Privacy notice
As data controllers, GPs have fair processing responsibilities under the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). This means ensuring that your personal confidential data (PCD) is handled in ways that are safe, transparent and what you would reasonably expect. Please find documents and links below.
Practice Privacy Notice
Version: 2.8
Date: 16/05/2023
Data Protection Privacy Notice for Patients
Introduction:
This privacy notice lets you know what happens to any personal data that you give to us, or any information that we may collect from you or about you from other organisations.
This privacy notice applies to personal information processed by or on behalf of the practice.
This Notice explains
- Who we are and how we use your information
- Information about our Data Protection Officer
- What kinds of personal information about you we hold and use (process)
- The legal grounds for our processing of your personal information (including when we share it with others)
- What should you do if your personal information changes?
- For how long your personal information is retained / stored by us?
- What are your rights under Data Protection laws
The UK General Data Protection Regulation (UKGDPR) and the Data Protection Act 2018 (DPA 2018) became law on 25th May 2018, and 1st January 2021 when the UK exited the EU.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (UK) 2016/679) (the “UKGDPR”), and the Data Protection Act 2018 the practice responsible for your personal data is [Practice Name].
This Notice describes how we collect, use and process your personal data, and how in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
How we use your information and the law.
Meadowview will be what’s known as the ‘Controller’ of your personal data.
We collect basic personal data about you and location-based information. This does include name, address and contact details such as email and mobile number etc.
We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare setting) ethnicity and sex life information that are linked to your healthcare, we may also receive this information about you from other health providers or third parties.
Why do we need your information?
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously. These records help to provide you with the best possible healthcare and treatment.
NHS health records may be electronic, paper-based or a mixture of both. We use a combination of working practices and technology to ensure that your information is kept confidential and secure.
Records about you may include the following information;
- Details about you, such as your address, your carer or legal representative and emergency contact details.
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments.
- Notes and reports about your health.
- Details about your treatment and care.
- Results of investigations such as laboratory tests, x-rays etc.
- Relevant information from other health professionals, relatives or those who care for you.
- Contact details (including email address, mobile telephone number and home telephone number)
To ensure you receive the best possible care, your records are used to facilitate the care you receive, including contacting you. Information held about you may be used to help protect the health of the public and to help us manage the NHS and the services we provide. Limited information may be used within the GP practice for clinical audit to monitor the quality of the service we provided.
How do we lawfully use your data?
We need your personal, sensitive and confidential data in order to provide you with healthcare services as a General Practice, under the General Data Protection Regulation we will be lawfully using your information in accordance with: –
Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”
Article 9, (h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems
This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.
We use your personal and healthcare information in the following ways:
- when we need to speak to, or contact other doctors, consultants, nurses or any other medical/healthcare professional or organisation during the course of your diagnosis or treatment or on going healthcare;
- when we are required by law to hand over your information to any other organisation, such as the police, by court order, solicitors, or immigration enforcement.
- In a de-identified form to support planning of health services and to improve health outcomes for our population
We will never pass on your personal information to anyone else who does not need it, or has no right to it, unless you give us consent to do so.
Legal justification for collecting and using your information
The law says we need a legal basis to handle your personal and healthcare information.
Contract: We have a contract with NHS England to deliver healthcare services to you. This contract provides that we are under a legal obligation to ensure that we deliver medical and healthcare services to the public.
Consent: Sometimes we also rely on the fact that you give us consent to use your personal and healthcare information so that we can take care of your healthcare needs.
Please note that you have the right to withdraw consent at any time if you no longer wish to receive services from us.
Necessary care: Providing you with the appropriate healthcare, where necessary. The Law refers to this as ‘protecting your vital interests’ where you may be in a position not to be able to consent.
Law: Sometimes the law obliges us to provide your information to an organisation (see above).
