NICU Guide PII & NHS DSPT

The NICU Guide App was developed with data protection and governance as foundational principles. Although the app does not handle or store patient data, it does process personally identifiable information (PII) related to clinical staff—such as names, roles, and contact details. This information is managed in strict accordance with the NHS Data Security and Protection Toolkit (DSPT) standards, ensuring compliance with UK data protection laws and NHS-specific requirements. All data is transmitted over encrypted API endpoints, and no PII is stored locally on user devices. Access to sensitive directories is restricted through role-based authentication via Firebase, allowing only authorised users to view staff data. Administrative tools are designed to be easy to use while preserving security boundaries. Audit trail functionality is planned for future releases to improve traceability and accountability, further aligning with NHS DSPT expectations for secure access monitoring and information governance.


Data Protection & Information Governance

1. Lawful Basis for Processing

  • The NICU Guide collects and processes personal identifiable information (PII) under a lawful basis: to support clinical communication and coordination within the NICU.

  • All data processed is necessary for the performance of this legitimate function in a healthcare context.

2. Data Minimisation

  • Only the minimum necessary data is collected: name, role, specialty, and professional (non-personal) contact details.

  • No unnecessary personal or sensitive data is collected.

3. Secure Access Controls

  • Authentication: All users must log in using Firebase Authentication with email and password.

  • Authorisation: Access is restricted to verified NICU staff. The app validates logins against a whitelist of staff emails sourced from the approved staff list.

  • Role-based Access: Users without an appropriate role cannot proceed beyond the login screen.

  • Data Segregation:

    • PII is stored in a secure Google Sheet (Nicu App PII) and synced to Firestore over HTTPS, using a Flask script authenticated via a Firebase Service Account key (stored in a restricted directory).

    • Non-sensitive data (guidelines, rotas, general content) is maintained in a separate Google Sheet (Nicu App Sheets) with distinct permissions.

  • Planned Enhancement: The PII sync to Firestore will be automated via a secure Apps Script trigger on sheet edits.

4. Data Transmission Security

  • All data transmission occurs over encrypted HTTPS endpoints.

  • Communication routes:

    • NICU Guide App → Flask API (HTTPS)

    • Flask API → Firebase/Firestore (authenticated, HTTPS)

    • Flask API → Google Sheets API (via secure service account)

  • No APIs or endpoints are exposed without encryption.

5. Data Storage Security

  • No PII is stored on user devices.

  • All PII is stored in secure, cloud-hosted Firestore collections with granular read/write permissions.

  • The Firestore database follows Google Cloud Platform security standards, with access limited to trusted service accounts.

6. Accountability & Audit

  • Login activity is logged with timestamp and email address, written to Google Sheets (UsageLog) for audit.

  • Admin functions (e.g., staff list updates) are limited to the developer and authorised administrator.

  • Full audit records are planned for inclusion in the Firestore database.

7. Transparency & Privacy Notice

  • A clear privacy notice is available from within the app, explaining:

    • What data is collected

    • Why it is collected

    • How it is stored and protected

    • How users can request changes or deletion

  • A contact form is provided for questions or data requests.

8. Regular Review & DSPT Submission

  • The NICU Guide will be reviewed regularly, with a formal annual DSPT self-assessment submitted to demonstrate ongoing compliance with:

    • UK GDPR

    • The Caldicott Principles

    • NHS Digital’s 10 Data Security Standards

NHS Digital’s 10 Data Security Standards