Our Governance

Corporate governance

PHIN is an independent, not-for-profit organisation working with the private healthcare industry on behalf of patients. From the outset, PHIN has embedded a balanced and independent approach into our governance structure and processes, and this was recognised and formalised by the Competition & Markets Authority (CMA) in approving us as the Information Organisation for private healthcare in 2014.

Board of Directors

Our Board of Directors reflects a range of stakeholder interests including patients, hospital operators, doctors, insurers and the wider healthcare community. Board members may not be directors or employees of any member organisation and must declare any potential conflicts of interest. Our Board must include Non-Executive Directors (NEDs) nominated by key stakeholder groups, according to the CMA's Private Healthcare Market Investigation Order 2014, Article 23.2.

The board meets between six and ten times each year and directors are remunerated on a per diem rate, except where a director is acting on behalf of an organisation within the normal scope of their employment.

Voting members

PHIN was established in 2012 as a Company Limited by Guarantee without shareholding. In accordance with Company Law, we have voting Members who play a formal role in governance similar to shareholders, but do not own the company and do not benefit from any profits or remuneration. The voting Members were originally the hospital groups that founded PHIN, but private medical insurers and organisations representing consultants are now also being invited to participate, as required by Article 24.2 of the Order.

The duties of voting Members includes rights to:

vote at general meetings, including the Annual General Meeting

call a general meeting (the board also have this right)

appoint or remove directors (the board also have this right)

receive the Annual Report and accounts

Current voting members

The following organisations are the voting Members of PHIN:

Our funding

The CMA has placed a duty on private hospital operators to fund PHIN through subscriptions (Article 21.4). Subscriptions are based on a fixed fee for every recorded episode of privately funded care. PHIN receives no funding from consultants or private medical insurers (PMIs). We carry no advertising on the website and so receive no revenue from marketing. Our focus is to provide value for our members and free, quality information for patients.

Information governance and personal data

Good information governance is at the heart of what we do. It is a standing agenda item at every Board meeting and all staff complete information governance training. Our Information Governance Policy covers data privacy, confidentiality, security, quality and integrity.

We are subject to the Data Protection Act 2018, have completed the NHS Information Governance Toolkit process and been accredited under the ISO27001 Information Security Management Systems standard since August 2016. The ISO27001 accreditation includes people, processes and IT systems by applying a risk management process.

Hospitals are required by law to send us detailed records of every episode of care that they deliver. These records contain basic demographic information (like the ages of patients treated) but have specific details like names and dates of birth removed.

To produce some of the most important performance measures we need to know for sure whether we are looking at the same patient appearing more than once in the data, or to join data from different sources. For that reason, hospitals are required to send us NHS Numbers or equivalents associated with each record, and these must be validated by an approved process.