One of the uncertainties of the changes is what will happen to many of the functions of the National Information Governance Board. As I understand it, the Commissioning Board will promote best practice and a National Information Governance Committee is to be established within the CQC. I am not sure where the 'toolkit' (an essential guide for new NHS bodies) will be based in the future and there is an issue in respect of Section 251 of the NHS Act. This is the useful provision where, upon application to the NIGB, the common law duty of confidence can be set aside in certain defined circumstances to permit the transfer of limited patient indefinable information. No home for that yet.
No doubt we will receive enlightenment in due course.