Privacy Policy

This is the privacy notice of University of Salford Health Centre. In this document, “we”, “our”, or “us” refers to University of Salford Health Centre, 3rd floor, Maxwell Building, The Crescent, Salford M5 4WT.

Telephone number: 0161 295 4209/4287

Our Practice aims to ensure the highest standard of medical care for our patients and we are committed to protecting and respecting your privacy. To do this we keep records about you, your health and the care we have provided, or plan to provide, to you. If you have any questions regarding this Privacy Policy please contact us at the address shown above.

We understand how important it is to keep your personal information safe and secure and we take this very seriously. We have taken steps to make sure your personal information is looked after in the best possible way and we review this regularly.

Please read this Privacy Notice (‘Privacy Notice’) carefully, as it contains important information about how we use the personal and healthcare information we collect on your behalf.

The General Data Protection Regulation (GDPR) came in to force on May 2018.

Patient Information Leaflet

You can download or view our Patient information leaflet about GDPR (General Data Protection Regulation).

Children’s Privacy Policy

You can download/view our Childrens’ Privacy Policy information leaflet shown below;

COVID -19 Privacy Policy

Introduction

  1. WHY WE ARE PROVIDING THIS PRIVACY NOTICE

We are required to provide you with this Privacy Notice by Law. It explains how we use the personal and healthcare information we collect, store and hold about you. If you are unclear about how we process or use your personal and healthcare information, or you have any questions about this Privacy Notice or any other issue regarding your personal and healthcare information, then please do contact our Data Protection Officer (details below).

The Law says:

  1. We must let you know why we collect personal and healthcare information about you;
  • We must let you know how we use any personal and/or healthcare information we hold on you;
  • We need to inform you in respect of what we do with it;
  • We need to tell you about who we share it with or pass it on to and why; and
  • We need to let you know how long we can keep it for.

  • THE DATA PROTECTION OFFICER

The data protection team can be contacted at [email protected] if:

  • You have any questions about how your information is being held;
  • If you require access to your information or if you wish to make a change to  your information;
  • If you wish to make a complaint about anything to do with the personal and healthcare information we hold about you;
  • Or any other query relating to this Notice and your rights as a patient.

ABOUT US

We, at the The University of Salford Health Centre 3rd Floor Maxwell Building, University of Salford, Salford, M5 4WT are a Data Controller of your information. This means we are responsible for collecting, storing and handling your personal and healthcare information when you register with us as a patient.

There may be times where we also process your information. That means we use it for a particular purpose and, therefore, on those occasions we may also be Data Processors. The purposes for which we use your information are set out in this Privacy Notice.

INFORMATION WE COLLECT FROM YOU

The information we collect from you will include:

  1. Your personal contact details (such as your name, address, contact telephone numbers (landline and mobile) and email address, including place of work and work contact details);
  • Details and contact numbers of your next of kin;
  • Your age range, gender, ethnicity;
  • Details in relation to your medical history;
  • The reason for your visit to the Surgery;
  • Medical notes and details of diagnosis and consultations with our GPs and other health professionals within the Surgery involved in your direct healthcare.

INFORMATION ABOUT YOU FROM OTHERS

We also collect personal information about you when it is sent to us from the following:

a. hospital, a consultant or any other medical or healthcare professional, or any other person involved with your general healthcare.

YOUR SUMMARY CARE RECORD

Your summary care record (‘SCR’) is an electronic record of your healthcare history (and other relevant personal information) held on a national healthcare records database provided and facilitated by NHS England.

You can ask your doctor to add further information to your SCR from your medical notes. This can include health problems such as diabetes and your treatment preferences.

   This record may be shared with other healthcare professionals and additions to this record may also be made by relevant healthcare professionals and organisations involved in your direct healthcare.

You may have the right to demand that this record is not shared with anyone who is not involved in the provision of your direct healthcare.  SCRs improve care, but if you do not want to have a SCR, then you are entitled to opt out. You can tell your GP or you can fill out a SCR opt out form. If you would like a form or wish to enquire further as to your rights in respect of not sharing information contained within this record then please contact our Data Protection Officer.

