There are currently many data flows in the NHS which conflict with patient privacy and a number which appear illegal under existing laws such as the Sexually Transmitted Diseases Act. The Caldicott report does not make a convincing case that these flows are unnecessary; the private sector has shown that one can operate perfectly well with de-identified data. Organisations considering their feedback to the current consultation on the implementation of the Caldicott report should bear this in mind and read the relevant documents carefully in the light of their ethical responsibilities.
A particular concern must be that the NHS Tracing Service will for the first time provide an accurate and up-to-date list of all adults and children in the UK. The scope for this system to be abused is frightening, the likelihood of strong public objection is high, and healthcare professionals run significant risks if they allow themselves to be co-opted into providing what many will see as the infrastructure for a police state.
Acknowledgement: Mary Hawking first brought the Caldicott implementation document to my attention and thereafter provided a number of valuable comments on it.