Analysis of responses
Question 1: Should registered medical practitioners be required to send abortion notifications to the Chief Medical Officer (CMO) electronically (rather than on a paper form)?
13. Of the thirty five responses to this question, thirty two answered yes, notifications should be sent electronically. Three respondents answered "I don't know" to this question. The number and percentage of responses are shown below in table 1.3.
|Yes – notifications should be sent electronically||32||91.4%|
|No – notifications should continue to be sent on paper forms||0||0.0%|
|I don't know||3||8.6%|
14. The comments given in response to this question were generally positive, indicating that moving to electronic notification could increase accuracy in reporting, would have a positive impact on the handling of sensitive data, reduce the possibility of human error and the burden on administrative staff and make the process quicker.
15. Public Health Scotland (PHS) indicated that it supports moving to electronic reporting. It commented that it, rather than the CMO, is the appropriate organisation to receive detailed information on patients having terminations in Scotland. PHS highlighted the potential for duplication of reporting and suggested that it work with the Scottish Government and providers to ensure the most efficient and joined up approach to provision of information.
16. Faith and pro-life organisations agreed with the proposal for notifications to be sent electronically and made broader comments about the scope of the data gathered (covered separately under question 3).
17. Of the respondents who answered "I don't know", comments provided included concerns about data protection issues, and questions over the need for reporting to the CMO.
Question 2: Should registered medical practitioners be given a longer time period to return abortion notifications to the CMO?
18. Of the thirty four responses to this question, twenty seven respondents in total agreed with one of the three proposed options for increasing the time period beyond seven days. Of these, sixteen respondents were in favour of increasing the time period to one month, eight respondents wanted to increase the time period to fourteen days, and three wanted to increase the time period to three months. Three respondents wanted to keep the current seven day time period, one answered "I don't know" and three answered "other". The number and percentage of responses are shown below in table 1.4.
|Yes – they should be given fourteen days from the date of the termination||8||22.9%|
|Yes – they should be given one month from the date of the termination||16||45.7%|
|Yes – they should be given three months from the date of the termination||3||8.6%|
|No – they should continue to provide notifications within seven days of the termination||3||8.6%|
|I don't know||1||2.9%|
19. Of those that answered 'other', one respondent (PHS) commented that the current seven day time period is too restrictive and, while quarterly reporting would be adequate, clear timescales should be agreed to enable alignment between the separate returns to the CMO and PHS. PHS indicated that this would help to minimise duplicate reporting requirements and any potential for discrepancies between the reporting strands.
20. Several of the additional comments from respondents who were supportive of extending the current seven day time period noted that this would allow greater flexibility for providers and that the current time period is too short.
21. It was noted by a women's organisation that other healthcare procedures do not require reporting within seven days, and more broadly that, as part of broader abortion care reform, the requirement for formal notification to the CMO should be reviewed.
22. Faith and pro-life respondents raised concerns about needing to ensure complications were properly reported and suggested that a longer reporting period would enable more accurate data to be collected in this regard.
Question 3: Should providers send data for the compilation of the abortion statistics directly to Public Health Scotland (PHS), rather than sending it via the CMO?
23. Of the thirty three responses to this question, twenty four were in favour of data being supplied directly to PHS. Five respondents indicated that they do not think data should be supplied directly to PHS, four answered "I don't know". The number and percentage of responses are shown below in table 1.5.
|Yes – data should be supplied directly to PHS||24||68.6%|
|No – data should not be supplied to PHS directly||5||14.3%|
|I don't know||4||11.4%|
24. Comments from respondents in favour of the change were that it would help to minimise the number of individuals who come into contact with the data, ensure that detailed data was only being collected where there is a clear need to do so, could speed up the process and help to avoid duplication. It was also noted that data regarding abortion shouldn't be treated differently to other elements of healthcare.
25. Some respondents caveated their support for the proposal, and comments in this regard variously proposed a need for public consultation on future data requirements, the need to ensure continuity of data, the need for follow-up appointments with patients to ensure complete data and the need to ensure data is anonymised.
26. PHS set out several options for a new electronic data return and stressed the need for the necessary time and resources to be made available to it and providers to enable the development of new processes ahead of any removal of current arrangements. It also reiterated the desire to harmonise responses to PHS and the CMO and proposed further exploration of a statutory requirement for data to be provided to PHS by abortion providers.
27. Of the five respondents who answered "no" only two offered comments, which focused on the need for comprehensive data. Comments included that data should continue to be required to be sent to the CMO as well as PHS and raised concerns about any gap between the Regulations no longer requiring detailed data to be provided to the CMO and the new arrangements for data to be provided to PHS.
28. In addition, some pro-life and faith organisations noted here or under question 1 that there was a need for comprehensive data, including data regarding complications and outcomes from abortions, and some suggested the data to be provided should be specified in the Regulations. Some respondents also indicated that there should be a public consultation on the data requirements for data supplied directly to PHS. Two respondents also suggested the establishment of an 'opt-in' patient 'registry' for longer-term reporting of patient experiences of abortion, including complications, which could be updated by maternity services, GPs and Emergency Departments, etc., and proposed a statutory requirement for a follow-up appointment for patients after one month to capture any information regarding any complications.
Question 4: Do you think there will be any impacts from the changes proposed in this consultation on the privacy of personal data about patients and staff?
29. Of the thirty three responses to this question, sixteen answered yes, these changes will have an impact on data privacy. Twelve answered no, these changes won't impact on data privacy. Five answered that they didn't know. The number and percentage of responses are shown below in table 1.6.
|Yes – these changes will impact on data privacy||16||45.7%|
|No – these changes won't have any impact on data privacy||12||34.3%|
|I don't know||5||14.3%|
30. Of the sixteen respondents who answered yes, the majority of the additional comments were that it would be a positive impact on data privacy. Comments variously highlighted the need for secure data and a data protection impact assessment to be carried out, the possibility that the changes might result in increased workload and the need for a simple system (for data transfer) to avoid this.
31. Only one respondent who answered 'no' provided comments. The comments given were that as long as a secure password protected system was put in place there would be no impact.