Special categories
The law states that personal information about your health falls into a special category of information because it is very sensitive. Reasons that may entitle us to use and process your information may be as follows:
Public Interest: Where we may need to handle your personal information when it is considered to be in the public interest. For example, when there is an outbreak of a specific disease and we need to contact you for treatment, or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment
Consent: When you have given us consent
Vital Interest: If you are incapable of giving consent, and we have to use your information to protect your vital interests (eg if you have had an accident and you need emergency treatment)
Defending a claim: If we need your information to defend a legal claim against us by you, or by another party
Providing you with medical care: Where we need your information to provide you with medical and healthcare services
Risk Stratification
Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from several sources including NHS Trusts and from this GP Practice. The identifying parts of your data are removed, analysis of your data is undertaken, and a risk score is then determined. This is then provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way in most circumstances, please contact the practice for further information about opt out.
Individual Risk Management at a GP practice level however is deemed to be part of your individual healthcare and is covered by our legal powers above.
Medicines Management
The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments. The reviews are carried out by the CCGs Medicines Management Team under a Data Processing contract with the Practice
Transferring the current paper medical records into patients’ electronic medical records.
The following provisions of the General Data Protection Regulation permit us to digitise existing paper medical records:
Article 6(1)(e) – ‘processing is necessary…in the exercise of official authority vested in the controller…’’
Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’
The paper patient records will be shared with [Scanning provider], who will scan and digitise the current paper medical records before destroying them. The paper patient records will be shared with the scanning provider above, who will scan and digitise the current paper medical records before destroying them.
Anonymised information
Sometimes we may provide information about you in an anonymised form. Such information is used analyse population- level heath issues and helps the NHS to plan better services. If we share information for these purposes, then none of the information will identify you as an individual and cannot be traced back to you.
GP Connect Service
The GP Connect service allows authorised clinical staff at NHS 111 to seamlessly access our practice’s clinical system and book directly on behalf of a patient. This means that should you call NHS 111 and the clinician believes you need an appointment with your GP Practice, the clinician will access available appointment slots only (through GP Connect) and book you in. This will save you time as you will not need to contact the practice direct for an appointment.
The practice will not be sharing any of your data and the practice will only allow NHS 111 to see available appointment slots. They will not even have access to your record. However, NHS 111 will share any relevant data with us, but you will be made aware of this. This will help your GP in knowing what treatment / service / help you may require.
Please note if you no longer require the appointment or need to change the date and time for any reason you will need to speak to one of our reception staff and not NHS 111.
Summary Care Records
All patients registered with a GP have a Summary Care Record, unless they have chosen not to have one. The information held in your Summary Care Record gives registered and regulated healthcare professionals, away from your usual GP practice, access to information to provide you with safer care, reduce the risk of prescribing errors and improve your patient experience.
Your Summary Care Record contains basic (Core) information about allergies and medications and any reactions that you have had to medication in the past.
Some patients, including many with long term health conditions, previously have agreed to have Additional Information shared as part of their Summary Care Record. This Additional Information includes information about significant medical history (past and present), reasons for medications, care plan information and immunisations.
Change to information held in your Summary Care Record
In light of the current emergency, the Department of Health and Social Care has removed the requirement for a patient’s prior explicit consent to share Additional Information as part of the Summary Care Record.
This is because the Secretary of State for Health and Social Care has issued a legal notice to healthcare bodies requiring them to share confidential patient information with other healthcare bodies where this is required to diagnose, control and prevent the spread of the virus and manage the pandemic. This includes sharing Additional Information through Summary Care Records, unless a patient objects to this.
If you have already expressed a preference to only have Core information shared in your Summary Care Record, or to opt-out completely of having a Summary Care Record, these preferences will continue to be respected and this change will not apply to you. For everyone else, the Summary Care Record will be updated to include the Additional Information. This change of requirement will be reviewed after the current coronavirus (COVID-19) pandemic.
Why we have made this change
In order to look after your health and care needs, health and social care bodies may share your confidential patient information contained in your Summary Care Record with clinical and non-clinical staff in other health and care organisations, for example hospitals, NHS 111 and out of hours organisations. These changes will improve the healthcare that you receive away from your usual GP practice.
