Pan-London DSA Project


A project to improve data sharing across London

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Status: Live

Introduction

Organisations across London share personal data daily to deliver their statutory obligations, prevent crime or harm, and improve the wellbeing of residents. There are many Data Sharing Agreements (DSAs) across London borough councils, the Metropolitan Police, health trusts, the Probation and London Ambulance Services, voluntary sector groups, and more. 

There is pressure on national or pan-London organisations who must agree to multiple DSAs for the same purposes, and there is a constraint that different organisations have different geographical boundaries. It is difficult for organisations to sign multiple agreements for the same subject/purpose, or to expect their staff to work under different DSAs depending on the location of the individual with whom they are working.

The fundamentals of sharing data for many public sector purposes are the same across local authorities and the police, so there is no need to have multiple agreements saying the same thing in slightly different ways. It is preferable to have one agreement; to provide clarity to professionals and promote a shared understanding of when and how information should be shared.

 

One of LOTI’s key goals is to tackle barriers to effective data sharing, and this project is a significant contributor to that aim.

 

Project Goals

 

The project began at the end of 2020 with the desired outcome of a DSA with the Metropolitan Police that all London Boroughs would agree to sign. Historically, there was no coordinating force across London for data sharing and although some groups worked together, succeeding with an agreed DSA across so many partners was a struggle. 

 

Problems

 

  • Pan-London organisations had 33 creation and approval processes for any DSA (for one with each borough and the City of London).
  • Relevant professionals were being missed when deciding on data sharing and drafting an agreement.
  • It took years in some cases to approve a DSA. By the time an agreement was in place, it was time to start the review process.
  • Staff with less data sharing experience felt less confident drafting or agreeing a DSA.
  • Frustration and confusion occurred, with too many parties involved and delays to completion.
  • Organisations had preferences for the structure and branding of a DSA which delayed or halted creation.

 

The Pan-London Data Sharing Project began with the ambition to create one DSA for London, for the purpose of Multi-Agency Safeguarding of Children.

 

To achieve this, the London Safeguarding Children Partnership Board and the Information Governance for London group (IGfL) created a working group approach [link to doc]. This accomplished a finished agreement in 3 months, with less combined officer time required. Following this, IGfL began working with the police on several core DSAs that cover areas of statutory responsibility for the police and councils.

 

Project Success

There were issues and successes, both of which led to the development of a role for a central coordinator.

Issues 

  • It was sometimes difficult to get people to volunteer to be a participant in a working group.
  • Leadership of the project took considerable time.
  • There were some knowledge gaps among participants.
  • Progress on some DSAs slowed without a coordinating force to seek progress checks and mediate issues.

However, the working group approach allowed for:

  • Less officer time being needed overall
  • A balance between enough professional input to achieve the objective, while reducing the total number of people involved and the amount of duplicate or contradictory comments.
  • Improved experience and knowledge of data sharing processes for some IG officers.
  • An improved collaborative relationship between the Metropolitan Police and London Boroughs.

The project worked on steps 4 and 5 of the LOTI 7-Step Information Governance Process, which had previously been developed with IGfL.

 

The success of this approach over the next year prompted the trial in January 2022 of a 3-month, co-funded, part-time role to complete in-progress DSAs more quickly. The success of this role, and other drivers from London, led to the creation of London’s first Pan-London Information Governance Lead (PLIGL). This role sits within LOTI, funded by London Councils, the Metropolitan Police, and the GLA. Leading the creation and review of pan-London DSAs is part of the role’s responsibilities.

 

The project was also successful in raising the profile of IGfL as a peer body that can positively influence change, and in improving recognition of the need to ensure that information governance is incorporated early in projects.

 

Get Involved

 

If you would like to engage with this project to develop a pan-London DSA or discuss data sharing opportunities, please contact Victoria on victoria.blyth@loti.london. 

 

If you are a member of an organisation that is a party to an existing DSA then we recommend that you contact your organisation’s Data Protection Officer or Information Governance Team first.

