These steps ensure that the use of the new functionality is safe, legal and meets NHS standards.
Checklist: what you need to do
1. Accept the Data Processing Agreement (DPA).
What is it?
A legally binding contract that governs the relationship between your organisation (Data Controller) and Accurx (Data Processor), ensuring that we only process personal data on your behalf and strictly under your instructions.
Why is it important?
It is a mandatory legal requirement under data protection laws. Without a DPA, both the data controller and the data processor can be held accountable for non-compliance with the UK GDPR.
Where to find it:
Only Accurx admins for your practice will be able to view and accept the DPA in the Accurx inbox via a pop-up or in Accurx settings via a banner.
Someone who is authorised to enter into a contract on behalf of your practice must accept the DPA and terms & conditions during the opt-in process to enable Navigator for your practice.
Your practice won't be able to access Navigator until it has been accepted.
A copy of Accurx's DPA is available on our website
You can also view Accurx's list of sub-processors
2. Complete your organisation’s clinical risk management assessment (DCB0160)
What is it?
Evidence that your organisation is ensuring safe use of digital products, including Accurx Navigator, in patient care.
Why is it important?
This is part of a mandatory NHS safety process (called DCB0160). It applies every time you use software that can influence patient care.
What you need to do:
The DCB0160 clinical risk management assessment is sometimes completed on your behalf by your ICB or PCN.
If not, then you need to:
Appoint a Clinical Safety Officer (e.g. a GP or nurse)
Review Accurx’s DCB0129 documents showing that Accurx Navigator has been safely built and tested, meeting NHS safety standards. Contact our User Support team at support@accurx.com or use the in-product support chat to request a copy.
Develop a DCB0160 safety case and hazard log listing potential risks and mitigations. You can use our DCB0129 Hazard Log as a template for your DCB0160 Hazard Log. Contact our User Support team at support@accurx.com or use the in-product support chat to request copies.
Document processes and procedures for staff to raise safety concerns
3. Complete a Data Protection Impact Assessment (DPIA)
What is it?
A formal process to identify, assess, and mitigate the risks that a processing activity involving personal data may pose to individuals.
Why is it important?
It is a legal requirement whenever the type of processing is likely to result in a high risk to the rights and freedoms of individuals, such as when new technologies are used to process sensitive data.
What the law says a DPIA should include:
A systematic description of the intended processing operations and the purposes of the processing.
An assessment of the necessity and proportionality of the processing operations in relation to the purposes.
An assessment of the risks to the rights and freedoms of data subjects.
The measures envisaged to address the risks, including safeguards, security measures and mechanisms to ensure the protection of personal data and to demonstrate compliance with the law.
When using Accurx, it is up to the data controller (your organisation) to complete a DPIA. As a data processor, we cannot complete it for you. However, to be as helpful as we can, we have filled in the key parts of a DPIA Template for Accurx Patient Triage, which covers Accurx Navigator. You can find this and all our other DPIA templates on our website.
4. Review Accurx’s Digital Technology Assessment Criteria (DTAC)
What is it?
The DTAC is a consistent question set designed by NHS England to be used by healthcare organisations to assess suppliers of digital technologies at the point of procurement or as part of a due diligence process.
Why is it important?
It is used to make sure digital technologies meet NHS England’s standards for clinical safety, data protection, cyber security, interoperability and accessibility.
What you need to do
If required for your organisation, review Accurx’s DTAC. Contact our User Support team at support@accurx.com or use the in-product support chat to request a copy.
If you still have any questions or concerns, feel free to chat with us using the green message bubble in the bottom right-hand corner of this page. 👉