GDPR Data processing modelHealthcare Data Processing via Secure Messaging (UK NHS context)

Sector: HealthOrganisation: Public

Processing of patients’ and healthcare professionals’ data through a secure NHS-compliant messaging system, enabling lawful, confidential exchange of health information between authorised professionals.

Purposes (2)

A purpose is the objective pursued by the setting up of your file. It indicates what the processing of personal data will be used for, its purpose. This purpose must be clear and understandable

Exchange of health data between authorised healthcare professionals via secure messaging

Public interest

- UK GDPR Art. 6(1)(e) – task carried out in the public interest / official authority.

Exchange of health data between authorised healthcare professionals via secure messaging

Public interest

Art. 6(1)(e) UK GDPR – public task (provision of health care by NHS bodies), with Art. 9(2)(h) and DPA 2018 Sch. 1, para. 2 (health or social care purposes). Private providers not exercising a public function rely on Art. 6(1)(f) or 6(1)(b), with the same Art. 9 condition.

Data categories (3)

Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified either directly (eg surname and first name) or indirectly (eg phone number, social security number, email or postal address, but also voice or image)

Patient Data

Data details

health datarequiredsensitive data

NHS/NI numbersrequiredsensitive data

Emailrequired

phone numberrequired

Addressrequired

Genderrequired

Date and place of birthrequired

first and last namerequired

Data conservation rules

Active base:

For as long as needed to exchange information for the patient's care between the professionals involved. Clinically relevant messages and attachments must be filed in the patient's health record, which is then retained under the NHS Records Management Code of Practice (e.g. adult health records generally 8 years after the end of treatment; GP records 10 years after the patient's death).

NHS Records Management Code of Practice

Intermediate archiving:

Messages kept in the secure messaging system once filed in the health record: no statutory period applies; the controller should set a period, e.g. deletion of a mailbox after 1 year of inactivity, based on the need to trace exchanges between professionals. Access and audit logs: no statutory period applies; the controller should set a period, e.g. 1 year, based on security monitoring and the investigation of incidents, extended while an investigation is ongoing.

Destruction

System Administration Data

Data details

Natural person identifierrequired

Job function required

Name and surnamerequired

Data conservation rules

Active base:

Duration of administrative role.

Intermediate archiving:

Deleted after 1 year of inactivity.

Destruction

Healthcare Professional Data

Data details

Traces of actions on messagingrequired

Cookiesrequired

IP addressrequired

Secure health messaging addressrequired

professional titlerequired

Emailrequired

phone numberrequired

Data relating to means of authenticationrequired

Registration number for the shared directory of healthcare professionalsrequired

Name and surnamerequired

Data conservation rules

Active base:

For the duration of the professional’s registration and role.

Intermediate archiving:

Mailbox deactivated when the professional leaves the role. No statutory period applies; the controller should set a period, e.g. deletion 1 year after deactivation, once clinically relevant content has been filed in patient records. Access and audit logs: no statutory period applies; the controller should set a period, e.g. 1 year, based on security monitoring needs.

Destruction

Data subject (3)

A data subject is any person whose data is collected, retained or processed by the data processing. e.g. In a recruitement process, any candidate for a position proposed in recruitement management process

Patients
Other
Healthcare Professionals

Created at:07/08/2023

Updated on:10/05/2026

Nb using:11