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Note: These use cases are a first draft, and in some cases are still under initial development. Whilst based on countless conversations with professionals and members of the public, they haven't yet been validated. Comments on the use cases are particularly welcome.
Use case:
Customer Services
As the front door to council services, the Customer Services team (and specifically the contact centre) need access to the basic information people may have shared with specific services, particularly around communication needs and reasonable adjustments.
Coupled with this, Customer Services need to know about the relationships the person already has with council services, eg benefits, housing, social care, so they can put a call through (where appropriate) to a team which already knows the person and their circumstances and needs, and save the caller from having to explain everything from scratch.
As
a person who draws on more than one council service
I need
services to talk to each other about what they're doing for me
so that
they don't work at cross-purposes and make things more difficult or complicated for me
As
a person with specific communication needs who draws on more than one council service
I need
every service I'm in touch with to understand my communication needs
so that
council staff can respect my needs and communicate with me effectively; I can understand what they're telling me; and I don't have the frustration of needing to repeat my needs over and over again
As
someone who needs to communicate with services on behalf of my mum (with her consent)
I need
organisations/services to keep a record of my mum's consent for me to act on her behalf
so that
I can deal with the stuff my mum needs me to deal with, without the constant frustration of "We can only speak to your mother herself" or "We need your mother to agree that we can talk to you", when they've been told that over and over again already
As
a customer service advisor
I need
to know about people's communication needs when they call the contact centre
so that
I can communicate with them in the way they need
Priority information
Name
The preferred name field is already included in the PRSB's Core Information Standard (CIS), where it is defined as “The name by which a person wishes to be addressed. The preferred name volunteered by the person or a preferred name given by PDS that the person has asked to be called by.” It also features in About Me (How I communicate and how to communicate with me: Describe how you would like others to engage and communicate with you, including how you would like to be addressed.)
This can be an extremely important factor in someone’s wellbeing; addressing someone by their legal/formal name when they have a preferred alternative can make them feel like a statistic in a system, and places that system at odds with an agenda of personalisation. However, it is often not recorded or shared systematically, even within the NHS, despite its presence in CIS.
It is strongly recommended that the preferred name is systematically recorded as a separate field, and is populated as a matter of routine, even when the preferred name is the same as the legal name.
Contact details
May include an order of preference for phone numbers, or different call types going to different numbers. Should also include any numbers used for SMS contacts. May include numbers for friends and family which the person has asked to be used - if so, should ideally state who the number belongs to.
Contact details
(Needs editing to remove jargon) Under the Equality Act 2010, organisations have a legal duty to make reasonable adjustments to ensure that services are as accessible to people with disabilities as they are for everybody else. This duty only applies to people’s disabilities, but there is also a need to record other communication needs, e.g. the requirement for an interpreter and/or translations of written material if someone does not speak or read English. The NHS has established a Reasonable Adjustments flag, with an extremely detailed SNOMED-CT value set, to capture this information. If this is already populated in NHS systems it is possible to import it using the Reasonable Adjustments Flag API – and indeed it is a duty on NHS services, under the Accessible Information Standard, to share this information across health and social care if they have recorded it. It is unclear whether the Accessible Information Standard is intended to apply to the core business of local authority adult social care. However, it would make sense to provide for it in the design of the case management system, by including the functionality to import, record, flag and share Reasonable Adjustment flags. (Import functionality might be from the NHS via the relevant API, or from another internal system such as children’s social care, housing, or a corporate customer management system.) Systematic capture of people’s reasonable adjustment needs could also provide useful business intelligence about the needs of the wider population, for example, by identifying geographic clusters of people with similar disabilities or communication needs, which could help with demand management and forecasting or targeted interventions. Feedback from local authorities and system suppliers suggests that the NHS Reasonable Adjustments value set is far too lengthy and detailed for practical purposes, and is not fit for purpose for use by frontline staff. There would be merit in developing either a sub-set of the existing SNOMED-CT value set for use in social care, or a smaller and higher level value set which could aggregate the detailed SNOMED-CT codes into a more workable solution. (If this idea is pursued it must still be possible to import records containing the full range of SNOMED-CT codes to ensure full interoperability.) Other resources such as Experian’s Support Hub and whatweneed.support also offer useful lists of reasonable adjustment needs which have been produced by, or co-produced with, people who draw on care and support.
