Prospective Access – October 2023 Update

Prospective access to patient medical records is still planned to go live in November although there are still discussions ongoing within NHS England and the BMA have also recently provided further guidance around a Data Protection Impact Assessment (DPIA) that all GP practices should carry out before the 31st October 2023. There have also been additional safeguarding concerns that have come to light that GP practices need to be mindful of.

The BMA guidance is quite comprehensive here:
BMA general practitioners committee England

with a useful FAQ here:

Additional concern has been raised about domestic violence risks relating to the automatic switch on that has been led by the charity Refuge:
Joint letter on concerns around survivors medical records on NHS app – Refuge

These concerns are also supported by the BMA:
BMA and Refuge highlight medical record access concerns for survivors of domestic abuse – BMA media centre – BMA

Fundamentally a decision needs to be made by GP practices around mitigating their own concerns based on a GP practice DPIA and also considering additional risks including those that were suggested in the clinical safety case completed by NHSE:
Clinical safety case report – Implementation Team – FutureNHS Collaboration Platform

Avon LMC have produced a useful flow chart to support decision making here:

So these are the steps practices need to go through now if not considered already:

1. Complete a DPIA based on this BMA template: bma-aatr-dpia-template.docx (

2. Decide if there are ongoing concerns.
– If concerns mitigated to code 104 to patients at high risk and then provide access
– If concerns NOT mitigated to consider an opt in model and bulk code all patients with 104 (and can exempt those with current online access)

3. Ensure all staff are aware of redaction processes: EMIS Web – Online Visibility (

4. Run searches to see who has current access and codes applied: GP PRACTICE ACTION for Patient Access to Medical Records – May 2023 – Dr

5. Download an AccuRx questionnaire florey for patients requesting access to complete:

6. Inform patients of prospective online access by downloading posters / screen banners / website banners from here: Access to Medical Records Resources – North East London (

7. If any change in decision outcome, to inform NHSE of the change in decision by emailing:
– NHSE on

8. If your DPIA suggests an opt in model you should consider informing your Primary Care team by using this email template: sample-draft-email-to-icb-primary-care-it-team-1-2.docx (

9. If your DPIA suggests an opt in model you should consider informing your ICB by using this template letter: template-letter-to-icb.docx (
This letter refers to a roadmap for implementing an opt in process. A suggested template is here.

10. If your DPIA suggests an opt in model you should consider informing the ICO by using this template letter: template-letter-to-ico.docx (

One thought to “Prospective Access – October 2023 Update”

Leave a Reply

Your email address will not be published. Required fields are marked *