Privacy Notice
Your information, what you need to know
This privacy notice explains why we collect information about you, how that information may be used, how we keep it safe and confidential and what your rights are in relation to this.
Why we collect information about you
Patients
Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received within any NHS organisation. These records help to provide you with the best possible healthcare and help us to protect your safety.
We collect and hold data for providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we may collect information about you which helps us respond to your queries or secure specialist services.
The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments. We may keep your information in written form and/or in digital form.
The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments.
Staff
As employers we are required to keep records about your employment to ensure we meet our legal responsibilities for example to ensure all employees have the right to work in the UK and to enable the development of a comprehensive understanding our workforce and how it is deployed to support our business functions.
We collect and hold data to:
- Inform the development of HR policies
- Support workforce planning
- Make recruitment decisions
- Enable staff to be paid and have the correct pension contributions deducted
- Monitor timekeeping and attendance
- Assess training needs and maintain training records
- Implement disciplinary and grievance processes
- Maintain up to date records to ensure effective correspondence and ensure that we can contact you or your next of kin in an emergency. For example, your details are shared with the payroll company for calculation of salary and production of payslip and the bank to pay you.
The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and disciplinary matters. We may keep your information in written form and/or in digital form.
Details we collect about you
Patients
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.
Records which this GP practice may hold about you include the following:
- Details about you, such as your 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 your carers
- The practice may receive emails and letters about your care (most frequently from hospitals and community services). These are scanned into your medical record and the originals are shredded using a confidential waste company.
- Patients can email the practice ([email protected]). These emails may be saved into your record if clinically relevant. If not clinically relevant (e.g. a prescription request once actioned does not need to be added to your medical record) it will be deleted.
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 the purposes advised with consent given by the patient, unless there are other circumstances covered by 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
- General Data Protection Regulation
- 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 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.
How we use your information
Improvements in information technology are also making it possible for us to share data with other healthcare organisations for providing you, your family and your community with better care. For example, it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing section below.
Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.
You may choose to opt-out to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start.
Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.
You can object to your personal information being shared with other healthcare providers which will not affect your entitlement to care, but you should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.
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.
Practice Website ([email protected])
Passive information collection and use
As you navigate through our website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, internet tags and navigational data collection.
Please read the section on Cookies below and review the Cookie Settings for detailed information about Cookies and other tracking technologies used on our site. In this policy you will also find information on how to disable cookies and tracking technologies if you do not agree to their use as well as the consequence(s), if any, of disabling each specific cookie/tracking technology. If you do not disable any cookies or tracking technologies, we will infer your consent to their use.
We and our third party service providers may passively collect and use information in a variety of ways, including:
- Through your browser - Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.
- IP Address – Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
- Using pixel tags, web beacons, clear GIFs, or other similar technologies - These may be used in connection with some site pages and HTML-formatted e-mail messages to, among other things, track the actions of site users and e-mail recipients, and compile statistics about Site usage and response rates.
- Device Information – We may collect information about your mobile device, such as a unique device identifier.
Cookies and IP addresses
A cookie is a small text file that is downloaded onto a computer or smartphone when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions. We use these to monitor access to our website and tailor any developments based on usage and pages visited.
We use Google Analytics software on this site to anonymously track how visitors interact with this website. This includes identifying:
- The pages visited on this site
- How long the visitor spends on each page on this site
- How visitors got to the site
- What visitors click on while visiting the site
We do this to help make sure the site is meeting the needs of visitors and help us make improvements, for instance improving site search.
We don’t use cookies to track the identity of visitors or the information they have entered into the site.
You give us consent to using cookies for analytic purposes if you continue to use our website. Alternatively, you can switch off cookies in your browser and the site will still work normally.
Third Party Sites and Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any App) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates.
Security
We use reasonable organisational, technical and administrative measure to protect personal information under our control and in accordance with this privacy policy.
Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk.
If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section.
Cross Border Transfers
Personal information other than medical data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms to send communication emails to our users.
Patients and staff
CCTV
Images are recorded to protect staff and practice property. It will not be used for any other purpose. Images from the CCTV system are securely stored and only authorised personnel may access them. The recorded images will only be retained long enough for any incident to come to light (e.g. for a theft to be noticed) and the incident to be investigated. Except for law enforcement bodies, images will not be provided to third parties.