If you are happy with the use of this information you do not need to do anything. You may however change your mind at any time.

NATIONAL DATA OPT-OUT

A new national data opt-out was introduced in May 2018, following recommendations from the National Data Guardian. You can opt out of having your confidential patient information shared for reasons beyond your individual care, for example for research and planning.

Your health records contain a type of data called confidential patient information. This data can be used to help with research and planning.

You can choose to stop your confidential patient information being used for research and planning. You can also make a choice for someone else like your children under the age of 13.

To help the NHS respond to coronavirus, your information may be used for coronavirus research purposes even if you have chosen not to share it. Any information used will be shared appropriately and lawfully.

Confidential patient information is when 2 types of information from your health records are joined together.

The 2 types of information are:

  • something that can identify you;
  • something about your health care or treatment;

For example, your name joined with what medicine you take.

Identifiable information on its own is used by health and care services to contact patients and this is not confidential patient information.

Health and care staff may use your confidential patient information to help with your treatment and care. For example, when you visit your GP they may look at your records for important information about your health.

Confidential patient information might also be used to:

  • plan and improve health and care services;
  • research and develop cures for serious illnesses.

You can stop your confidential patient information being used for research and planning. Find out how to make your choice at https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/

If you’re happy with your confidential patient information being used for research and planning you do not need to do anything.

Any choice you make will not impact your individual care.

WHO WE MAY PROVIDE YOUR PERSONAL INFORMATION TO AND WHY

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care Services, important information about you is collected to help ensure you get the best possible care and treatment. This information may be passed to other approved organisations where there is a lawful basis, to help with planning services, improving care, research into developing new treatments and preventing illness. All of this helps to improve services and provide better care to you and your family and future generations. However, as explained in this Privacy Notice, confidential information about your health and care is only used in this way where allowed by law and would never be used for any other purpose without your clear and explicit consent.

We may pass your personal information on to the following people or organisations, because these organisations may require your information to assist them in the provision of your direct healthcare needs. It, therefore, may be important for them to be able to access your information in order to ensure they may properly deliver their services to you:

  1. Hospital professionals (such as doctors, consultants, nurses, etc);
  • Other GPs/Doctors;
  • Pharmacists;
  • Nurses and other healthcare professionals;
  • Dentists;
  • Any other person that is involved in providing services related to your general healthcare, including mental health professionals.

OTHER PEOPLE WHO WE PROVIDE YOUR INFORMATION TO

  1. Commissioners;
  • Clinical Commissioning Groups; (from June 2022 they will be know as ICS)
  • Local authorities;
  • Community health services;
  • For the purposes of complying with the Law e.g. Police, Solicitors, Insurance Companies;
  • Anyone you have given your consent to, to view or receive your record, or part of your record. Please note, if you give another person or organisation consent to access your record, we will need to contact you to verify your consent before we release that record. It is important that you are clear and understand how much and what aspects of, your record you give consent to be disclosed.  
  • Extended Access – we provide extended access services to our patients which means you can access medical services outside of our normal working hours. In order to provide you with this service, we have formal arrangements in place with the Clinical Commissioning Group and with other practices whereby certain key “hub” practices offer this service on our behalf for you as a patient to access outside of our opening hours. This means, those key “hub” practices will have to have access to your medical record to be able to offer you the service. Please note we ensure that those practices comply with the Law and protect the use of your information, we have very robust data sharing agreements and other clear arrangements in place to ensure your data is always protected and used for those purposes only.

    The key Hub practices are as follows: Victoria Road Surgery,9 Victoria Road Salford M6 8EZ

  • Data Extraction by the Clinical Commissioning Group – the clinical commissioning group at times extracts medical information about you, but the information we pass to them via our computer systems cannot identify you to them. This information only refers to you by way of a code that only your practice can identify (it is pseudo-anonymised). This therefore protects you from anyone who may have access to this information at the Clinical Commissioning Group from ever identifying you as a result of seeing the medical information and we will never give them the information that would enable them to do this.

