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RCP issues data sharing consultation response

The Royal College of Physicians (RCP) has issued its response to a review of the potential impact that the memorandum of understanding (MOU) between the Home Office and NHS Digital might have on the health and healthcare-seeking behaviour of migrants.

In a letter to Duncan Selbie, CEO of Public Health England, the RCP outlined its support for a review into the effect this MOU may have on public health, following concerns raised in 2016. We also highlighted further concerns, which include:

  • the impact on individual and public health of a tracing service which may deter some migrants from healthcare
  • the compatibility of this tracing service with the law, data protection regulation and human rights
  • the compatibility of this tracing service with clinicians’ confidentiality responsibilities, and
  • how in practice officials will apply the public interest test to every individual tracing request.

Included in the letter is anecdotal evidence showing that the RCP is aware that individuals may be deterred from seeking medical attention:  

A case I saw a few years ago when somebody who was dropped off at a service station … was arrested. He clearly had pulmonary TB. The immigration services refused to take him, so he was released into the community and presumably then kept well away from health services to avoid detection. (Anonymous Physician)

The RCP's response said 'it eagerly awaits the findings of this inquiry and subsequent recommendations in relation to the memorandum'.

The MOU formalises existing arrangements for the Home Office to make disclosure requests to NHS Digital for the purpose of tracing immigration offenders and vulnerable people who may be at risk.


RCP Data-sharing consultation response 412.89 KB Uploaded: 9 April 2018