Data Protection Considerations
For the Digital Growth Charts API Server
The dGC server Application Programming Interface (API), and the service we provide around it, has been designed with privacy and information security in mind.
API Requests Contain No PID
The data sent to our server does not contain any Personally Identifiable Data (PID) or identifiers such as patient name, NHS number, any other numeric identifier, or address data. It does contain date of birth because this is required to calculate the age of the patient, but this is not saved to the server.
The API is Stateless
The term 'State' in computing is equal to 'saved data'. In computing terminology, if an application is 'Stateful' it means it saves some information on the API server and thus can remember 'state' between two requests to the API. Conversely, a system that is 'stateless' does not save any data on the API server.
The Digital Growth Charts API is 'Stateless' by design, meaning it does not persist information between web requests. Each request from the API-consuming application to our API contains all the information required for our Growth Chart server to calculate a set of centile data. The response we send back contains this data, and it is never saved on our server. Some information about the requests made is kept for a maximum of 72 hours in the logs of our server, to enable us to monitor performance and debug problems, however, this information is anonymous.
Persistence of results in Medical Records
Because our API is stateless, any 'persistence' (data saving) must happen in the application which is consuming the API, which is the natural place to persist data anyway, since this client system is likely to be an existing GP system, hospital Electronic Patient Record, or Personal Health Record - which likely persists lots of data about the patient.
Legal basis for Requester (client) persistence
Your legal basis for persisting data on the client side is likely to be 'Direct Care', if your organisation is providing medical care for the patients whose data you're persisting. If your organisation doesn't provide direct individual care for these patients, then you may need a different legal basis.
For example, if your project is purely for research or planning then you may need to have consent from patients to persist their data. Either way, your organisation should be registered as a Data controller with the Information Commissioner's Office (ICO) and there should be a named person in a role, such as Data Protection Officer or Caldicott Guardian, who can provide advice and ensure there is a valid legal basis for the data you collect. You may need to conduct a Data Protection Impact Assessment.
RCPCH dGC Data Protection Impact Assessment
In view of the stateless nature of the server, the RCPCH doesn't handle any Patient Identifiable Data for this platform. We have reviewed the privacy implications of the Digital Growth Charts platform, and it does not require a full Data Protection Impact Assessment, according to our review of current Information Commissioner's Office guidance, for the reasons described above.
For the Digital Growth Charts API Service provided by the RCPCH
The API developer portal collects the essential minimum details from Consumers/Integrators/Customers, so we can provide them a safe, reliable API service. Use of the service requires some data to be collected. This data is retained only for the duration of the customer's use of the API service, after which is it deleted.
|Data elements||Reason for collection|
|Name||As a point of contact with the organisation|
|Email Address||As a point of contact with the organisation|
|Name of Organisation||To understand the likely needs of the customer|
|Customer's intended products for integration||To understand the likely needs of the customer|
|Estimated API volume usage||To help us find the best API usage plan for the customer|
See our Privacy Notice for further details.
For other products
Most of our products do not collect or store any data whatsoever. These include:
- the dGC
- the dGC React client demo
- the dGC React component library
- the React Native client
- the dGC command line tools
- the Google Sheets plugin (note: it's possible that Google or other services collect data about you during your use of this plugin)