There are good reasons why the Clinical commissioning Group may require this pseudo-anonymised information, these are as follows:

     To ensure practices are delivering safe, high quality patient care and patients  are able to access services

  1. Primary Care Network

We are a member of Ordsall & Claremont Primary Care Network (PCN).  This means we will be working closely with a number of other Practices and health and care organisations to provide healthcare services to you. These Practices are listed at the end of this Privacy Notice. See Schedule 1 below.

During the course of our work we may share your information with these Practices and other health care organisations/professionals.  We will only share this information where it relates to your direct healthcare needs. 

When we do this, we will always ensure that appropriate agreements are in place to protect your information and keep it safe and secure. This is also what the Law requires us to do.

If you would like to see the information the PCN holds about you, please contact Samantha Brown, Practice Manager [email protected]

See also your rights listed below

ANONYMISED INFORMATION

Sometimes we may provide information about you in an anonymised form. If we do so, then none of the information we provide to any other party will identify you as an individual and cannot be traced back to you.

YOUR RIGHTS AS A PATIENT

The Law gives you certain rights to your personal and healthcare information that we hold, as set out below:

Access and Subject Access Requests

You have the right to see what information we hold about you and to request a copy of this information.

If you would like a copy of the information we hold about you, please email our Data Protection Officer.We will provide this information free of charge however, we may in some limited and exceptional circumstances have to make an administrative charge for any extra copies if the information requested is excessive, complex or repetitive.

We have one month from the date of a request to reply to you and give you the information that you require. We would ask, therefore, that any requests you make are in writing and it is made clear to us what and how much information you require. 

Please include your name, D.O.B and contact details so that we may deal with your request.

Online Access

We are currently working towards offering all existing patients on-line access to their medical records. All new patients will automatically be given on-line access to their records.

Please note that online access will also provide access to all relevant correspondence attached to your record. It is your responsibility to make sure that you keep your information safe and secure if you do not wish any third party to gain access.

  • Correction

We want to make sure that your personal information is accurate and up to date. You may ask us to correct any information you think is inaccurate. It is very important that you make sure you tell us if your contact details including your mobile phone number has changed.

  • Removal

You have the right to ask for your information to be removed however, if we require this information to assist us in providing you with appropriate medical services and diagnosis for your healthcare, then removal may not be possible.

  • Objection

We cannot share your information with anyone else for a purpose that is not directly related to your health, e.g. medical research, educational purposes, etc. We would ask you for your consent in order to do this however, you have the right to request that your personal and healthcare information is not shared by the Surgery in this way. Please note the Anonymised Information section in this Privacy Notice.

  • Transfer

You have the right to request that your personal and/or healthcare information is transferred, in an electronic form (or other form), to another organisation, but we will require your clear consent to be able to do this.

THIRD PARTIES MENTIONED ON YOUR MEDICAL RECORD

Sometimes we record information about third parties mentioned by you to us during any consultation. 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. Third parties can include: spouses, partners, and other family members. 

HOW WE USE THE INFORMATION ABOUT YOU

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.

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 clear consent to do so.

LAWFUL JUSTIFICATION FOR COLLECTING AND USING YOUR INFORMATION

In accordance with the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”), the Data Protection Act 2018 and any other relevant legislation, regulation, code of practice or guidance the Law says we need a lawful 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. 

LEGAL OBLIGATION: 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 (e.g. 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.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We carefully consider any personal information that we store about you, and we will not keep your information for longer than is necessary for the purposes as set out in this Privacy Notice.

CHILDREN

There is a separate Privacy Notice for patients under the age of 16, a copy of which may be obtained on request.

IF ENGLISH IS NOT YOUR FIRST LANGUAGE

If English is not your first language you can request a translation of this Privacy Notice. Please contact our Data Protection Officer.

