| Reference | FOI 2026/1663 |
|---|---|
| Description | Liothyronine Patient Data Audits and GDPR Compliance |
| Date Requested | 24/03/2026 |
| Date Replied | 09/04/2026 |
| Category | Medicines Optimisation |
Under the Freedom of Information Act 2000, please provide the following information regarding the Integrated Care Board’s (ICB) monitoring, auditing, and review of patients prescribed Liothyronine (T3).
1. Patient Data Audits Between 1st December 2017 and the date of this request (or its predecessor CCG) directed or conducted any audits, data extractions, or “medicines optimisation” reviews that identified specific cohorts of patients prescribed liothyronine?
2. Data Protection Impact Assessments (DPIA) If the answer to Question 1 is ‘Yes’, please provide a copy of the Data Protection Impact Assessment (DPIA) associated with these activities, as required under Article 35 of the UK GDPR for the large-scale processing of special category health data.
3. Lawful Basis for Processing Please state the specific Lawful Basis relied upon under Article 6 and the Special Category Condition relied upon under Article 9 of the UK GDPR for the collection and collation of this patient-level data (e.g., dosage, TSH levels, initiation history).
4. Transparency and Patient Notification Please provide a copy of the Privacy Notice, Fair Processing Notice, or Transparency Communication issued to the affected patients to inform them that their clinical data was being processed for the purpose of these audits/reviews, as required by the ‘Right to be Informed’ (Articles 13 & 14).
5. Purpose and Outcome Please confirm the primary purpose of these audits. Specifically:
a) Were they used to facilitate the “repatriation” of prescribing from primary to secondary care?
b) Were they used to identify patients for the potential withdrawal or restriction of treatment?
c) Were they used to support Individual Funding Request (IFR) or Exceptional Funding Request (EFR) decision-making?
6. Governance Please provide the date and the specific minute of the ICB Board (or CCG Governing Body) meeting where these audit activities and any subsequent treatment restriction policies were formally authorised.
| Q1 | Q2 | Q3 | Q4 | Q5a | Q5b | Q5c | Q6 | |
| Bolton | In 2019, practices were told how many patients they had taking liothyronine and a copy of the NHSE guidance on prescribing Liothyronine shared, with a request that practices reviewed the appropriate use of this, in line with NHSE guidance. | N/A | N/A | N/A | To ensure practices reviewed patients and ensure ongoing prescribing was in line with national guidance. | To ensure practices reviewed patients and ensure ongoing prescribing was in line with national guidance. | To ensure practices reviewed patients and ensure ongoing prescribing was in line with national guidance. | N/A |
| Bury | No specific patient audits have been conducted. However, as this is identified as a Drug of limited clinical value, where identification of prescribing has taken place, this would be highlighted to the practice for review. | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| HMR | No specific patient audits have been conducted. However, as this is identified as a Drug of limited clinical value, where identification of prescribing has taken place, this would be highlighted to the practice for review. | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Manchester | No targeted review work has happened in Manchester specifically looking at Liothyronine. It’s part of DLVC which pharmacist may have reviewed via SMRs but no audits have been undertaken. | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Oldham | No specific patient audits have been conducted. However, as this is identified as a Drug of limited clinical value, where identification of prescribing has taken place, this would be highlighted to the practice for review. | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Salford | We have not conducted any patient audits on patients prescribed liothyronine. Where prescribing data indicates prescribing of liothyronine by GP practices, we have highlighted the ‘DLCV’ status and advised practices to review patients in line with NHS England commissioning guidance on products which should not routinely be prescribed. | N/A | N/A | N/A | If in line with NHS England guidance | If in line with NHS England guidance | Unknown | N/A |
| Stockport | Stockport issued Liothyronine Treatment Guidance in January 2018, there is no record of whether this was used for audit. | N/A | N/A | N/A | The guidance refers to Patients currently under the specialist should be flagged to the specialist and be reviewed by them at the earliest opportunity to initiate a switch to levothyroxine or, in exceptional circumstances, continue prescribing in secondary care only. | The guidance refers to patients on liothyronine as being on the DNP/Grey list, which would identify them through prescribing software for review | The guidance may be referred to as part of the Local Panel Appeals Process. | Stockport Area Medicines and Prescribing Group (STAMP) approved Liothyronine Treatment Guidance in January 2018 |
| Tameside | The Medicines Optimisation team now employed by the NHS GM ICB and previously with Tameside & Glossop CCG proactively work with General Practice to optimise prescribing efficiency and thereby supporting patient care whilst maximising the cost benefits of prescribing, enhancing patient safety and improving formulary and guidance adherence. These activities formed part of routine medicines optimisation work with General Practice and included:• Prescribing searches within GP clinical systems• Identification of prescribing cohorts aligned to national and regional guidance• Generation of practice level reports to support clinical review | Attached current and previous redacted DPIA.
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Article 6(1)(e) – Processing is necessary for the performance of a task carried out in the public interest. Article 9(2)(h) – Provision of health/social care. Both covered in the DPIA. Only aggregated data sets with formulation, dose, frequency & number of issues shared. Other parameters e.g. TSH levels are not collated. | DPIA confirms that this processing falls within established direct care / healthcare management purposes and therefore, no patient-specific notification issued for overarching MO work programmes | NO -Supporting safe, evidence-based prescribing, ensuring alignment with national, regional‑ and local guidance and enabling GP practices to review prescribing on an individual patient basis | NO – Supporting safe, evidence-based prescribing, ensuring alignment with national, regional‑ and local guidance and enabling GP practices to review prescribing on an individual patient basis | NO – Supporting safe, evidence-based prescribing, ensuring alignment with national, regional‑ and local guidance and enabling GP practices to review prescribing on an individual patient basis | No specific meeting authorising specific liothyronine audits. However, overarching medicines optimisation work plans are approved through governance and practice level agreements. Tameside as a locality adheres to the GMMMG formulary, RMOC and NHS England guidance |
| Trafford | No targeted review work has happened in Trafford specifically looking at Liothyronine. It’s part of DLVC which pharmacist may have reviewed via SMRs but no audits have been undertaken. | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
| Wigan | Where prescribing data has indicated prescribing of Liothyronine in GP practices, we have highlighted this to practices and asked them to review prescribing to ensure it remains in line with national/GMMMG guidance. | N/A | N/A | N/A | N/A – Where prescribing data has indicated prescribing, this has been highlighted to support practices to review and ensure ongoing prescribing in line with national guidance | N/A – Where prescribing data has indicated prescribing, this has been highlighted to support practices to review and ensure ongoing prescribing in line with national guidance | N/A – Where prescribing data has indicated prescribing, this has been highlighted to support practices to review and ensure ongoing prescribing in line with national guidance | N/A |
**PDF documents were sent to the requester with this response. If you require a copy of the full response, together with the attachments, please contact NHS GM’s FOI team – nhsgm.foi@nhs.net **
