Privacy Policy

PARK LEYS MEDICAL PRACTICE

Privacy Notice

How we use your personal information

The Privacy Notice explains why the GP practice collects information about you and how that information may be used.  Health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in Clinic, etc.) These records are used to help to provide you with the best possible healthcare.

NHS health care records 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. Records this GP Practice hold about you may include the following information:

• Details about you, such as your name, address, carers, legal representatives and emergency contact details
• 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.

Legal Statements

GPs have to establish both a lawful basis and a special category condition to process special category data. The lawful basis for which we can process your data will usually fall under the category of Public Task (article 6.1e).  The special Category Condition for processing of your data will usually fall under “medical diagnosis” article 9.2h – the processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health and social care or treatment or the management of health and social care systems and services on the basis of union or member states law or pursuant to contract with a health professional and subject to the condition and safeguards – common law duty of confidentiality.

Enhancing Care

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Examples include:

• ·         Clinical audit. Information may be used for clinical audit to monitor the quality of the service provided. Some of this information may be held centrally and used for statistical purposes. Where we do this we take strict measures to ensure that individual patients cannot be identified e.g. the National Diabetes Audit.
• Clinical Research. 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.
• 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.
• 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 1998.  Data matching by the Cabinet Office is subject to a Code of Practice.  View further information on the Cabinet Office’s legal powers and the reasons why it matches particular information. https://www.gov.uk/government/publications/code-of-data-matching-practice-for-nationalfraud-initiative
• Risk Stratification. Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re) admission and identifying a need for preventive intervention. 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 managed by our CCG and is only 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.
• 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 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 the CCG that 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.
• Safeguarding. To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.
• 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.
• Local Sharing via My Care Record. Your patient record is held securely and confidentially on our electronic system. If you require attention from a health professional such as an Emergency Department, Minor Injury Unit or Out Of Hours location, those treating you are better able to give appropriate care if some of the information from your GP patient record is available to them. This information can be locally shared electronically via My Care Record.  In all cases, the information is only used by authorised health and social care professionals in Coventry and Rugby based organisations, involved in your direct care. Your permission will be asked before the information is accessed, unless the health and social care user is unable to ask you and there is a clinical reason for access, which will then be logged.
• 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. This service is provided to practices within Coventry and Rugby Clinical Commissioning Group.

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 1998 and General Data Protection Regulation 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 orgainisation 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, or in accordance with the new 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 be the Caldicott principles. They should be supported by the polices of their employers, regulators and professional bodies.

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
• GP’s
• 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
• Health and Social Care Information Centre (HSCIC)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police and Judicial Services
• Other data processors’ which you will be informed of

During your communication with the practice, we expect that your data will be shared with the relevant organisations but in some cases you will be asked for explicit consent for this to happen when this is required.

Access to personal information

You have a right under the Data Protection Act 1998 to request access to view or to obtain copies of what information the surgery holds about you, 3^rd party information will be redacted.  Patients can request amendments, corrections, and erasure but do not have the right to be forgotten.  Right of erasure does not apply to a person’s health record or care record or for public health or scientific research purposes.  In order to request this, requests must be made in writing to the GP – for information from the hospital you should write to them directly.

• There may be a charge to have a printed copy of the information held about you if the demand is unfounded, excessive or repetitive
• We are required to respond to you within 28 days
• 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.  Photo ID is required.

Change of Details

It is important that you tell the person treating you, or a member of staff, if any of your details such as your name or address or contact details 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 and to prevent any possible breach of date confidentiality.  By supplying us your mobile number we may use this to send SMS reminders related to your health condition.  Likewise, an email address may be used in future if you have given us this.

Notification

The Data Protection Act 1998 requires organisations to register a notification with the Information Commissioner to describe the purpose for which they process personal and sensitive information.  This information is publicly available on the information commissioner’s office website www.ico.org.uk  The practice is registered with the Information Commissioners Office (ICO).  Registration Number: Z5076976

https://ico.org.uk/ESDWebPages/Entry/Z7082058

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential is:  Springfield Medical Practice.  The Data Protection Officer is to be decided, in collaboration with Coventry and Rugby CCG, but currently our Practice Manager will fulfill that role for the practice.

Objections / Complaints

Should you have concerns about how your information is managed at the GP, please contact the GP Practice Manager.  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.

Claire Underhill

Practice Business Manager

Park Leys Medical Practice

Keresley Green Medical Centre

Bennetts Road South

Coventry

CV6 2FL

Tel: 024 7633 2636

If you are still unhappy following a review by the Practice you can then complain to the Information Commissioners Office (ICO). www.org.uk, casework@ico.org.uk, telephone: 0303 123 1113 (local rate) or 01625 545 745

Where To Find Us...