COMPLAINTS

If you have a concern about the way we handle your personal data or you have a complaint about what we are doing, or how we have used or handled your personal and/or healthcare information, then please contact our Practice Manager, Samantha Brown.

However, you have a right to raise any concern or complaint with the UK information regulator, at the Information Commissioner’s Office: https://ico.org.uk/.

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.

COOKIES

The Surgery’s website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy.

SECURITY

We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secure. We regularly update our processes and systems and we also ensure that our staff are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that if we provide any other services, we carry out proper assessments and security reviews.

TEXT MESSAGING AND CONTACTING YOU

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 in the event that 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 actually contacting you and not another person.

We will always inform you if we record or monitor any telephone call you make to us.

  1. Telephone recordings are kept for one month
  2. They are kept in the practice managers office
  3. The practice manager & GP Partners are able to listen to the recordings in the managers office.
  4. They will be destroyed after one month

WHERE TO FIND OUR PRIVACY NOTICE

You may find a copy of this Privacy Notice in the Surgery’s reception, on our website, or a copy may be provided on request.

CHANGES TO OUR PRIVACY NOTICE

We regularly review and update our Privacy Notice. This Privacy Notice was last updated on 11th May 2022 by Samantha Brown, Practice Manager

SCHEDULE 1

List the Practices that are members of your PCN here

Salford Medical Practice

Clarendon Medical Practice

Cornerstone Medical Practice

Ordsall Health Surgery

Orient Road Medical Practice

Pendleton Medical Centre

Sorrel Bank Medical Practice

The Heights Practice

The Willows Medical Practice

Registering for NHS care

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

  • All patients who receive NHS care are registered on a national database
  • This database holds your name, address, date of birth and NHS Number but it does not hold information about the care you receive
  • The database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS data.
  • More information can be found at NHS Digital or you can telephone general enquiries on 0300 303 5678
  • NHS England’s privacy notice
  • NHS App privacy policy

The right to data portability

The right to data portability allows individuals to obtain and re-use their personal information for their own purposes across different services. It allows them to move, copy or transfer personal information easily from one IT environment to another in a safe and secure way. For example: it enables consumers to take advantage or applications and services which can use their information to find them a better deal.The right to data portability only applies when the individual has submitted their personal information directly, through electronic means to our Practice.This means that in most circumstances the right to data portability does not apply within the Practice.

Rights related to automated decision making and profiling

You have the right to object to any instances where a decision is made about you solely by automated means without any human involvement, including profiling.

The Practice does not undertake any decision-making about you using wholly automated means.

Invoking your rights

If you wish to invoke any of the data subject rights then please write to The Practice Manager, at the above address.

Payments

Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QUOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research .

In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws – NHS England’s powers to commission health services under the NHS Act 2006 or to delegate such powers to CCGs and the GMS regulations 2004 (73)1).

Public health

Public health encompasses everything from national smoking and alcohol policies, the management of epidemics such as flu, the control of large scale infections such as TB and Hepatitis B to local outbreaks of food poisoning or Measles. Certain illnesses are also notifiable; the doctors treating the patient are required by law to inform the Public Health Authorities, for instance Scarlet Fever.

This will necessarily mean the subjects personal and health information being shared with the Public Health organisations.

Some of the relevant legislation includes: the Health Protection (Notification) Regulations 2010 (SI 2010/659), the Health Protection (Local Authority Powers) Regulations 2010 (SI 2010/657), the Health Protection (Part 2A Orders) Regulations 2010 (SI 2010/658), Public Health (Control of Disease) Act 1984, Public Health (Infectious Diseases) Regulations 1988 and The Health Service (Control of Patient Information) Regulations 2002.

