Online safety – reflections on safety by design from ETHOS.

Following the publication of the principles of safer online platform design by the Department for Digital, Culture, Media and Sport, we consider the contribution of clinical safety.

ETHOS compliance tick

The online safety draft bill was published in the summer of 2021

ETHOS team contextualise this in terms of the NHS Clinical Safety Standards and works with a wide range of designers, developers and organisations seeking to deliver this ambition.

The principles published last year relate to:

  • Users are not left to manage their own safety
  • Platforms should consider all types of users
  • Users are empowered to make safer decisions

How will this work in relation to the clinical safety standards, mandated in England?

What is the digital clinical safety link to these principles?

Clinical Safety can be seen as freedom from unacceptable clinical risk to patients (including young people and their families/carers/guardians). The focus on the commissioning, implementation, deployment, and use of digital health products within the NHS, is underpinned by the assumption that it can deliver substantial benefits to those accessing services. The latter is often realised through the timely provision of complete and correct information to service users and to those healthcare professionals that are responsible for administering care.

However, it must be recognised that failure or incorrect use of such digital systems has the potential to cause harm, not least to those people that the system is intended to benefit, such as young people.

The core requirement of the NHS Clinical Safety standards is to conduct robust clinical risk management activities to provide assurance to all those using the digital platform/tool, and that this benefit will not be overridden by potential harm. A systematic and evidence-driven balance of risk and benefit.

As previously stated, the standards promote effective use of clinical risk management across all organisations that are responsible for the designing, building, commissioning, implementing, and deploying of any digital health systems and services. This may include those less obvious organisations such as education services working with vulnerable children and young people, using digital interventions.

Within the clinical safety standards, the term ‘clinical risk’ seeks to emphasise that the scope is limited to managing risks. These are related to patient safety, distinct from other types of risk such as those relating to financial, information governance (IG) or security. Safeguarding is not referenced explicitly, but we believe it is in scope in this context. These may be factors in the evaluation of risks, but the end-users safety is the primary focus of our efforts.

Clinical risk management activities should be within the culture of ‘usual practice’ risk management, and any wider IG/security processes, adopting practical and adaptable risk management tools they already have at their disposal rather than starting from nothing.

A fit with the principles?

The clinical safety standards do map to these principles, but clearly, clinical safety is a multifaceted set of systematically applied steps that will only be as good as those deploying the controls at the cutting edge of complex human-computer interactions in a complex context. This is true for digital interventions now spanning health, care, education and research involving vulnerable young people.

Risk management encompasses a clearly defined scope that reflects all users across a workflow, has co-creating at its heart and drives the use of the safety workshops to embrace lived experience and expertise from across a multidisciplinary team, adding robustness to this vital work. While terminology in educational settings may vary to health and care, safeguarding provides an open door for staff to embrace the design and clinical safety principles in practice.

Sounds like a match to us!

Get in touch if you would like to explore this with the team or share your challenges:

E: info@ethos.co.im T: @LtdEthos

Stuart Harrison

Dean Mawson

Clive Tomsett

Alicia Ridout