Beyond-care sharing route

Planning, commissioning, service management, audit, research, public health, population health and product development are not automatically covered by the direct-care route.

Order of preference

1. Use genuinely anonymous information where it can achieve the purpose.
2. If personal information is necessary, reduce identifiability and access while recognising that pseudonymised data remains personal data for parties able to re-identify.
3. Identify the controller’s function and complete Article 6, Article 9 and DPA Schedule 1 analysis.
4. For CPI, establish a separate confidentiality route: explicit consent, a specific legal requirement, section 251/COPI support, or a documented overriding-public-interest basis.
5. For identifiable GP record data leaving the practice/system, apply the Type 1 opt-out; separately apply the national data opt-out where the use/disclosure is in scope and no current exemption applies.
6. Screen for a DPIA and complete it before processing where likely high risk; otherwise document the screening result. Put agreements, transparency, security, retention and audit controls in place, and obtain specialist approval where the chosen route requires it.

Section 251 is not a blanket permission. It enables regulations supporting defined medical purposes where anonymised information is not practicable and approval conditions are met. SRC-008

The Type 1 opt-out operates at GP-system level for identifiable GP record data leaving for beyond-care purposes. The national data opt-out applies to many later uses and disclosures of CPI beyond individual care in England. Each is a patient choice mechanism, not a lawful basis. Properly anonymous data and some defined exceptions fall outside the national data opt-out; both results must be recorded rather than assumed. SRC-009 SRC-033

See research, planning and audit, opt-outs and section 251, and the sharing route decision workflow.