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FOI - 962 Organisation Key Roles

 

Information Requested:

Thank you for considering and responding to my Freedom of Information request.  I am seeking to better understand how Wales’s Health Boards are using healthcare data to improve, integrate, and transform health and community care across their regions.  Therefore, I am inquiring about your Health Board’s relevant key roles and strategies.

Regarding Key Roles: do you employ the following roles within your Health Board?

•            Chief System Integration Officer/Chief Integration Officer (or Director),

•             Director of Digital Products & Improvement Analytics (or Deputy/Associate),

•             Director of Partnerships & Digital Lead (or Deputy/Associate),

•             Head of Digital Solutions and Adoption (or Director),

•             Head of Digital Innovation (or Director),

•             Director of Digital Transformation (or Deputy/Associate),

•             Director for System Strategy (or Deputy/Associate),

•             Director of Integration  (or Deputy/Associate),

•             Director of System Partnerships (or Deputy/Associate)

If no roles match verbatim, are there similar management-level roles regarding digital strategy to drive improvement, integration, and transformation?

Regarding specific strategies: can you please answer the following?

•             Do you have specific plans for integrating data between primary, community and secondary care?

•             Do you have a baseline mapping of your system digital infrastructure in place?

•             Do you have a public facing digital strategy?

•             Do you use 'Patients know best' or other similar system?

 

Information provided for the answer:

Thank you for your request dated 20 July 2022. Public Health Wales does not recognise the roles listed. Within our organisation we have a Director of Operations & Finance and a Head of Digital Experience and Services, who we feel would possibly cover the roles listed, with support staff.

•             Do you have specific plans for integrating data between primary, community and secondary care? Please see attached a copy of our IMTP which has been approved, but not published yet as it is currently being translated in to Welsh. Particularly, the section on Maximise the use of digital, data and evidence to improve public health (strategic theme 4; Pages 73-79). A few of the objectives sitting within this section would cover your question.

Do you have a baseline mapping of your system digital infrastructure in place?  Section 38

•             Do you have a public facing digital strategy? No

•             Do you use 'Patients know best' or other similar system? No

Section 38(2) – Health and Safety of the Act – which states that:

38(1) Information is exempt information if its disclosure under this Act would, or would be likely to –

(a) endanger the physical or mental health of any individual, or

(b) endanger the safety of any individual.

(2) The duty to confirm or deny does not arise if, or to the extent that, compliance with section 1(1)(a) would, or would be likely to, have either of the effects mentioned in subsection (1).

 

Public Interest Test

Public interest considerations in favour of releasing the information.

 

There is a general public interest in openness and transparency in public sector bodies which can help to maintain public trust.

Information relating to Public Health Wales protective security measures in relation to its systems are clearly matters of public interest and we recognise that there is a legitimate interest in knowing that security measures are in place and where they are focused.

 

Public interest considerations in favour of refusing to release the information.  

 

Public Health Wales has a duty to protect the public and individuals, and to provide a safe and effective public health service. The release of information under FOIA is ‘release to the world’ and I feel that releasing this information into the public domain would not be in the public interest.

 

Public Health Wales protective security measures that exist are there to protect our systems which are used to directly assist with the provision of patient care. It has been established that any groups who may be planning cyber-attacks are known to conduct extensive research into the opposition they might face and the release of any information which is held about the security of our systems, no matter how innocuous such requests may appear, may enhance the capability of cyber terrorists and hackers to carry out such attacks.

 

Releasing any information held could enable hackers and cyber criminals to gain knowledge about Public Health Wales capabilities and IT security measures, and this could enable them to plan attacks where they perceive a lower level of security resource exists. This exposes our IT systems to greater risk and therefore it also follows that risk to our systems will also constitute a risk to both public and staff of Public Health Wales as our systems are used to provide patient care.

Balance of Public Interest Test

 

Public Health Wales concedes that there is a very real interest in the public knowing that it has adequate levels of protection in place for its IT systems to ensure that we limit any potential for risk befalling the systems on which we heavily rely upon to complete our day to day business and for running the organisation. 

 

However Public Health Wales believes that ensuring the safety of our systems is paramount and on the balance of the information provided above Public Health Wales believes that there would be a clear causative link between releasing the

requested information which could then expose Public Health Wales to the risk of crime which could subsequently endanger or cause harm to our patients. Public Health Wales believes that confirming or denying the information requested is held could expose Public Health Wales sites to hackers and cyber criminals this in turn could lead to Public Health Wales being unable to deliver and provide patient care thereby resulting in a real risk of potential harm to our patients and staff and endanger individuals who are depend upon our IT systems for the care they require.

 

Public Health Wales therefore believes that the public interest in releasing this information outweighs any arguments for disclosure and so we will neither confirm nor deny that we hold the information requested.

John Lawson

Head of Information Governance

Public Health Wales NHS Trust

 

 

 

If you are unhappy with the service you have received in relation to your request and wish to make a complaint or request a review of the decision, you should write to the Corporate Complaints Manager, Public Health Wales NHS Trust, 3, Number 2, Capital Quarter, Tyndall Street, Cardiff, CF10 4BZ.

If you are not content with the outcome of your complaint or review, you may apply directly to the Information Commissioner for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Trust. The Information Commissioner can be contacted at:

Information Commissioner for Wales
2nd Floor
Churchill House
Churchill Way
Cardiff
CF10 2HH

Telephone: 029 2067 8400
Email: wales@ico.org.uk