all staff involved in clinical services e.g. this would include reception staff who process clinical information for the purposes of triage. 
• Individual practice data will only be viewable by the practice and the Associate Medical Director of the Health Board - all others involved in workforce planning (e.g. at cluster / HB / WG level) will only have access to anonymised aggregated data, which will be held by NHS Digital.
• Is there a risk to practices of being found responsible in the event of a data breach?

Welsh Government has said this risk is negligible as all information is anonymised. We have asked several times to have this assurance in writing – however this has yet to be suppled.

GPC Wales was promised a specific GDPR compliance information guidance sheet for practice managers and staff but we are disappointed that this was not supplied alongside the communication.

Furthermore, the issue of obtaining individual consent to sharing this data is obviously something we believe is good practice and essential for the confidence staff and practices might have in the process – however ,we have been advised by the NWIS Data Protection Officer, who in turn cites the ICO statement that consent needs to be specific and freely given, hence  Public Authorities and employees being in a position of power may not be seen to obtain consent freely. It is the DPO’s advice that personalised data may be released by the data controller under clauses in article 6 & 4 in GDPR and clauses such as "Processing data to satisfy a condition for processing necessary for performance of a task or contract" would be a better fit for this purpose. Again, GPC Wales has asked for sight of this and that it be covered in a guidance briefing for practices. This is still outstanding.

In light of the above we would strongly advise practices to contact the DPO (data protection officer) or the Health Board to request this assurance / guidance prior to completion of the workforce tool (explaining not refusing to complete dataset but require this assurance prior to sharing sensitive personalised information).

Finally, please remember that the provision of the dataset required for the purposes of cover under the scheme could be completed in other ways e.g. utilising the previous spreadsheet used by many HBs in annual returns. If, as a practice, you decide that you do not wish to utilise the tool, you could offer to supply the information in an alternative format as before - we would recommend you inform your LMC at the time you advise the Health Board of this. 

*We have queried why these are noted as mandatory

If you have any questions about the above please direct them to ourselves at This email address is being protected from spambots. You need JavaScript enabled to view it. or to your LMC. 

Dulaine Mulcahy 
Committee executive officer (GPC Wales)/Swyddog gweithredol pwyllgorau

BMA Cymru Wales 

Y Gymdeithas Feddygol Brydeinig/British Medical Association 
Ffôn/Tel: 029 2047 4625 neu/or: 07773 428873 |Ebost/Email: This email address is being protected from spambots. You need JavaScript enabled to view it. 
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