The GPC has received a reply from the ICO regarding the use of Subject Access Reports under the Data Protection Act rather than requesting GP reports.
The ICO has ruled that this use is inappropriate (see letter). In particular, please note the first paragraph of the Summary:
“The right of subject access is a key element of the fundamental right to the protection of personal data provided for under Article 8 of the EU Charter of Fundamental Rights which is conferred upon individuals. It is not designed to underpin the commercial processes of the life insurance industry. The Commissioner takes the view that the use of subject access rights to access medical records in this way is an abuse of those rights.”
The GPC will issue a ‘Focus On’ shortly, but in the interim, as we are aware that practices are regularly receiving these requests , GPC would recommend/advise practices not to respond to these requests.