Royal Free London publishes findings of legal audit in use of Streams

Last July, the Information Commissioner concluded an investigation into the use of the Streams app at the Royal Free London NHS Foundation Trust. As part of the investigation the Royal Free signed up to a set of undertakings – one of which was to commission a third party to audit the Royal Free’s current data processing arrangements with DeepMind, to ensure that they fully complied with data protection law and respected the privacy and confidentiality rights of its patients.You can read the full report on the Royal Free’s website here, and the Information Commissioner’s Office’s response here. The report also has three recommendations that relate to DeepMind Health:

• It recommends a minor amendment to our information processing agreement to contain an express obligation on us to inform the Royal Free if, in our opinion, the Royal Free’s instructions infringe data protection laws. We’re working with the Royal Free to make this change to the agreement.
• It recommends that we continue to review and audit the activity of staff who have been approved access to these systems remotely.
• It recommends that the Royal Free terminate the historical memorandum of understanding (MOU) with DeepMind. This was originally signed in January 2016 to detail the services that we then planned to develop with the Trust. As this document is no longer relevant to our work, we will work with the Royal Free to terminate it.

We look forward to continuing our collaboration with the Royal Free to improve care for patients. You can read more about the way in which we process and protect patient data here and you can read our previous blog about what we’ve learned here.