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Thank you for posting this. Have you been in contact with your Councillors or MSP as it has been Xmas and New year so I don't know if they have been made aware.

Comments by the NHSCR governance board.

1.The PIA referred to in the minutes you mentioned is one worked on for the Beyond 2011 Programme. This considered options for the 2021 Census and concluded with a recommendation early in March 2014. The PIA was based on an initial consideration of options for the 2021 Census. A full PIA will done as part of the final 2021 Census programme. The use of NHSCR data in relation to the Census was part of the considerations hence the discussions at the NHSCR board about this.

As there was concern that the PIA that had been developed for B2011 included secure content (as suggested in the minutes) and as the B2011 Programme had concluded more quickly than expected the PIA was never made public but NRS are currently reviewing the contents in order to share this document with you as quickly as possible.

2.The minutes also refer to two compliance checks relating to NHSCR, which were published and the links are given below. We are also moving copies of these alongside the minutes on the website for ease of reference in the future.

These documents are "Use of NHS Central Register Data in the Scottish Longitudinal Study Report on privacy safeguards" (PDF 84 Kb) and "Use of NHS Central Register Data in the Production of Population and Migration Estimates Report on privacy safeguards" (PDF 84 Kb)

3.More generally, the NHSCR has been in existence since the 1950s and thus pre-dates the undertaking of PIAs. A PIA of the existing NHSCR in its entirety has therefore not been undertaken however the approach is to develop PIAs relating to new proposals as they emerge.

4.As you know Scottish Government have already published a PIA for the Myaccount element of the proposal in respect of which the consultation is being carried out. The current consultation (including your response) will inform the production and publication of new PIAs in respect of any future proposals regarding the NHSCR.

Many thanks for your most helpful comments. Just one or two issues by way of response:

1. Linked to these proposals, we have already had a national ID card infrastructure in place in Scotland for the past nine years. This is based on the so-called ‘pensioner bus pass’ (for older and disabled people) and the ‘Young Scot card’ (for youngsters), both properly referred to as the National Entitlement Card (NEC). See:

This card is effectively compulsory for most pensioners and disabled. For if you refuse to register for the card, you lose your entitlement to free bus travel.

This scheme was introduced in 2006 by the then Labour/Lib Dem coalition government in Holyrood, and there is little doubt that the multi-function ‘smart’ NEC card is in reality an ID card, with the underlying infrastructure, based around the UCRN number and an associated national register, directly paralleling what was being planned for the UK ID card. I have maintained information about these developments here:

2. In terms of how many people are currently registered in the NHSCR register, I would guess that it could be very high, and greatly in excess of the stated “approximately 30%”. I’m aware that around 40% of people are registered for NEC cards. But in addition, a very large number of people will most certainly be in there for having been born in Scotland and also having registered with a GP.

Note that this note from the NHSCR Governance Board, ‘the NHSCR and the Citizen’s Account’, dated October 2005:

explains how the NHSCR was to be populated and UCRNs created, viz:
- when people apply for a Citizens Account (i.e. essentially when they apply for an NEC card)
- when people born in Scotland submit registration details (after the creation of the Infrastructure)
- possibly prepopulated from the Scottish national birth register (still to be agreed at that time)

3. Like the introduction of the Poll Tax, Scotland was chosen as the guinea pig for the roll out of NEC cards in 2006. Two years later, very similar multi-function, smart ‘pensioner bus passes’ were introduced elsewhere in the UK by the Labour Government. So it is possible/probable that a similar underlying ‘national register’ infrastructure was put in place. I have provided a few details here:

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