Processing of prescriptions

We process prescription requests on a daily basis. This involves our staff accessing information held about you on our computer database, to produce prescription(s) that you, your carer, nominated person, or Pharmacy has requested. Prescriptions can be requested using various methods: by telephone, online via our computer system, by post, in writing, via fax (if available) or in person. Please refer to our Prescription Procedure for further information. If using the postal service always allow extra time so you do not run out of your medication.

Collection/uplift of prescriptions

We will always ask for your details when a prescription uplift request is received; this could be your name, date of birth and address, medication you requested, or Community Health Index Number (which uniquely identifies you). This ensures that we can produce your prescription(s) efficiently, and reduces the risk of an incorrect prescription being given to you or your nominated person/carer/Pharmacy.

Please allow the allotted time before uplifting your prescription. Prescriptions can be collected/sent via the following methods:

  • In person
  • Via your nominated choice of person/organisation, this could be your carer, pharmacy, family member or friend (please be aware if you are not uplifting your own prescription we may ask for proof of identification from that person before we issue your Prescription, and we may also require a signature for our own records)
  • Post – if using the postal service, please always allow extra time when ordering your medication, as we cannot guarantee postal delivery schedules
  • Home delivery service – some Pharmacies may deliver your prescription directly to your home; please check with your local Pharmacist to see if they can provide this service for you

Summary Care Record (SCR)

The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.

Please be aware that if you choose to opt-out of SCR, NHS Healthcare Staff caring for you outside of this Surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, fax or phone. If you wish to opt-out of having an SCR please return a completed opt-out form to the practice.

Direct Care Emergencies

There are occasions when intervention is necessary in order to save or protect a patient’s life or to prevent them from serious immediate harm, for instance during a collapse or diabetic coma or serious injury or accident. In many of these circumstances the patient may be unconscious or too ill to communicate.

In these circumstances we have an overriding duty to try to protect and treat the patient. If necessary we will share your information and possibly sensitive confidential information with other emergency healthcare services, the police or fire brigade, so that you can receive the best treatment.

National Screening 

The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.

More information can be found at: Population screening programmes, or if you prefer please contact the Practice. Please contact the Practice if you do not wish to participate in any National Screening programmes offered.

Public Health

Public health encompasses everything from national smoking and alcohol policies, the management of epidemics such as flu, the control of large scale infections such as TB and Hepatitis B to local outbreaks of food poisoning or Measles. Certain illnesses are also notifiable; the doctors treating the patient are required by law to inform the Public Health Authorities, for instance Scarlet Fever.

This will necessarily mean the subjects personal and health information being shared with the Public Health organisations.

Some of the relevant legislation includes: the Health Protection (Notification) Regulations 2010 (SI 2010/659)the Health Protection (Local Authority Powers) Regulations 2010 (SI 2010/657) ,  the Health Protection (Part 2A Orders) Regulations 2010 (SI 2010/658) ,  Public Health (Control of Disease) Act 1984Public Health (Infectious Diseases) Regulations 1988 and The Health Service (Control of Patient Information) Regulations 2002

Risk stratification

‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.
Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health. Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the our NHS Clinical Commissioning Group (OCCG). Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes.

Further information about risk stratification.

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for
this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.

Medicines Management

CCG’s and some GP Federations operate Pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These Pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, is safe and also cost-effective. Where specialist prescribing support is required, the CCG Medicines Management Team may order medications on behalf of your GP Practice to support your care.
Supporting Locally Commissioned Services, CCGs support GP Practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality. The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

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…’

Clinical audit

Information may be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long-term conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

Clinical Research 

Sometimes your information may be requested to be used for research purposes – we will always ask your permission before releasing your information for this purpose.

Care Quality Commission (CQC)

The CQC regulates health and social care services to ensure that safe care is provided. The Law says that we must report certain serious events to the CQC, for example, when patient safety has been put at risk.  

Information about the Care Quality Care Commission (CQC)

National registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

Data retention

We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care, which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England.This is based on current legal requirements and professional best practice. If you transfer to another GP and we are asked to transfer your records we will do this to ensure your care is continued. Currently the NHS is required to keep GP records for 10 years after a patient has died. Exceptions to these rules are detailed in the code of practice.

Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

NHS Digital

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

Our legal basis for sharing data with NHS Digital

NHS Digital has been legally directed to collect and analyse patient data from all GP practices in England to support the coronavirus response for the duration of the outbreak. NHS Digital will become the controller under the General Data Protection Regulation 2016 (GDPR) of the personal data collected and analysed jointly with the Secretary of State for Health and Social Care, who has directed NHS Digital to collect and analyse this data under the COVID-19 Public Health Directions 2020 (COVID-19 Direction).

All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the data provision notice issued by NHS Digital to GP practices.

Under GDPR our legal basis for sharing this personal data with NHS Digital is Article 6(1)(c) – legal obligation. Our legal basis for sharing personal data relating to health, is Article 9(2)(g) – substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the COVID-19 Direction.

The type of personal data we are sharing with NHS Digital

The data being shared with NHS Digital will include information about patients who are currently registered with a GP practice or who have a date of death on or after 1 November 2019 whose record contains coded information relevant to coronavirus planning and research. The data contains NHS Number, postcode, address, surname, forename, sex, ethnicity, date of birth and date of death for those patients. It will also include coded health data which is held in your GP record such as details of:

  •  diagnoses and findings
  •  medications and other prescribed items
  •  investigations, tests and results
  •  treatments and outcomes
  •  vaccinations and immunisations

How NHS Digital will use and share your data

NHS Digital will analyse the data they collect and securely and lawfully share data with other appropriate organisations, including health and care organisations, bodies engaged in disease surveillance and research organisations for coronavirus response purposes only. These purposes include protecting public health, planning and providing health, social care and public services, identifying coronavirus trends and risks to public health, monitoring and managing the outbreak and carrying out of vital coronavirus research and clinical trials. The British Medical Association, the Royal College of General Practitioners and the National Data Guardian are all supportive of this initiative.

NHS Digital has various legal powers to share data for purposes relating to the coronavirus response. It is also required to share data in certain circumstances set out in the COVID-19 Direction and to share confidential patient information to support the response under a legal notice issued to it by the Secretary of State under the Health Service (Control of Patient Information) Regulations 2002 (COPI Regulations).

Legal notices under the COPI Regulations have also been issued to other health and social care organisations requiring those organisations to process and share confidential patient information to respond to the coronavirus outbreak. Any information used or shared during the outbreak under these legal notices or the COPI Regulations will be limited to the period of the outbreak unless there is another legal basis for organisations to continue to use the information. 

Data which is shared by NHS Digital will be subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the coronavirus purpose will be shared. Organisations using your data will also need to have a clear legal basis to do so and will enter into a data sharing agreement with NHS Digital. Information about the data that NHS Digital shares, including who with and for what purpose will be published in the NHS Digital data release register.

For more information about how NHS Digital will use your data please see the NHS Digital Transparency Notice for GP Data for Pandemic Planning and Research (COVID-19).

National Data Opt-Out

The application of the National Data Opt-Outto information shared by NHS Digital will be considered on a case by case basis and may or may not apply depending on the specific purposes for which the data is to be used. This is because during this period of emergency, the National Data Opt-Out will not generally apply where data is used to support the coronavirus outbreak, due to the public interest and legal requirements to share information.

Your rights over your personal data

To read more about the health and care information NHS Digital collects, its legal basis for collecting this information and what choices and rights you have in relation to the processing by NHS Digital of your personal data, see:

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access healthcare services, the quality of care received, the treatments and programmes available, confidentiality, information and a patients right to complain if things go wrong.

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under the Data Protection Act 2018.

NHS digital looking after information and data

National Fraud Initiative – Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see UK Government publications code of data.

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

Individual Funding Request

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a Clinician, for funding of specialised healthcare which falls outside the range of services and treatments that CCG has agreed to commission for the local population. An Individual Funding Request is taken under consideration when a case can be set out by a patient’s Clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition and who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s Clinician.