Contact details
(Needs editing to remove jargon) Under the Equality Act 2010, organisations have a legal duty to make reasonable adjustments to ensure that services are as accessible to people with disabilities as they are for everybody else. As the duty is owed to disabled persons generally, it is an anticipatory duty which means service providers and people exercising public functions must anticipate the needs of disabled people and make appropriate reasonable adjustments. There's some anecdotal evidence of NHS staff believing that reasonable adjustments should only be recorded on the basis of a clinical diagnosis. This is at odds with the spirit of the Equality Act (if not the letter) and with practice elsewhere, where people are asked if they consider themselves disabled and if they require any reasonable adjustments. The statutory duty to make reasonable adjustments only applies to people’s disabilities. However, there is also a need to record other communication needs, e.g. the requirement for an interpreter and/or translations of written material if someone does not speak or read English. The NHS has established a Reasonable Adjustments flag, with an extremely detailed SNOMED-CT value set, to capture this information.1 If this is already populated in NHS systems it is possible to import it using the Reasonable Adjustments Flag API – and indeed it is a duty on NHS services, under the Accessible Information Standard, to share this information across health and social care if they have recorded it. It is unclear whether the Accessible Information Standard is intended to apply to the core business of local authority adult social care. However, it would make sense to provide for it in the design of the case management system, by including the functionality to import, record, flag and share Reasonable Adjustment flags. (Import functionality might be from the NHS via the relevant API, or from another internal system such as children’s social care, housing, or a corporate customer management system.) Systematic capture of people’s reasonable adjustment needs could also provide useful business intelligence about the needs of the wider population, for example, by identifying geographic clusters of people with similar disabilities or communication needs, which could help with demand management and forecasting or targeted interventions. Feedback from local authorities and system suppliers suggests that the NHS Reasonable Adjustments value set is far too lengthy and detailed for practical purposes, and is not fit for purpose for use by frontline staff. There would be merit in developing either a sub-set of the existing SNOMED-CT value set for use in social care, or a smaller and higher level value set which could aggregate the detailed SNOMED-CT codes into a more workable solution. (If this idea is pursued it must still be possible to import records containing the full range of SNOMED-CT codes to ensure full interoperability.) Other resources such as Experian’s Support Hub and whatweneed.support also offer useful lists of reasonable adjustment needs which have been produced by, or co-produced with, people who draw on care and support.
Home environment
Many of the other headings refer to elements of risk, but this data item should cover flags like "Visit in pairs" which may be held by planning enforcement, community safety etc.
In general, property-specific hazards and risks are poorly communicated between services. One approach might be to have a hazard/risk flag, with contact details of the person/team/service who holds details, so anyone needing to visit the property can be given whatever detail they legitimately need and are entitled to.
This might be a high priority data item for the "digital firebox", as the details about the risk could be kept secure but immediately available in casses of legitimate need.
Background
Flagging (and acting on) people's communication/reasonable adjustment needs would help to reduce failure demand, also known as "avoidable contact" (defined as "demand on a service organisation caused by the organisation's failure to do something, or to do something right, for a customer" (Wikipedia). It would also help councils meet the Public Sector Equality Duty, which - as an anticipatory duty - requires them to plan ahead for the adjustments they are likely to need to make, without people needing to ask for those adjustments.
There are a great many sensitivities around this, particularly around how much information should be shared with Customer Services. The problem won't be solved by data sharing alone, but would need process and culture change to support it.
There are a number of existing tools that could act as a starting-point for meeting this requirement:
The PRSB's "About Me" standard - designed for health and social care and applicable to any service with an ongoing relationship with the person, but not used to the full even in its services of origin.
NHS England's Accessible Information Standard - mandated for all NHS and social care providers, but again, not in widespread use.
Experian's Support Hub, which combines a place for people to share their comms needs, with a commitment on the part of banks and utility companies to act on those needs in the way they communicate.
Further narrative
The most urgent need is to identify the individual making contact and to have access to basic information about them, e.g. any teams/services who have an ongoing relationship with them, any specific communication needs or reasonable adjustments, how they want to be addressed.
There may be a particular need to be aware of any hazards or risks to the person's wellbeing, e.g. if they are in an abusive relationship. This would need to be carefully managed in terms of how it's presented to Customer Services staff.
The next layer of need might be around formal and informal proxy relationships. If a resident has given permission for the council to speak to a close relative on their behalf about certain issues, this needs to be recorded clearly for anyone at the council who might take that close relative's call.
There may well be other information that Customer Services needs to be aware of. This use case needs further investigation and testing.
Risks
Risk
Comms/reasonable adjustment needs may have been recorded incorrectly or inaccurately by some services
Mitigation
Customer Services would be well placed to identify any inaccuracies/omissions, and to cascade any corrections to frontline services.
Risk
Frontline services may resist sharing what they perceive as sensitive data about someone's communication preferences or reasonable adjustment needs
Mitigation
Emphasise the approach taken in the NHS England Accessible Information Standard (AIS). Whilst not binding on local authorities, it's a matter of good practice, common sense and basic respect for the person, that anyone who has contact with them is aware of how they need to communicate.
In terms of GDPR/lawful basis of processing, AIS operates under consent.
