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What is ‘personal data’ and may I upload it to SimActive?

Our Website Terms of Use say “You agree not to upload to any part of our site any personal data relating to a third party as defined in the Data Protection Act 1998 (including, without limitation, the names of patients).” So the next question is: what is ‘personal data’?

The Department of Health refers to the Caldicott review, and on p.65 the table cites “De-identified data for publication” as “Personal confidential data which has been anonymised with a low residual risk of re- identification. This means third parties can only re-identify the persons with unreasonable effort.” for which there are “No conditions for disclosure. Data may be published.”. So you need to remove any identifiable information from the data, and a list of identifiers to avoid is on page 138.

You will probably want some way to track back from the display to your own patient records. The Information Commissioner’s Office also provides detailed guidance on this. In the closest example, we are in the position of the second company. So when using a linking code, you should consider using a purpose-specific alternative that you keep to yourself, such as the row number of a lookup table.

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