Your rights in relation to your Summary Care Record
Regardless of your past decisions about your Summary Care Record preferences, you will still have the same options that you currently have in place to opt out of having a Summary Care Record, including the opportunity to opt-back in to having a Summary Care Record or opt back in to allow sharing of Additional Information.
You can exercise these rights by doing the following:
- Choose to have a Summary Care Record with all information shared. This means that any authorised, registered and regulated health and care professionals will be able to see a detailed Summary Care Record, including Core and Additional Information, if they need to provide you with direct care.
- Choose to have a Summary Care Record with Core information only. This means that any authorised, registered and regulated health and care professionals will be able to see limited information about allergies and medications in your Summary Care Record if they need to provide you with direct care.
- Choose to opt-out of having a Summary Care Record altogether. This means that you do not want any information shared with other authorised, registered and regulated health and care professionals involved in your direct care. You will not be able to change this preference at the time if you require direct care away from your GP practice. This means that no authorised, registered and regulated health and care professionals will be able to see information held in your GP records if they need to provide you with direct care, including in an emergency.
To make these changes, you should inform your GP practice or complete this form and return it to your GP practice.
Patient Communication
Because we are obliged to protect any confidential information, we hold about you and we take this very seriously, it is imperative that you let us know immediately if you change any of your contact details.
We may contact you using SMS texting to your mobile phone if we need to notify you about appointments and other services that we provide to you involving your direct care, therefore you must ensure that we have your up-to-date details. This is to ensure we are sure we are contacting you and not another person. As this is operated on an ‘opt out’ basis we will assume that you give us permission to contact you via SMS if you have provided us with your mobile telephone number. Please let us know if you wish to opt out of this SMS service. We may also contact you using the email address you have provided to us. Please ensure that we have your up-to-date details.
There may be occasions where authorised research facilities would like you to take part in research. Your contact details may be used to invite you to receive further information about such research opportunities.
Safeguarding
The Practice is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently, and conscientiously applied with the wellbeing of all, at the heart of what we do.
Our legal basis for processing For the General Data Protection Regulation (GDPR) purposes is: –
Article 6(1)(e) ‘…exercise of official authority…’.
For the processing of special categories data, the basis is: –
Article 9(2)(b) – ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law…’
Research
Clinical Practice Research Datalink (CPRD) collects de-identified patient data from a network of GP practices across the UK. Primary care data are linked to a range of other health related data to provide a longitudinal, representative UK population health dataset. You can opt out of your information being used for research purposes at any time (see below), full details can be found here: –
https://cprd.com/transparency-information
The legal bases for processing this information
CPRD do not hold or process personal data on patients; however, NHS Digital (formally the Health and Social Care Centre) may process ‘personal data’ for us as an accredited ‘safe haven’ or ‘trusted third-party’ within the NHS when linking GP data with data from other sources. The legal bases for processing this data are:
- Medicines and medical device monitoring: Article 6(e) and Article 9(2)(i) – public interest in the area of public health
- Medical research and statistics: Article 6(e) and Article 9(2)(j) – public interest and scientific research purposes
Any data CPRD hold or pass on to bona fide researchers, except for clinical research studies, will have been anonymised in accordance with the Information Commissioner’s Office Anonymisation Code of Practice. We will hold data indefinitely for the benefit of future research, but studies will normally only hold the data we release to them for twelve months.
Categories of personal data
The data collected by Practice staff in the event of a safeguarding situation will be as much personal information as is possible that is necessary to obtain in order to handle the situation. In addition to some basic demographic and contact details, we will also process details of what the safeguarding concern is. This is likely to be special category information (such as health information).
Sources of the data
The Practice will either receive or collect information when someone contacts the organisation with safeguarding concerns, or we believe there may be safeguarding concerns and make enquiries to relevant providers.
Recipients of personal data
The information is used by the Practice when handling a safeguarding incident or concern. We may share information accordingly to ensure duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals (i.e. their GP or mental health team).
Third party processors
To deliver the best possible service, the practice will share data (where required) with other NHS bodies such as other GP practices and hospitals. In addition, the practice will use carefully selected third party service providers. When we use a third-party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties include:
- Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
- Delivery services (for example if we were to arrange for delivery of any medicines to you).
- Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).
Further details regarding specific third-party processors can be supplied on request to the Data Protection Officer as below.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection Act 2018
- The General Data Protection Regulations 2016
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality, Information Security and Records Management
- Information: To Share or Not to Share Review
Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles.
Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulation (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.
All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a sub-contractor acts as a data processor for Meadowview Surgery an appropriate contract (art 24-28) will be established for the processing of your information.
In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent. If some circumstances, we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.
Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose in an identifiable format. In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes.
With your consent we would also like to use your information
There are times that we may want to use your information to contact you or offer you services, not directly about your healthcare, in these instances we will always gain your consent to contact you. We would however like to use your name, contact details, and email address to inform you of other services that may benefit you. We will only do this with your consent. There may be occasions where authorised research facilities would like you to take part on innovations, research, improving services or identifying trends, you will be asked to opt into such programmes if you are happy to do so.
At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO as below.
National Opt-Out Facility
You can choose whether your confidential patient information is used for research and planning.
Who can use your confidential patient information for research and planning?
It is used by the NHS, local authorities, university and hospital researchers, medical colleges and pharmaceutical companies researching new treatments.
Making your data opt-out choice
You can choose to opt out of sharing your confidential patient information for research and planning. There may still be times when your confidential patient information is used: for example, during an epidemic where there might be a risk to you or to other people’s health. You can also still consent to take part in a specific research project.
Will choosing this opt-out affect your care and treatment?
No, your confidential patient information will still be used for your individual care. Choosing to opt out will not affect your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.
What should you do next?
You do not need to do anything if you are happy about how your confidential patient information is used.
If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service.
You can change your choice at any time. To find out more or to make your choice visit nhs.uk/your-nhs-data-matters or call 0300 303 5678
Where do we store your information electronically?
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.
No 3rd parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place such as a Data Processor as above). We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.
EMIS Web
The Practice uses a clinical system provided by a Data Processor called EMIS, from 10th June 2019, EMIS started storing your practice’s EMIS Web data in a highly secure, third-party cloud hosted environment, namely Amazon Web Services (“AWS”).
The data will remain in the UK at all times and will be fully encrypted both in transit and at rest. In doing this, there will be no change to the control of access to your data and the hosted service provider will not have any access to the decryption keys. AWS is one of the world’s largest cloud companies, already supporting numerous public sector clients (including the NHS), and it offers the very highest levels of security and support.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations.
- NHS Trusts / Foundation Trusts
- GP’s
- Primary Care Network
- NHS Commissioning Support Units
- Independent Contractors such as dentists, opticians, pharmacists
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services
- NHS England (NHSE) and NHS Digital (NHSD)
- Multi Agency Safeguarding Hub (MASH)
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Voluntary Sector Providers
- Private Sector Providers
- Other ‘data processors’ which you will be informed of
You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.
Computer System
This practice operates a Clinical Computer System on which NHS Staff record information securely. This information can then be shared with other clinicians so that everyone caring for you is fully informed about your medical history, including allergies and medication.
To provide around the clock safe care, unless you have asked us not to, we will make information available to our Partner Organisation (above). Wherever possible, their staff will ask your consent before your information is viewed.
Shared Care Records
To support your care and improve the sharing of relevant information to our partner organisations (as above) when they are involved in looking after you, we will share information to other systems. You can opt out of this sharing of your records with our partners at anytime if this sharing is based on your consent.
We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure. All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for [Practice Name] an appropriate contract (art 24-28) will be established for the processing of your information.
Sharing your information without consent
We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:
- where there is a serious risk of harm or abuse to you or other people;
- Safeguarding matters and investigations
- where a serious crime, such as assault, is being investigated or where it could be prevented;
- notification of new births;
- where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS);
- where a formal court order has been issued;
- where there is a legal requirement, for example if you had committed a Road Traffic Offence.
How long will we store your information?
We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.
More information on records retention can be found online at (https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016).
