AUDLEM MEDICAL PRACTICE
This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you.
This privacy notice applies to your personal information processed by or on behalf of the practice.
This Notice explains:
Introduction
The General Data Protection Regulation (GDPR) came into force on 25th May 2018. This is a new regulation about the protection of any confidential and sensitive information.
This Notice explains how we collect and process your personal data and how we meet our obligations to you.
As your registered GP practice, we are the data controller for any personal data that we hold about you.
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
The information that we collect and use
When you register with Audlem medical Practice we must collect basic ‘personal data’ about you. This includes your name, address, contact details such as email and mobile. We may also ask you for health information, ethnicity, sex and religious beliefs. This type of information is called ‘Special data’. We are required to do this to ensure your healthcare information is linked between other healthcare providers.
We will collect the following types of information from you or about you from a third party for example a hospital that help in the delivery of your care:
The reason why we collect this data
The NHS Act 2006 and the Health and Social Care Act 2012 tell us that Practices need to promote and provide the health services in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training
In order to provide your care, we need to collect and keep information about you and your health on our records. Your records are used to:
We also may use, or share, your information for the following purposes:
The health care professionals who provide you with care must maintain records about your health and any treatment or care you have received previously. This maybe at another GP Surgery or at a Hospital. These records help to provide you with the best possible healthcare.
NHS health records may be electronic, on paper or a mixture of both. We use several ways of working and through the use of computerised systems this helps to ensure that your information is kept confidential and secure.
Legal Basis for Processing your Personal Information
We need to know your personal, sensitive and confidential data so that we can provide you with Healthcare services as a General Practice. Under the new rules called General Data Protection Regulation (GDPR) there are different reason why we may process your data, we mostly rely upon
Personal data:
Article 6.1(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.
For personal data including special category (health) data:
Article 9.2(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 systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3.
We will also be using your data within the following regulations:
Keeping your information safe and secure
Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.
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.
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 Regulations (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 who work with our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if necessary.
All the personal data we hold about you is processed in the UK.
Where we store your information
Your information will be collected either electronically using secure NHS Mail or a secure electronic record transferred over an NHS encrypted network connection. In addition physical information will be sent to your practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.
How we use your information
We may use your name, contact details and email address to inform you of services that may benefit you, with your consent only. There may be occasions where you will be asked if would like you to take part in innovations, research, improving services or identifying trends. We will always ask for your consent before we do this and you can choose to opt out at any stage.
Who we share your information with
We may also share your information, subject to strict agreements on how it will be used, with the following organisations;
Your information will only be shared if it is for the provision of your care or required for our statutory function and legal obligations.
Third party processors
When we use a third party service provider to process data on our behalf 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. An example of functions that may be carried out by third parties includes:
EMIS
Docman Clinical Systems
The safety and availability of your data is our utmost concern and we are confident that this approach will improve data security, integrity and performance.
Health Risk Screening / Risk Stratification
Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health. By using selected information such as age, gender, NHS number, diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.
To summarise Risk Stratification is used in the NHS to:
Your GP may use computer based calculations to identify if you are at risk, with support from the local Commissioning Support Unit.
Your GP will conduct this process outside of your GP appointment. This process is conducted electronically and without human intervention. The resulting report is reviewed by a healthcare team of staff within the Practice. This may result in contact being made with you if alterations to the provision of your care are identified.
The Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification; this is because it would take too long to carry out a manual review of all patients. You have the right to object to your information being used in this way.
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.
If you decide to object to this, you should be aware that this may have a negative impact on the timely provision of your direct care. Should you wish to object please contact the Practice Manager.
Research
This practice may undertake accredited research projects. Where this involves accessing or disclosing identifiable patient information, we will only do so with your explicit consent and with approval from the Research Ethics Committee or where we have been provided with special authority to do so without consent.
National screening programmes
More information can be found at: https://www.gov.uk/topic/population-screening-programmes
Clinical Audit
This practice contributes to national and internal clinical audits so that healthcare can be checked and reviewed.
Summary Care Record
NHS England have also created a Summary Care Record which contains information about medication you are taking, allergies you suffer from and any bad reactions to medication that you have had in the past.
The shared record means patients do not have to repeat their medical history at every care setting.
Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to stop your record from being shared or only allow access to parts of your record.
Your electronic health record contains lots of information about you. In most cases, particularly for patients with complex conditions and care arrangements, this means that you get the best care and means that the person involved in your care has all the information about you. The shared record means patients do not have to repeat their medical history at every care setting.
If you decide not to share your Information (Opting –Out)
You have the right to withdraw your consent at any time for any instance of processing, provided consent is the legal basis for the processing. Please contact your GP Practice for further information and to raise your objection.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care.
National Data opt out
Health and care organisations have until March 2021 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care. Our organisation is working towards compliance with the national data opt-out policy.
To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research);
https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
How long will we store your information?
We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.
. Access to your personal information
The General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format. This is known as a ‘Subject Access Request ‘
You also have the right to have it amended should it be inaccurate this is called:
In order to request access to your information, you need to do the following:
You should however be aware that some details in your health records may not be able to be given to you. This will be in the interests of your wellbeing or to protect the identity of a third party.
Covid Vaccination Programme
In order to deliver the Covid Vaccination programme to our patients we are working collaboratively with other practices within the local area. This is called a Primary Care Network or PCN. The other practices within this PCN are located in Audlem, Nantwich and Wrenbury. To ensure we can work safely and efficiently we may, from time to time need to share patient information. In order for us to do this safely we have put special agreements in place to protect your confidentiality. We will only share the absolute minimum data necessary to ensure we can look after you.
What should you do if your personal information changes?
It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.
Objections / Complaints
Should you have any concerns about how your information is managed at the GP practice please contact the Practice Manager. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with the Information Commissioner.
Information Commissioner:
Wycliffe house
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 01625 545745
www.informationcommissioner.gov.uk
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 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 Tara Moylan of Howbeck Healthcare.
Any queries in regard to Data Protection issues should be addressed to:
DPO.healthcare@nhs.net or 01270 275217
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 Manager or Data Protection Officer.
For further information on COVID related matters please see the following links:
Summary Care Record Covid 19 Supplementary Privacy Notice
GP Connect Patient Information
NHS Track & Trace Privacy Notice
NHS Digital Transparency Notice for GP data for Pandemic Planning & Research (COVID 19)