Summary of responses
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In total we received 31 responses to our consultation, and a full list of those who responded can be found here.The list includes government departments, NHS bodies, advice sector groups, professional bodies and other public sector ombudsmen.
We are pleased to see that the Information Promise and the Framework were well received, with many responses commenting on their quality and clarity.
Some respondents gave detailed responses to all of the questions in the consultation, whilst others broadly indicated their support for our approach. The summary below highlights the general themes and comments that emerged from the questions asked. Where we have used quotes, these are to illustrate some of the points made by particular organisations and should not be taken to reflect the entirety of their views.
We said 'The Information Promise is intended to be a clear statement that we value the information entrusted to us, will put the appropriate resources in place to look after that information and will report on how we are doing'. We asked if it did this. Of those who answered this question directly, 97 per cent agreed that it did.
The Parliamentary and Health Service Ombudsman's Information Promise, in my opinion, achieves and sets out the vision and ambition for which it is intended.' NHS Lincolnshire"
'Yes - adherence to these principles will ensure an open, honest and transparent approach which service users and organisations can feel confident in.' Walsall Healthcare NHS Trust
When asked where the Information Promise fell short and how it could be improved, the main theme that arose was accessibility. Respondents pointed to the value of making the Information Promise accessible to all our customers and stakeholders, including those with learning difficulties and physical and sensory disabilities. POhWER asked us to show leadership in this field, and they were not the only respondent to suggest that one possible way of doing so was to provide an Easy Read version of the Information Promise.
We agree, and the Information Promise is now available on our website both in an Easy Read version and as a web accessible tagged PDF.
Commenting on the content of the Information Promise, the Information Commissioner's Office said that there should be a clear statement that personal information will be kept to the minimum necessary and that once the information is no longer needed, it will be deleted. We are fully committed to the timely deletion of information and, where that information is personal, we adhere to the requirements of the Data Protection Act 1998. Our records management policy and our casework retention and disposal Schedules are accessible to the public through our Publication Scheme.
We said ‘The Framework is intended to set out clearly the approach that we will take to achieve the Information Promise and how we will measure its success’. We asked if it did this. Of those who answered this question directly, 83 per cent agreed that it did. A further 15 per cent welcomed the document but made suggestions for its improvement.
‘The connection of the promise to those who are or will be responsible for its delivery together with how you will measure success shows good intention, openness and transparency and is most welcome.’
The Welsh Government
Many respondents welcomed the detail in the Framework, and said this was necessary and important in explaining how the Information Promise will work. However, some respondents echoed the Ministry of Defence’s comment that the language of the Framework could be clearer and possibly shortened to make it easier for the general public to understand. Others thought that the Framework should set out what the Information Promise means in practice for different audiences, such as complainants or bodies in our jurisdiction.
We intend the Framework to be used in two ways:
- by our customers and professional stakeholders, to find out about the standards that we set ourselves; and
- by our staff, to set out how we will work and to provide a point of reference against which we can measure our performance.
We have already developed materials that will make the Framework more accessible and meaningful to those groups.
What happens to the information you give us is a new page on our website. It explains what happens to the information that complainants give us, who we may share it with, their rights to see it, others’ rights to see it, and how long we will keep it.
We have also developed The Information Promise: Guidance on legal obligations. This document is written primarily for staff so that they have a clear understanding of what the complex legislative landscape means for our work. However, we are making it available so that anybody who is interested in this aspect of the Ombudsman’s work can see it.
Over time, and as needs are identified, we will use the Framework as our reference point for further materials for both external and internal audiences. We are already considering what material our professional stakeholders need, especially those working in the new health landscape, and the content of that material will be informed in part by the responses we have received to this consultation.
We asked our respondents if there were any other comments they wished to make.
Respondents wanted to know more about our processes, such as our decision-making on redress, how and when we share information during an investigation, and our arrangements for keeping information secure.
At the end of March 2012 we launched a renewed Publication Scheme, which can be accessed through our website. It sets out what information we will routinely and proactively release.It includes documents such as our casework policy and guidance for staff, our records management policy and security policy.
Respondents also wanted to know more about the substance of our casework, recognising that the learning from this can be a powerful force for change.They wanted more detail of the complaints made to us and the outcomes so that they could improve their complaint handling.Other respondents wanted us to challenge the limits set by legislation and address any technical difficulties with making our reports more widely available.
We are fully committed to publishing more about our casework in a way that can be used to improve public services and inform public policy.We are already working with other organisations who recognise that there is a clear need for meaningful, comparable complaints information that can be used to help drive improvement in healthcare and strengthen the quality of services for patients and the public.
From July 2012 amendments to our legislation enable us to share our decisions about NHS complaints more widely.When we decide not to investigate formally, we will be able to share the reasons for that with the organisation complained about.At the same time, we will look at publishing more information about the NHS complaints coming to us, seeking to highlight good practice as well as bad.
Several responses raised the issue of compliance.We recognise the importance of testing, learning and adapting our new approach.We are committed to reviewing the Information Promise regularly to ensure that it is up to date and relevant.The Framework also sets out how we will monitor and report on compliance.
Finally, some respondents asked how we would link our Information Promise to the government's transparency agenda and the various cross-government publication schemes.Our relationship to the transparency agenda is one that we will explore over the coming year.