Telephone Recording
All calls are recorded for training and quality purposes. There is an announcement on the telephone system to alert anyone calling the surgery that calls may be recorded. Telephone calls are stored securely and only accessed by authorised personnel.
How we keep your information confidential and safe
Patients
Everyone working for our organisation is subject to the Common Law Duty of Confidentiality. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by 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.
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.
Patients and staff
The 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
How we use your information
Patients
Improvements in information technology are also making it possible for us to share data with other healthcare organisations for providing you, your family and your community with better care. For example, it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing section below.
Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below. Please also see https://digital.nhs.uk/data-and-information/looking-after-information for more information.
You may choose to withdraw your consent to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start.
Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared. Please see right to withdraw consent section below.
You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.
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.
Accurx
Accurx is a clinical text messaging software that allows two-way communication between patients and the practice.
Child Health Information – CHIS
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 NHS health visitors and school nurses, with the NWL Commissioning Support Unit, who provide the Child Health Information Service (CHIS) on behalf of NHS England.
Clinical audit
Information may be used by the ICB for clinical audit to monitor the quality of the service provided to patients with long terms 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 normally ask your permission before releasing your information for this purpose.
In some instances, the Confidentially Advisory Group, part of the Health Research Authority may allow for identifiable information to be shared with researchers without consent of individuals. You may however opt-out of this, details of which can be found below under the ‘National Data Opt-Out’.
Electronic Prescribing Service (EPS)
We share information about your medications with your pharmacy when you inform us of your usual pharmacy. This allows your repeat medication prescription to be sent securely to your preferred pharmacy so that you do not need to attend the surgery to collect your prescription.
Enhanced Data Sharing Module
The Argyle Surgery uses TPP SystmOne and this allows you to choose whether other health and care providers can access your information to help provide you with care. We have drawn up an “allowed list” of local organisations with whom we can share your data (when you register for their services and give them verbal permission to provide your care through a TPP clinical system). See the link below under who are our partner organisations.
Organisations outside of this allowed group who use the same software will require formal documented permission to see your records. Your GP system will send you an SMS or email which you can give to the organisation asking for access which will formally validate your consent. It is possible for you to set your own specific permissions (as distinct from the allowed list we have provided).
GP Connect
We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.
GP Connect is not used for any purpose other than direct care.
Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS Digital service called GP connect.
The NHS 111 service (and other services determined locally e.g. Other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services.
Further information can be found here: https://digital.nhs.uk/services/gp-connect
Improving Diabetes Care and long-term condition management
We share information about patients with diabetes with the Diabetic Retinopathy Screening Service (DRSS) to ensure that all diabetic patients receive annual screening.
Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.
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 ICB 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 which ICB 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.
Local Information Sharing
Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. In order to provide you with health and social care services your GP practice works in close collaboration with neighbouring practices as part of a Primacy Care Network (PCN). Our practice is part of The Ealing Network PCN. The organisational boundary within which professionally trained staff can access your health record without consent has extended from your GP practice to this Primary Care Network and staff employed on its behalf. Staff are trained to understand their legal and professional responsibilities of confidence to their patients and will only access your records when they are required to do so to support you care. They will identify themselves and their role using a smart card and access to your PCN record is recorded, monitored, and audited.
If you require attention from a local health or care professional outside of your usual PCN services, such as in an Evening and Weekend GP Hub services, Emergency Department, Minor Injury Unit or Out of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent.
Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or EMIS remote consulting system).
In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Aside from your registered health care provider, your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).
MISL
We use a secure storage service to store our patient records off site.
MJOG
We use a text messaging platform called MJOG to send text messages regarding health campaigns and screening and to ask for feedback about our services.
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.
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.
NHS Digital
The NHS needs data about the patients it treats in order to plan and deliver its services and to ensure that care and treatment provided is safe and effective. The General Practice Data collection for planning and research will help the NHS to improve health and care services for everyone by collecting patient data that can be used to so this. We have agreed to share the patient data we look after in our practice with NHS Digital who will securely store, analyse, publish and share this patient data to improve health and care services for everyone. This includes:
- Informing and developing health and social care policy
- Planning and commissioning health and care services
- Taking steps to protect public health including managing and monitoring the covid pandemic
- In exceptional circumstances, providing you with individual care
- Enabling healthcare and scientific research
This means that we can get on with looking after our patients and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it to improve health and care for everyone.
Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality.
