This is a case study for Principle T6: Data governance.
The Scottish Government’s (SG) health and homelessness in Scotland project linked local authority data about homelessness between 2001 and 2016 with NHS data on hospital admissions, outpatient visits, prescriptions, drugs misuse, and National Records of Scotland information about deaths.
Transparency around the risk assessment process helps to demonstrate a producer’s Trustworthiness to users, suppliers and the public. One of the ways that SG were able to demonstrate this was by conducting and publishing their data privacy impact assessment alongside the main analysis report. SG also published the original application for the data, the public benefit and privacy panel application and the correspondence documenting its approval, and details of how to access the data. This approach is now standard practice for all SG publications based on linked data.
Since SG carried out this work, a new tool for risk assessment – Data Protection Impact Assessments (DPIAs) – have been introduced following the 2018 Data Protection Act (DPA), as a requirement of GDPR. They are mandatory where data are combined from multiple sources and the Information Commissioner’s Office recommends they are also conducted on a voluntary basis for any large-scale processing of personal data.
The accountability principle in the DPA requires organisations to have appropriate records in place to demonstrate compliance if required. Departments can meet the DPA accountability principle by conducting a DPIA, and publishing them helps to meet the Code’s requirements for transparency (providing that they are accessibly presented). It isn’t essential to publish a DPIA in full, a summary of the process and the lessons learnt would be sufficient to demonstrate transparency.
Another step producers can take to increase transparency is to publish details of all the data share requests made to them and their outcomes. SG publishes details of the data sharing requests submitted to its Statistics Data Access Panel on its website, which also includes details about past decisions made and the justifications for those decisions.
The Department for Education in England has also been publishing details of the data share requests and outcomes in relation to ad hoc National Pupil Data Sharing for several years. In December 2017, the Department for Education broadened the scope to cover all routine sharing of personal data and have recently consulted users about further changes to make this easier to engage with and understand.
These examples show how Trustworthiness can be demonstrated by statistics producers being transparent about their approaches to the management of the data linkage process and data shares, and their relevance to some of the current legislation in this area.