FOI 2026/1747

To the Freedom of Information Officer, NHS Greater Manchester Integrated Care Board (ICB) and or NHS England.

Under the Freedom of Information Act 2000 (FOIA), I am making a formal request for statistical data regarding patient demographics and placements onto the Special Allocation Scheme (SAS).

As a public body, the ICB is bound by the Public Sector Equality Duty (PSED) under Section 149 of the Equality Act 2010 to monitor said data.

Please provide the following data covering the period from 1 January 2019 to the present date.

General Practice Population Demographics & Reference Estimates

1. For each individual GP practice within the NHS Greater Manchester ICB jurisdiction, please provide the reference estimate for the total number of registered patients per year (2019 to present). For each practice, please break down this total baseline population by the following recorded protected characteristics and vulnerability markers:

• Ethnicity / Race: Broken down by standard NHS ethnic categories (e.g., White British, Asian/Asian British, Black/Black British, Mixed, Other).
• Disability Status: Patients with a recorded disability under the Equality Act 2010.
• Vulnerability Status: Patients flagged as vulnerable (e.g., those on the Severe Mental Illness (SMI) register, Learning Disability register, or with active safeguarding/vulnerability flags).
• Age: Bracketed into [18-25], [26-35], [36-45], [46-55], [56-65], and [65+].
• Sex / Gender
• Sexual Orientation (where recorded/available).

Special Allocation Scheme (SAS) Placements Breakdown

2. For each individual GP practice identified in Part 1, please provide the total number of patients who were placed onto the Special Allocation Scheme (SAS) per year (2019 to present), broken down by the exact same demographic and vulnerability categories:

• Ethnicity / Race (Primary focus)
• Disability Status (Primary focus)
• Vulnerability Status (SMI register, Learning Disability register, safeguarding flags)
• Age: Bracketed into [18-25], [26-35], [36-45], [46-55], [56-65], and [65+].
• Sex / Gender
• Sexual Orientation (where recorded/available)

3. Overturned Appeals: Of the total number of patients placed on the SAS per year, please state how many of those placements were subsequently overturned, revoked, or rescinded following an appeal or panel review within 30 days, 60 days or 90 days.

GTD Healthcare Limited Clinics (Specific Request)

4. Within the requested data, I require you to specifically identify and list all surgeries, clinics, and primary care services currently operated by GTD Healthcare Limited.

5. For every clinic operated by GTD Healthcare Limited, please clearly delineate:

• The reference estimate of total registered patients per GTD clinic.
• The demographic and vulnerability breakdown of those patients (focusing on ethnicity and disability/vulnerability).
• The demographic and vulnerability breakdown of patients placed on the SAS by GTD Healthcare Limited.

Guidance on Exemptions and Refusals (Section 12, 16, 17 and 40 FOIA)

Section 40(2) (Personal Data): I am strictly seeking anonymized statistical data.

Section 12 (Cost Limit) & Section 16 (Advice and Assist): If compiling this data for the entire Greater Manchester ICB exceeds the Section 12 cost limit, please consider this a formal request under Section 16 to refine the scope. However I note this should only be dozens of surgeries but hundreds with data already collected.

in a event of cost limit, please automatically narrow the geographic scope to cover only Manchester Central, Manchester City Centre, and the immediately surrounding boroughs from 2019 onwards.

This narrowed scope will cover GTD Healthcare clinics alongside several dozen other surgeries, which should easily fall within the appropriate cost limit to collect.

Section 17 (Refusal Notice): If you determine that providing this data for even the narrowed, localized central area (dozens of surgeries) still exceeds the Section 12 limit, you are required under Section 17 FOIA to provide a formal Refusal Notice detailing the exact reasons why.

This must include a specific, itemized breakdown of the time and cost estimates explaining why the ICB is unable to extract basic PSED demographic and disability/vulnerability data for this confined group of central surgeries.

Under the Freedom of Information Act 2000, you are required to respond to this request promptly and in any event within 20 working days of receipt. Please provide the data in a machine-readable format, such as an Excel or CSV spreadsheet. You may forward to this email.

1. NHS GM does not hold the detailed breakdown of categories requested. However, data related to patients registered at GP practices, is publicly available on the NHS England – Digital and NHS Primary Care Support England websites. To assist you please find below links to the information requested.

Patients Registered at a GP Practice – NHS England Digital

Information Services Request | PCSE

For the Greater Manchester data, it is necessary to review against all 10 GM Localities (previously CCGs):

• Bury – 00V
• Bolton – 00T
• Heywood, Middleton & Rochdale – 01D
• Manchester –
• Oldham – 00Y
• Salford – 01G
• Stockport – 01W
• Tameside – 01Y
• Trafford – 02A
• Wigan – 02H

Any reference to NHS Greater Manchester ICB (NHS GM) would be against QOP.

2. NHS GM does not hold data from individual GP practices or detailed breakdown of the categories requested. Please find below the number of patients assigned to the SAS scheme since 2020 for NHS GM which is held.

NHS Greater Manchester (NHS GM) does hold the information requested however, due to the low numbers involved (where patient data is 5 or less <5) we consider this to be exempt under section 40(2) of the Freedom of Information Act 2000 as the disclosure of this information may lead to the identification of individuals. This exemption is not subject to the public interest test.

3. Please find below the number of patients placed onto the SAS whose placements were subsequently overturned, revoked, or rescinded following an appeal.

NHS Greater Manchester (NHS GM) does hold the information requested however, due to the low numbers involved (where patient data is 5 or less <5) we consider this to be exempt under section 40(2) of the Freedom of Information Act 2000 as the disclosure of this information may lead to the identification of individuals. This exemption is not subject to the public interest test.

4. Details of surgeries, clinics, and primary care services currently operated by GTD Healthcare Limited is available from their website:

Home :: gtd healthcare

5. NHS GM does not hold the detailed analysis requested. However please refer to the list of registered patients by GP Practice, as per the links provided in the response to question 1. This data list includes the post code of the practice for the number of registered patients.