Data may be shared from the GP medical records about:
- any living patient registered at a GP practice in England when the collection started – this includes children and adults
- any patient who died after this data sharing started, and was previously registered at a GP practice in England when the data collection started
We will not share your name or where you live. Any other data that could directly identify you, for example your NHS number, General Practice Local Patient Number, full postcode and date of birth, is replaced with unique codes which are produced by de-identification software before the data is shared with NHS Digital.
NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and GP practices.
The full privacy notice can be found here: NHS Digital Privacy Notice
NHS England
NHS England has a legal duty to keep a list of all patients registered with GP Practices in England. This list is held in the National Health Application and Infrastructure Services (NHAIS) systems. These systems also hold data about patients registered with GPs in Wales and the Isle of Man. NHS Digital, and other service agencies around the country manage these systems on behalf of NHS England.
The data are used to provide Primary Care Support Services. NHS England has a contract with Capita Business Services Ltd, operating as Primary Care Support England to provide these services which include:
- Moving paper patient records between practices and into storage when patients leave or move practices
- Storing paper records of unregistered and deceased patients
- Sending letters to patient to inform them of their NHS number when one is first allocated
- Providing the cervical cytology call and recall administrative service on behalf of Public Health England
- Delivering prior notification lists of patients eligible for screening to GPs
- Processing new patient registrations and de-registrations at GP practices to maintain accurate lists of numbers of patients at GP Practices–
- Making payments to NHS Ophthalmic practitioners for NHS services provided
- Making payments to GP practices based on lists of registered patients, and specific payments for childhood vaccinations and immunisations
- Writing to patients on behalf of Primary Care commissioners with regards to provision of primary care services or assignment to a GP Practice list.
- Writing to patients when they have been removed from their GP Practice list
- Conducting audits and reconciliations of GP Practice lists to ensure list sizes are accurate.
The data from the NHAIS list is used to update the Personal Demographics Service (PDS). This provides information for hospitals, Public Health England Cancer Screening Programmes, Child Health systems and other health providers making sure that they know their patients’ current GP Practice and can access other essential information such as the Summary Care Record.
NHS England Regional Local Teams (RLTs) and Integrated Care Boards (ICBs) (where delegated) may also undertake necessary processing of a limited subset of these data (e.g. patient name, address, postcode and NHS number) for example when managing practice closures and list dispersals (the process used to allocate patients to neighbouring GP Practices). This processing is necessary to inform patients of their reregistration options and ‘Choice’ as required under the NHS Constitution.
Sources of the data: The data are transferred automatically from GP practice systems in to the NHAIS systems. The data is also updated by Primary Care Support England after notifications from data subjects themselves.
The categories of personal data held on the systems are:
- Name – including any previous names, unless name changes are the result of adoption, gender reassignment or witness protection schemes
- Current and historic addresses and whether the address is a registered nursing home
- Dates of Birth
- Gender
- Place of Birth
- NHS number
- Cervical Screening history
- Special allocation scheme status
- Current and Previous GP practice details
- GPs Banking details
Categories of recipients: Statistical information (numbers) produced from NHAIS systems is shared with other organisations to enable them to fulfil their statutory obligations, for example the Office of National Statistics, Public Health England and local authorities for their public health purposes. Personal data may also be shared with the approval of NHS England’s Caldicott Guardian when he is assured that confidentiality is respected, for example when hospitals need to update their records for direct care purposes or to support specific research projects with ethical and or Health Research Authority approval.
Patient Participation Group (PPG)
We invite all patients at point of registration and opportunistically thereafter if they would like to be part of our Patient Participation Group. Email addresses and contact details are kept securely for the purpose of communicating with the group about meetings and any other events or issues we would like the PPG’s opinion on.
Public Health
We share information about patients with Public Health England in relation to notifiable diseases (e.g. measles, salmonella), screening programmes (cervical cytology) and childhood immunisations.
Shred it
The practice uses shred it a document shredding service to securely dispose of confidential material
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 NWL Clinical Commissioning Group. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from:
NHS England » 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. Please see below for more information on how to withdraw consent.
Safeguarding
To ensure that adult and child 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 reasons 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.
During the height of the pandemic changes were made to the Summary Care Record (SCR) to make additional patient information available to all appropriate clinicians when and where they needed it, to support direct patients care, leading to improvements in both care and outcomes.
These changes to the SCR will remain in place, unless you decide otherwise.