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to check which CCG is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

Sending a message to our Practice Team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our Practice. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Use of information we collect through automated systems when you visit our website

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to keep you signed in our site
  • to record your answers to surveys and questionnaires on our site while you complete them

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Data may be processed outside the European Union

Our website is hosted in the United Kingdom.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

For example online patient forms on our website are encrypted and delivered securely to the NHS system by an email service provider based in the United States of America. Their systems comply with provisions certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, a mechanism for cross border transfer of personal data.

Your Data

To find out more about the benefits of data sharing, how data is protected, or to make/change your opt-out choice visit NHS your data matters.

Child Health Information 

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with our NHS Trust health visitors and school nurses.

How we keep your information confidential and safe 

Everyone working for our organisation is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for specific purposes in accordance with the law. The NHS Digital Code of Practice on Confidential Information  applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this. 

The health records we use may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel. We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed. We are committed to protecting your privacy and will only use information collected lawfully in accordance with: 

  • Data Protection Act 2018 
  • Human Rights Act 
  • Common Law Duty of Confidentiality 
  • NHS Codes of Confidentiality and Information Security 
  • Health and Social Care Act 2015 
  • And all applicable legislation 

We have a senior person responsible for protecting the confidentiality of patient information and enabling appropriate information sharing. This person is called the Caldicott Guardian.

We are registered with the Information Commissioner’s Office (ICO) as a data controller which describes the purposes for which we process personal data. A copy of the registration is available from the ICO’s web site by searching on our name.

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

Other matters

Use of our website by children

  • If you are under 18, you may use our website only with consent from a parent or guardian
  • We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children
  • Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site information they find, wherever they visit

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

How you can complain

If you are happy for your data to be extracted and 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.

  • If you are not happy with our Privacy Policy or if have a complaint then you should tell us by writing to us
  • If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration
  • If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at ICO concerns
  • The Information Commissioner
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF
    Phone: 0303 123 1113

Caldicott Guardian

The Caldicott Guardian/IG Lead is responsible for;

  • Ensuring implementation of the Caldicott Principles and Data Security Standards with respect to Patient Confidential Data
  • Ensuring that the Practice processes satisfy the highest practical standards for handling patient information and provide advice and support to Practice staff as required
  • Ensuring that patient identifiable information is shared appropriately and in a secure manner. The Caldicott Guardian will liaise where there are reported incidents of person identifiable data loss or identified threats and vulnerabilities in Practice information systems to mitigate the risk.

The aim of the Caldicott Guardian is to ensure the organisation implements the Caldicott principles and data security standards; there is no need to appoint a Caldicott Guardian, but there is a need to have an Information Governance lead (sometimes referred to as a Caldicott lead) who, if they are not a clinician, will need support from a clinically qualified individual.

Department for Work and Pensions

Our practice is legally required to provide anonymised data on patients who have been issued with a fit note under the Fit for Work scheme. The purpose is to provide the Department for Work and Pensions with information from Fit Notes to improve the monitoring of public health and commissioning and quality of health services.

Opt-outs

You have a right to object to your information being shared.  Should you wish to opt out of data collection, please contact a member of staff who will be able to explain how you can opt out and prevent the sharing of your information; this is done by registering a Type 1 opt-out, preventing your information from being shared outside this Practice.

If you have previously opted-out of any data sharing arrangements, your opt-out I will continue to be valid.

Compliance with the Law

Our Privacy Policy has been compiled so as to comply with the Law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the Law of your jurisdiction, we would like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

Further Information – Understanding Patient Data

Understanding Patient Data’ supports better conversations about the uses of health information. Our aim is to explain how and why data can be used for care and research, what’s allowed and what’s not, and how personal information is kept safe. We work with patients, charities and Healthcare Professionals to champion responsible use of data.

Review of this Privacy Policy

We may update this Privacy Notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our Privacy Policy, please contact us.