Posted on: 10 August 2023
CNWL’s information Governance team led a Quality Improvement (QI) project to improve Subject Access Requests Compliance to 95%.
But what is a SAR and why is it important?
SARs are a statutory requirement under the Data Protection Act 2018, and the UK General Data Protection Regulation (GDPR) that allow individuals to view and receive a copy of their personal data that is being 'processed.' This applies to both patients and employees.
Complying with a SAR within the allocated one calendar month demonstrates that CNWL is fulfilling its commitment to being compliant with the GDPR’s accountability and transparency principles. Non-compliance with this statutory right could lead to reputational damage to the organisation and regulatory action by the Information Commissioners Office.
Identifying the issue and aim of the QI project
Due to the complex nature of the Trust, it continues to receive a large number of SARs on a monthly basis. At the start of QI project, the monthly compliance rate of the Trust ranged between 55% and 85%. The team wanted to change this by improving SAR monthly compliance to 95%.
What did they do?
After consultation with key stakeholders, the team came up with some ideas to bring about change. The following ideas were implemented:
- Bespoke training sessions are now available to all SAR coordinators who are processing SARs.
- Bi Monthly Information Governance (IG) Forums have been set up to provide support and guidance to SAR Coordinators
- Guidance on serious harm test and the SAR process have been updated and circulated.
- Information Governance team worked with Community Living Well Kensington and Chelsea as a pilot area to test the change ideas before rolling them out trust wide
Feedback from some of the ideas implemented throughout the project was positive. For instance, introducing the bespoke training sessions virtually to all SAR coordinators was well received. The team learnt that many staff members needed up-to-date knowledge in this area. Due to high demand, more training sessions have been created bi-monthly.
Setting up the IG forums was also effective. During these sessions, the team learned that different processes were being followed when manging SARs. Therefore, there was a need for a standard process across the board.
Additionally, the team saw a 39.9% decrease in the average time it takes to process a SAR request - and importantly, have achieved an overall compliance of 98% in February 2023.