FUTURE MEDICAL EQUIPMENT LTD
THE MANAGEMENT OF SENSITIVE AND CONFIDENTIAL PATIENT DATA
The Data Protection Act 1998 (DPA 1998) enforces organisations that holds and processes personal information to manage the data in line with a number of specified principles. Organisations must ensure any personal details held and processed are for specific purposes, held for reasonable timescales, current and up to date, reviewed regularly, kept secure, including adequately deleting and removing from systems once obsolete or when disposing of hardware.
Future Medical has a responsibility to all clients, not only where we hold personal information but where we are contracted to remove medical devices for resale or disposal, that contain sensitive and confidential patient data.
This procedure note sets out the steps Future Medical take to ensure compliance with the DPA 1998, in managing, deleting/removing patient data, that supports our client to meet their obligations.
PROCEDURE FOR MANAGING PATIENT DATA
When liaising with a client regarding a potential purchase or disposal of equipment, the client will be responsible for notifying Future Medical whether the equipment for disposal holds patient data. We will then discuss the following options to ensure compliance:
- Unless agreed in writing, any system being removed by Future Medical must be fully functioning on the agreed day of removal.
- If the system is not fully functioning, Future Medical withhold the right to withdraw from any purchase agreement and charge accordingly.
- If patient data is evident on the equipment on the day of removal, Future Medical will revert to Option 2 below.
- The Client takes Responsibility
Future Medical will establish whether the client has the ability to wipe/remove the data and agree to undertake prior to removal of the equipment. Please note that the system must be left in fully working order to allow the planned removal to take place.
Documentation: The client will provide evidenced confirmation that the process has been carried out, prior to Future Medical removing from site.
- Future Medical Run the Standard OEM Data Deletion Programme
Where the client is unable to arrange the data deletion, Future Medical will use the OEM service programme to perform full patient data deletion in accordance with the OEM process. This process is non-chargeable but on-going liability remains with the Client.
This process will be undertaken on site, prior to removal as follows:-
- Future Medical Engineer will test the functionality and check if patient data is present.
- If patient data is present, the Engineer will utilise the specific modality OEM procedure. This can vary from built in programs to manual record deletion.
- Following completion, the Engineer re-checks the system to ensure all patient data has been deleted.
- The client representative will witness and sign to agree the process is complete.
Documentation: Future Medical will provide the client with documentation to confirm completion of this process.
- Future Medical Removal and Replacement of Hard Drives and Software Reload
As a final option, Future Medical can remove the system hard drives and leave these with the client contact on site. Future Medical will source replacement blank hard drives and reload all system software and licences to these new drives.
For this option Future Medical will require all system software, back-up disks and software licences to be present on site. This process can take up to two days and Future Medical will therefore require access to the system for sufficient time prior to the removal date.
This service is chargeable and Future Medical will provide a quotation to provide this service.
Process: Every attempt will be made to undertake this process while the equipment is on the client site. Where this is not achievable, Future Medical will ensure:-
- The equipment is packaged and labelled to confirm the presence of patient data, prior to removing from site. A Data Processing Form will be completed by Future Medical to confirm our responsibility under the DPA 1998 and the timescales for the data removal and signed by both parties. Future Medical will then securely transfer the equipment to storage, isolating from all other stored equipment, pending completion of the data removal by the appointed OEM/Supplier.
Documentation: A hand-over form will be signed by the Client confirming receipt and responsibility of the hard drives.
Future Medical Equipment Ltd Mandy Davis
Data Protection Officer: firstname.lastname@example.org
DDI: 0117 916 2076
Mob: 07955 329186