Regardless of your past decisions about your Summary Care Record preferences, you will still have the same options that you currently have in place to opt out of having a Summary Care Record, including the opportunity to opt-back in to having a Summary Care Record or opt back in to allow sharing of Additional Information.
You can exercise these choices by doing the following:
1. Choose to have a Summary Care Record with all information shared. This means that any authorised, registered and regulated health and care professionals will be able to see a detailed Summary Care Record, including Core and Additional Information, if they need to provide you with direct care.
2. Choose to have a Summary Care Record with Core information only. This means that any authorised, registered and regulated health and care professionals will be able to see limited information about allergies and medications in your Summary Care Record if they need to provide you with direct care.
3. Choose to opt-out of having a Summary Care Record altogether. This means that you do not want any information shared with other authorised, registered and regulated health and care professionals involved in your direct care. You will not be able to change this preference at the time if you require direct care away from your GP practice. This means that no authorised, registered and regulated health and care professionals will be able to see information held in your GP records if they need to provide you with direct care, including in an emergency.
To make these changes, you should inform your GP practice or complete this form and return it to your GP practice.
Supporting Medicines Management
NWL ICB uses 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, safe and cost-effective. Where specialist prescribing support is required, the ICB medicines management team may provide support relating to obtaining medications on behalf of your GP Practice to support your care.
Supporting Locally Commissioned Services
ICBs 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.
Suspected Cancer
Data may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital NHS Foundation Trust, London North West Healthcare NHS Trust and University College London Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual patients.
Universal Care Plan (UCP – formerly CMC)
UCP is a platform which gives patients an opportunity to express their wishes about how and where they are treated. It enables all healthcare professionals to offer more personalised medical care, with full respect to each patient’s preferences.
Data Retention
We manage patient records in line with the Records Management Code of Practice 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, based on current legal requirements and professional best practice.
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
- GP Federations
- Independent Contractors such as dentists, opticians, pharmacists
- Private Health Sector Providers e.g. Bupa
- Voluntary Sector Providers e.g. carers centre
- Ambulance Trusts
- Integrated Care Boards
- Local Authorities e.g. social services
- Education Services e.g. school nurses
- Fire and Rescue Services
- Police
- Other ‘data processors’
We will not share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function. No information will ever be shared where we do not have a lawful basis to do so.
Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below).
This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence.
Right to withdraw consent to share personal information (Opt- Out)
Patients
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 do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.
There are two main types of opt-out.
Type 1 Opt-Out
If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to register a Type 1 opt out please fill out the form below and email it to [email protected]
National Data Opt-Out
NHS Digital have created an opt-out system named the National Data Opt-Out which allows individuals to opt-out of their information being used for planning and research purposes. From 25 May 2018, NHS Digital has had to apply this opt-out for all their data flows, and from 2020 all health and care organisations will have to ensure the opt-out is respected. Individuals who previously opted out with a ‘Type 2’ objection will not have to do anything as you will be automatically be opted out.
If you wish to apply the National Opt-Out, please go to NHS Digitals website here https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/
Access to your information
Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing or speak to a member of the Practice staff. Under special circumstances, some information may be withheld.
If you wish to have a copy of the information we hold about you, please email the Practice Manager at [email protected]
Our practice is compliant with the National Data Opt Out
Staff
You have the following rights in relation to the personal data we hold on you:
- The right to be informed about the data we hold on you and what we do with it
- The right of access to the data we hold on you
- The right for any inaccuracies in the date we hold on you, however they come to light to be corrected. This is also known as “rectification”
- The right to have data deleted in certain circumstances. This is also known as “erasure”
- The right to restrict the processing of data.
- The right to transfer the data we hold on you to another party. This is also known as “portability”
If you wish to exercise any of these rights please speak to the Practice Manager
Access to your information
Patients and staff
Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.
If you wish to have a copy of the information we hold about you, please contact, the Practice Manager
Change of Details
Patients
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 are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.
Staff
Please let your line manager know if there are any changes to your details so that our records for you are accurate and up to date.
Mobile telephone number
Patients
If you provide us with your mobile phone number, we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.
Notification
The Data Protection Act 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.
We are registered as a data controller and our registration can be viewed online in the public register at: https://ico.org.uk/ESDWebPages/Entry/Z5539588
Any changes to this notice will be published on our website and in a prominent area at the Practice.
