Purposes for processing

Medical revalidation is a process for evaluating that a doctor is up to date and fit to practise, introduced in December 2012. Every licensed doctor who practises medicine in the UK must have an annual appraisal and recommended as being up to date and fit to practise, by their responsible officer to the GMC, every five years. All designated bodies with connected doctors must appoint a responsible officer to oversee the revalidation of their doctors.

The (national) Senior Level Responsible Officer (SLRO) for Medical Revalidation in NHS England, supported by the four (regional)  Higher Level Responsible Officers (HLRO), must be assured that all responsible officers and designated bodies are discharging their statutory responsibilities and will support them to achieve this. The SLRO in NHS England is also responsible for the revalidation of primary care medical practitioners in England that are on the medical performers list.

In order to allow NHS England to discharge its duties as a designated body, the personal details of all doctors in England, appraisers and responsible officers, (together with the contact details of administrators, Medical Directors, Clinical Appraisal Leads and Chief Executives of designated bodies in England), are held within NHS England’s Revalidation Management System (RMS).  The system links to GMC Connect  to make revalidation recommendations and also to ensure that the databases remain synchronized.

The medical revalidation and appraisal processes have been designed so that the appraisal inputs are confidential between the doctor and their appraiser. For more information about the use of information during the revalidation please refer to the Medical Appraisal Documentation Access Statement.  Also the Medical appraisal policy – Annex H regarding Information Governance.

To facilitate payment of appraisals, RMS holds the supplier reference number for the appraisers and in some cases it also holds information such as the National Insurance Number and Pension Scheme Reference number where NHS England manages the pension contributions.

Sources of the data

The data is obtained from the appraisees, appraisers and responsible officers in designated organisations.

Categories of personal data

The RMS system includes personal details of doctors who have been appraised. It also includes information on education and employment history, alleged criminal offences and convictions, and health information, where relevant, to their appraisal. To facilitate payment of appraisers, RMS holds the supplier reference number for the appraisers and in some cases it also holds information such as the National Insurance Number and Pension Scheme Reference number where NHS England manages the pension contributions.

Categories of recipients

The information in RMS will primarily be accessible to responsible officers and their administrative staff.  However, certain other persons, including medical directors and regulatory bodies, may have access to the information, as explained in the access statement, referred to above. The information in RMS will only be shared with other organisations for the purposes of medical revalidation or otherwise where there is a legal power to do so, with the agreement of NHS England’s Caldicott Guardian.

Legal basis for processing

For the GDPR purposes NHS England’s lawful basis for processing is Article 6(1)(e) ‘…exercise of official authority…’. For the processing of special categories data, the basis is Article 9(2)(h) ‘…health or social care…’.