###### Definitions of ' Personal ' , ' Pseudonymised ' and ' Anonymised Data '

Where possible, patient identifiers should be removed and the data should be anonymised or pseudonymised.

Personal data relates to any information relating to an identified or identifiable living person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Please note that combinations of variables can make a person more identifiable than any single variable alone, even if direct identifiers have been removed.

Pseudonymisation of data can help reduce privacy risks by making it more difficult to identify individuals, but it is still personal data. If the identifiers can be replaced so that the data can be linked back to the individual, then the data is only pseudonymised and still counts as personal data under data protection law. Most data obtained from NHSS would be classed as pseudonymised, as the identifiers for the patients within the proposal are usually held by someone, even if they are not accessed by the applicant and their team.

Anonymisation refers to the process of removing personal identifiers (directly and indirectly) that may lead to an individual being identified from that information, or combined together with other information. If personal data can be truly anonymised, then the anonymised data is not subject to data protection law. If there is no way in which the data can be linked back to an individual, by anyone, it can be classed as anonymised. Once a dataset is anonymised, this cannot be reversed.

The Data Protection Act 2018, section 171 states that 'I t is an offence for a person knowingly or recklessly to re- identify information that is de-identified personal data without the consent of the controller responsible for de- identifying the personal data. '

Information about a deceased person does not constitute personal data but it is still subject to the Common Law Duty of Confidentiality.

## Information Governance Training

Although there are a number of Information Governance (IG) courses available in different NHS boards and Trusts throughout the UK, there are few courses that are available to all applicants, and many do not sufficiently cover the IG requirements for the handling of large amounts of health data. HSC-PBPP does not have the capacity to assess all available IG courses, so has limited the approved ones to those that are widely available and of sufficient depth. The HSC-PBPP-approved IG training courses are listed in Table 4 of Appendix A. HSC\_PBPP requests the IG training is updated every three years, regardless of the of the time-frame for which the course provider might say the training is valid. All those with access to the data must have valid IG training throughout the whole of the time for which approval is given and data is accessed. If your IG training will expire before your HSC-PBPP approval expires, your training must be renewed in sufficient time to continue to access the data.

Evidence of IG training is an important aspect of all applications, giving assurances that individuals are aware of the privacy, confidentiality, data protection and Caldicott implications of working with personal