Complaints
If you have concerns or are unhappy about any of our services, please contact the Practice Manager, or email [email protected]
For independent advice about data protection, privacy and data-sharing issues, you can contact:
The Information Commissioner
Wycliffe House
Water Lane
Wilmslow Cheshire SK9 5AF
Information we are required to provide you
| Data Controller contact details
|
The Argyle Surgery, 128 Argyle Road, Ealing, W13 8ER
|
| Data Protection Officer contact details
|
Dr E Norman-Williams ([email protected]) or DPO NHS North West London CCG ([email protected]) |
| Purpose of the processing for the provision of your healthcare
|
|
| Lawful basis for processing
for the provision of your healthcare |
These purposes are supported under the following sections of the GDPR:
Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and |
| Article 9(2)(h) ‘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 or social care or treatment or the management of health or social care systems and services…” | |
| Healthcare staff will also respect and comply with their obligations under the common law duty of confidence. | |
| Purpose of the processing for medical research and to measure quality of care | Medical research and to check the quality of care which is given to patients (this is called national clinical audit). |
| Lawful basis for processing for medical research and to measure the quality of care | The following sections of the GDPR mean that we can use medical records for research and to check the quality of care (national clinical audits)
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 medical research: there are two possible conditions. | |
| Either:
Article 9(2)(a) – ‘the data subject has given explicit consent…’ Or: Article 9(2)(j) – ‘processing is necessary for… scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member States law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject’. |
|
| To check the quality of care (clinical audit):
Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’ |
| Purpose of the processing
to meet legal requirements |
Compliance with legal obligations or court order. |
| Lawful basis for processing to meet legal requirements | These purposes are supported under the following sections of the GDPR:
Article 6(1)(c) – ‘processing is necessary for compliance with a legal obligation to which the controller is subject…’ Article 9(2)(g) – ‘processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject; Schedule 1 part 2 of the Data Protection Act 2018 lists the substantial public interest conditions, of which paragraph 2 states data can be processed when the purpose is for the exercise of function conferred on a person by enactment or rule of law. |
| Purpose of the processing for National screening programmes | The NHS provides several national health screening programmes to detect diseases or conditions early such as cervical and breast cancer, aortic aneurysm and diabetes.
The information is shared so that the correct people are invited for screening. This means those who are most at risk can be offered treatment. |
| Lawful basis for processing
for National screening programmes |
The following sections of the GDPR allow us to contact patients for screening.
Article 6(1)(e) – ‘processing is necessary…in the exercise of official authority vested in the controller…’’ Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’ |
| Lawful basis for processing for employment purposes | The following sections of GDPR allow us to process staff data in an employment capacity Article 6(1)(b) – ‘processing is necessary for compliance with a legal obligation’
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 … law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;’ |
| Rights to object | You have the right to object to information being shared between those who are providing you with direct care.
This will not affect your entitlement to care, but this may affect the care you receive – please speak to the practice. Any objection will be reviewed by the Practice and a decision taken on whether to uphold the request. The right to object is not an absolute right. In appropriate circumstances it is a legal and professional requirement to share information for safeguarding reasons. This is to protect people from harm. The information will be shared with the local safeguarding service |
| Right to access and correct | You have the right to access your medical record and have any errors or mistakes corrected. Please speak to a member of staff.
You have the right to request rectification of your record if you believe information contained within it is wrong. Information will only be deleted in very exceptional circumstances. In most instances the original information will be retained on the record noting the rectified information. |
| Retention period | GP medical records will be kept in line with the law and national guidance. Information on how long records are kept can be found at: www.digital.nhs.uk/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016 or speak to the practice. |
| Right to complain | You have the right to complain to the Information Commissioner’s Office. You may follow this link www.ico.org.uk/contact-us or call the helpline 0303 123 1113 |
| Data we get from other organisations | We receive information about your health from other organisations who are involved in providing you with health and social care. For example, if you go to hospital for treatment or an operation the hospital will send us a letter to let us know what happens. This means your GP medical record is kept up-to date when you receive care from other parts of the health service. |
Further Information
Further information about the way in which the NHS uses personal information and your rights in that respect can be found at the links below.
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.
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 health services, the quality of care you’ll receive, the treatments and programmes available to you, confidentiality, information and your right to complain if things go wrong. https://www.gov.uk/government/publications/the-nhs-constitution-for-england
Reviews of and Changes to our Privacy Notice
We will keep our Privacy Notice under regular review. This notice was last reviewed in March 2023