How we use your information

This privacy notice explains why the GP Practice collects information about you, and how that information may be used.

As data controllers, GPs have fair processing responsibilities under the Data Protection Act 2018. In practice, this means ensuring that your personal confidential data (PCD) is handled in ways that are transparent and that you would reasonably expect. The Health and Social Care Act 2012 changed the way that personal confidential data are processed, therefore it is important that patients are made aware of, and understand these changes and that you have an opportunity to object and know how to do so.

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received within the NHS (e.g. NHS Hospital Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

NHS health records may be processed electronically, on paper or a mixture of both, and a combination of working practices and technology are used to ensure that your information is kept confidential and secure. Records held by this GP Practice may include the following information:

• Details about you, such as address and next of kin
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
• 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

The Practice collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that the information is kept confidential. We can disclose personal information if:

• It is required by law
• You consent – either implicitly or for the sake of their own care or explicitly for other purposes
• It is justified in the public interest

Some of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict measures to ensure that individual patients cannot be identified.

On some occasions it may be necessary to undertake clinical audits of records to ensure that the best possible care has been provided to you or to prevent the spread of infectious disease, wherever possible this will be done in anonymised form.

Sometimes your information may be requested to be used for research purposes – the Practice will always endeavor to gain your consent before releasing the information.

Under the powers of the Health and Social Care Act 2012 (HSCA) NHS Digital can request Personal Confidential Data (PCD) from GP Practices without seeking patient consent. Any patient can choose to withdraw their consent to their data being used in this way. When the Practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-out’ of each new scheme.

A patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

Risk Stratification

Risk stratification is a process for identifying and managing patients who are at high risk of emergency hospital admission. Typically this is because patients have a long term condition such as COPD or cancer. NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help prevent avoidable admissions.

Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information using software as the data processor and is only provided back to your GP or member of your care team as data controller in an identifiable form.

Risk stratification enables your GP to focus on the 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 Risk Stratification.

Should you have any concerns about how your information is managed, or wish to opt out of any data collection at the Practice, please contact the Practice Manager or your healthcare professional to discuss how the disclosure of your personal information can be limited.

Patients have the right to change their minds and reverse a previous decision. Please contact the practice if you change your mind regarding any previous choice.

Safeguarding

Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm.

These circumstances are rare however we do not need your consent or agreement to do this. For more information please see our Safeguarding Policy.

Invoice Validation

If you have received treatment within the NHS, the CCG may require access to your personal information in order to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.

Information such as your name, address and date of treatment may be passed on to enable the billing process. These details are held in a secure environment and kept confidential. This information will only be used to validate invoices, and will not be shared for any further Commissioning purposes.

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 the Data Protection Act 2018 (which is overseen by the Information Commissioner’s Office), Human Rights Act, the Common Law Duty of Confidentiality, and the NHS Codes of Confidentiality and Security.

All of our staff, contractors and committee members receive appropriate and on-going training to ensure they are aware of their personal responsibilities and have contractual obligations to uphold confidentiality, enforceable through disciplinary procedures. Only a limited number of authorised staff have access to personal information where it is appropriate to their role and is strictly on a need-to-know basis.

We maintain our duty of confidentiality to you at all times. 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), or where the law requires information to be passed on.

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
• Specialist Trusts
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police
• Other ‘data processors’ during specific project work, eg Diabetes UK

Access to personal information

You have a right under the Data Protection Act 2018 to access/view information the Practice holds about you, and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject access. If we do hold information about you we will:

• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form.

If you would like to make a ‘subject access request’ please complete the form and ensure you provide the surgery with the identification documents requested. If this is not your first application, there may be a charge for this service.

Any changes to this notice will be published on our website and on the Practice notice board.

The Practice is registered as a data controller under the Data Protection Act 2018. The registration number is Z6225035 and can be viewed online in the public register at: https://ico.org.uk/ESDWebPages/Search

Further information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found in:

• The NHS Care Record Guarantee: National Care Records Service – NHS England Digital
• The NHS Constitution: https://www.gov.uk/government/publications/the-nhs-constitution-for-england
• The NHS Guide to Confidentiality gives more information on the rules around information sharing: https://digital.nhs.uk/data-and-information/looking-after-information/data-security-and-information-governance/codes-of-practice-for-handling-information-in-health-and-care/a-guide-to-confidentiality-in-health-and-social-care
• An independent review of information about patients is shared across the health and care system led by Dame Fiona Caldicott was conducted in 2012. The report, Information: To share or not to share? The Information Governance Review, be found at: https://www.gov.uk/government/publications/the-information-governance-review
• NHS England – Data Services for Commissioners provides further information about the data flowing within the NHS to support commissioning: https://www.england.nhs.uk/ourwork/tsd/data-services/