How can you access, amend move the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data and you do not agree, you have the right to object. We will respond to your request within one month (although we may be allowed to extend this period in certain cases). This is NOT an absolute right sometimes we will need to process your data even if you object.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project, or consent to send you information about us or matters you may be interested in), you may withdraw your consent at any time.
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within one month (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will need to keep a note of your name/ other basic details on our register of individuals who would prefer not to be contacted. This enables us to avoid contacting you in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.
Primary Care Network
The objective of primary care networks (PCNs) is for group practices together to create more collaborative workforces which ease the pressure of GP’s, leaving them better able to focus on patient care.
This practice is a member of TABA (Tyldesley, Atherton, Boothstown and Astley). Other members of the network are:
Sevenbrooks/Elmfield Surgery, Bag Lane Surgery, Popular Street Surgery, The Surgery Tyldesley, Elliott Street Surgery, Beefold Surgery, Astley General Surgery, Dr Sivakumar & Dr Gude Surgery, Dr Vardens Surgery, Boothstown Surgery
Primary Care Networks form a key building block of the NHS long-term plan. Bringing general practices together to work at scale has been a policy priority for some years for a range of reasons, including improving the ability of practices to recruit and retain staff; to manage financial and estates pressures; to provide a wider range of services to patients and to more easily integrate with the wider health and care system.
This means the practice may share your information with other practices within the PCN to provide you with your care and treatment.
Service Evaluation
The PCN carries out service evaluations in order to improve the quality and accessibility of primary care services. This may be carried out in a number of ways including telephone surveys, online surveys and interviews.
The legal basis for contacting you to take part –
Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”
Article 9, (h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems
To process the survey information, we collect from you we will only do so with your consent.
Article 6(1)(a) – Consent of the data subject (you)
Article 9(2)(a) – Explicit consent of the data subject. (you)’
Population Health Management
Population Health Management (or PHM for short) is aimed at improving the health of an entire population. It is being implemented across the NHS and this Practice is taking part in a project as a time limited pilot across named practices in Derby and Derbyshire.
The PHM approach requires health care organisations to work together with communities and partner agencies, for example, GP practices, community service providers, hospitals and other health and social care providers. These organisations will share and combine information with each other in order to get a view of health and services for the population in a particular area. This information sharing is subject to robust security arrangements.
As part of this programme, personal data about your health care will have all identifiers removed (like your name or NHS Number) and replaced with a code which will be linked to information about care received in different health care settings. If we see that an individual might benefit from some additional care or support, we will send the information back to your GP or hospital provider and they will use the code to identify you and offer you relevant services.
As part of this programme your GP and other care providers will send the information they hold on their systems to the North Of England Commissioning Support Unit (NECS). NECS are part of NHS England. More information can be found here https://www.necsu.nhs.uk
NECS will link all the information together. Your GP and other care providers will then review this information and make decisions about the whole population or particular patients that might need additional support. NECS work in partnership with a company called Optum to help them with this work. Both NECS and Optum are legally obliged to protect your information and maintain confidentiality in the same way that your GP or hospital provider is. More information about Optum can be found here www.optum.co.uk.
Health and Social Care Providers are permitted by data protection law to use personal information where it is ‘necessary for medical purposes’. This includes caring for you directly as well as management of health services more generally.
The PHM project is time-limited to 22 weeks. Once the project has completed all de-identified , information processed by NECS / Optum will be securely destroyed. This will not affect any personal information held by your GP or other health or social care providers.
Access to your personal information
Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
- Your request should be made to the Practice. (For information from a hospital or other Trust/ NHS organisation you should write direct to them.
- There is no charge to have a copy of the information held about you
- We are required to provide you with information within one month
- You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.
What should you do if your personal information changes?
You should tell us so that we can update our records please contact the Practice Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.
Online Access
You may ask us if you wish to have online access to your medical record. However, there will be certain protocols that we have to follow to give you online access, including written consent and the production of documents that prove your identity.
Please note that when we give you online access, the responsibility is yours to make sure that you keep your information safe and secure if you do not wish any third party to gain access.