 

DSAs are hosted on the Information Sharing Gateway

 

 

The Pan-London DSA working group approach

 

Information Governance for London (IGfL) acts as coordinator, with a working group for each DSA. The working group is an experienced selection of professionals in multiple specialisms from local authorities, health and police, who have engaged with front-line practitioners and other local agencies, like the voluntary sector. Each working group is led by an information governance professional from a London borough, part of the IGfL membership, and incorporates professionals specialising in public sector duties, police procedures and crime prevention, information governance, and law

The working group members create a DSA, and a Data Protection Impact Assessment (DPIA). Multiple meetings and review periods take place. The group consults with any relevant colleagues to ensure the agreement is legally and factually correct, and accurately describes the data sharing and the lawful basis justification for the work. This liaison may involve other groups, such as the London Safeguarding Children Partnership or the London Heads of Community Safety. A final version is then published for signature by all parties. 

 

Agreement of the DSA

A DSA is an agreement between equal partners and each organisation has a responsibility to ensure it is correct and reflects their situation. However, coordinating the preferences of scores of parties is a struggle. The working group approach is designed to allow relevant professionals to develop an agreement without input from every party. The project provides confidence to all parties that a completed DSA includes all relevant information and requirements. 

 

Can organisations propose changes?

We hope that all parties can feel confident that an experienced group of professionals from multiple specialisms has included all relevant information and requirements. The working group members work to a structure and language that meet the requirements of all and avoids any personal or organisational preference for structure, language or design.  Therefore, we request that changes are only proposed where you believe there are material, factual errors.  All DSAs will be reviewed on a regular basis and any requested changes can be considered in the reviews. 

 

Can we add appendices or other documents to this DSA?

Each organisation is expected to have local protocols, policies and processes that cover the local specifics of its work under each DSA. These documents complement the DSA and should sit alongside it, but not added to it. The DSA is for all parties across London and so local changes cannot be made. 

 

Undertaking a Data Protection Impact Assessment

The sensitivity and volume of the personal data, and the vulnerability of the data subjects, means that the sharing under each DSA is processing that most likely requires a Data Protection Impact Assessment (DPIA).  Each working group produces a high-level DPIA which is published as part of the DSA.  It is suggested that each organisation can use this DPIA and include a ‘top-up’ for any specific local risks. A template for this top-up is provided, to use in whole or part (or not at all) as you wish.

 

DSA publication and agreement

 

DSAs are hosted on the Information Sharing Gateway (www.informationsharinggateway.org.uk) Home Page – Information Sharing Gateway

All London boroughs have a licence funded by the GLA. Other partners may choose to purchase a licence, or free registration is available, which provides for a small number of users to sign DSAs only.

 

DSA Review

 

A DSA will be reviewed when it meets its review date. In addition, changes in legislation and developments in the areas of public sector data sharing will be considered as and when they arise, as will any changes to the signatory parties.

 

A review assesses whether the purposes for sharing remain relevant, that the scope has not slipped, that the benefits to the data subjects and organisations are being realised, and that the procedures followed for information security are effective. 

Collaborators


Project Timeline


October 2022

Victoria Blyth begins working for LOTI as the Pan-London Information Governance Lead.

September 2022

The Child Protection - Information Sharing (CP-IS) system allows health and social care professionals to share key information regarding protected children, as they have a statutory responsibility and professional duty of care to safeguard the welfare of children.

June 2022

A DSA for the London Innovation and Improvement Alliance (LIIA) is published, to support sharing under multiple use cases for the Association of London Directors of Children’s Services (ALDCS) sector-led improvement partnership.

March 2022

Several more in-progress DSAs were completed. (YOS, Enviro Crime Councils, Adult Safeguarding, PABE, Supporting Families, Prevent)

February 2022

The MAPPA DSA is published. Multi-Agency Public Protection Arrangements are the statutory arrangements to facilitate the assessment and management of risks posed by relevant sexual and violent offenders in London. The Department of Justice oversees MAPPA work.

January 2022

The 3-month trial of a part-time coordinator officer begins. This provides the resource to complete several in-progress DSAs. (ASB, IOM, DA MARAC, and Residual Crime)

June 2021

The Licensing DSA is published, covering sharing for licensing activities undertaken by local authorities, including alcohol, gambling and food premises.

May 2021

The DSA for sharing data relating to the Metropolitan Police Gangs Violence Matrix (GVM) is published. The aim of the matrix is to reduce gang-related violence, safeguard those exploited by gangs and prevent young lives being lost.

 

January 2021

The Multi-Agency Safeguarding (MAS) DSA is published.

November 2020

The London Safeguarding Children Partnership Board and Information Governance for London (IGfL) begins work on the Multi-Agency Safeguarding DSA, for the protection and well-being of children and young people across the capital.

Project Kick-off

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