Third parties mentioned on your medical record
Sometimes we record information about third parties mentioned by you to us during any consultation, or contained in letters we receive from other organisations. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them which may breach their rights to confidentiality, are removed before we send any information to any other party including yourself.
The NHS wants to give people better ways to see their personal health information online. We know that people want to be able to access their health records. It can help you see test results faster. It also lets you read and review notes from your appointments in your own time.
From 01/112022 we’re now letting you see all the information within your health record automatically. If you are over 16 and have an online account, such as through the NHS App, NHS website, or another online primary care service, you will now be able to see all future notes and health records from your doctor (GP). Some people can already access this feature, this won’t change for you.
This means that you will be able to see notes from your appointments, as well as test results and any letters that are saved on your records. This only applies to records from your doctor (GP), not from hospitals or other specialists. You will only be able to see information from 01.09.2023. For most people, access will be automatic, and you won’t need to do anything.
Your doctor (GP) may talk to you to discuss test results before you are able to see some of your information on the app. Your doctor (GP) may also talk to you before your full records access is given to make sure that having access is of benefit to you. There might be some sensitive information on your record, so you should talk to your doctor if you have any concerns.
These changes only apply to people with online accounts. If you do not want an online account, you can still access your health records by requesting this information through reception. The changes also only apply to personal information about you. If you are a carer and would like to see information about someone you care for, speak to reception staff.
The NHS App, website and other online services are all very secure, so no one is able to access your information except you. You’ll need to make sure you protect your login details. Don’t share your password with anyone as they will then have access to your personal information.
If you do not want to see your health record, or if you would like more information about these changes, please speak to your GP or reception staff.
Our website
The only website this Privacy Notice applies to is the Surgery’s website. If you use a link to any other website from the Surgery’s website then you will need to read their respective Privacy Notice. We take no responsibility (legal or otherwise) for the content of other websites.
The Surgery’s website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy.
CCTV recording
CCTV is installed on our practice premises covering both the external area of the building and the internal area excluding consulting rooms. Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime. The images are recorded onto an integral hard drive of the equipment and are overwritten on a rolling basis. Viewing of these digital images is password protected and controlled by the Practice Manager.
Telephone system
Our telephone system records all telephone calls. Recordings are retained for up to three years, and are used periodically for the purposes of seeking clarification where there is a dispute as to what was said and for staff training Access to these recordings is restricted to named senior staff.
Medical Examiner Service
Following the death of any patients of Meadowview we are now obliged to inform WWL NHS Trust, Medical Examiner Service.
Medical examiner offices at acute trusts now provide independent scrutiny of non-coronial deaths occurring in acute hospitals. The role of these offices is now being extended to also cover deaths occurring in the community.
Medical examiner offices are led by medical examiners, senior doctors from a range of specialties including general practice, who provide independent scrutiny of deaths not taken at the outset for coroner investigation. They put the bereaved at the centre of processes after the death of a patient, by giving families and next of kin an opportunity to ask questions and raise concerns. Medical examiners carry out a proportionate review of medical records and liaise with doctors completing the Medical Certificate of Cause of Death (MCCD).
The Practice will share any patient with the service upon request.
Objections / Complaints
Should you have any concerns about how your information is managed at the GP, please contact the GP Practice Manager or the Data Protection Officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.
Information Commissioner:
Wycliffe house
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 01625 545745
If you are happy for your data to be used for the purposes described in this privacy notice, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact the Practice Data Protection Officer.
If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.
Data Protection Officer:
The Practice Data Protection Officer is Paul Couldrey of PCIG Consulting Limited. Any queries regarding Data Protection issues should be addressed to him at: –
Email: Couldrey@me.com
Postal: PCIG Consulting Limited
7 Westacre Drive
Quarry Bank
Dudley
West Midlands
DY5 2EE
Changes:
It is important to point out that we may amend this Privacy Notice from time to time. If you are dissatisfied with any aspect of our Privacy Notice, please contact the Practice Data Protection Officer.