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Privacy Notice & Fair Processing

WITHNELL HEALTH CENTRE

PRIVACY NOTICE

This privacy notice explains why Withnell Health Centrery collects information about you, how we keep it safe and confidential and how that information may be used.

This practice handles medical records according to the laws on data protection and confidentiality.

We share medical records with health professionals who are involved in proving you with care and treatment. This is on a need to know basis and event by event.

Why we collect information about you

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 with any NHS organisation. These records help to provide you with the best possible health care.

How we use your personal information

This fair processing notice explains why the GP practice collects information about you and how that information may be used.

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. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

NHS health 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. Our GP records data base is hosted by Emis Health Limited. All information is secured on their servers in Leeds, is protected by appropriate security and access is restricted to authorised personnel.

We use your mobile number to text you regarding matters of medical care such as appointment reminders unless you have opted out of this service.

Records which this GP Practice holds about you may include the following information:

    • Details about you, such as your address, carer, legal representative, 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

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. Information may be used within the GP Practice for clinical audit to monitor the quality of the services provided.

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

Data about you is used to manage national screening campaigns such as Flu, Cervical Cytology and Diabetes Prevention. Data about you, usually de-identified, is used to manage the NHS and make payments. Your data is used to check the quality of care provided by the NHS. 

How long does the practice hold my information?

As long as you are registered as a patient with Withnell Health Centre your paper records are held at the practice along with your GP electronic record. If you register with a new practice, they will initiate the process to transfer your records. The electronic record is transferred to the new practice across a secure NHS data-sharing network and all practices aim to process such transfers within a maximum of 8 working days. The paper records are then transferred via Primary Care Services England (operated on behalf of NHS England by Capita) which can take longer. Primary Care Services England also look after the records of any patient not currently registered with a practice and the records of anyone who has died.

Once your records have been forwarded to your new practice (or after your death forwarded to Primary Care Services England), a cached version of your electronic record is retained in the practice and classified as “inactive”. If anyone has a reason to access an inactive record, they are required to formally record that reason and this action is audited regularly to ensure that all access to inactive records is valid and appropriate. We may access this for clinical audit (measuring performance), serious incident reviews, or statutory report completion (e.g., for HM Coroner).

 

Change of Details

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.

How can I see what information you hold about me?

You have a right under data protection legislation to request to see what information the practice holds about you. You also have the right to ask for inaccuracies to be corrected and in some circumstances you have the right to request that we stop processing your data. Some of these rights are not automatic and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.

If you make a Subject Access Request, we will:

    • describe the information we hold about you

    • tell you why we are holding that information

    • tell you who it might be shared with

    • at your request, provide a copy of the information in an easy to read form.

In order to request this, you need to do the following:

    • Your request must be made in writing – for information from the hospital you should write direct to them

    • We will provide electronic copies (via online access, by email or on CDROM) free of charge.

    • We are required to respond to you within 1 month.

You will need to give enough 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.

In some circumstances there may be a charge to have a printed copy of the information held about you. If this is the case, this will be discussed with you before any charge is made.

If you would like to make a Subject Access Request or have any further questions, please contact Lorraine Bychowski – our Admin Officer.

HOW IS MY INFORMATION USED?

For provision of direct care:

In the practice, individual staff will only look at what they need in order to carry out such tasks as booking appointments, making referrals, giving health advice or provide you with care.

Sometimes your information may be used to run automated calculations. These can be as simple as calculating your Body Mass Index but they can be more complex and used to calculate some risks to your health that we should consider with you. The ones we use in practice include Qrisk (cardiovascular risk assessment – usually following an NHS Health check), Qdiabetes (diabetes risk assessment) and eFI (electronic frailty index). Whenever we use these profiling tools, we assess the outcome on a case-by-case basis. No decisions about individual care are made solely on the outcomes of these tools but they are used to help us assess and discuss your possible future health and care needs with you.

We share information about you with other health professionals where they have a genuine need for it to support your care.

We may also use your contact details to send you details of our feedback survey called the Friends & Family test. Any feedback that you provide in response is received anonymised and published in the same way
 

For commissioning and healthcare planning purposes:

In some cases, for example when looking at population healthcare needs, some of your data may be shared (usually in such a way that you cannot be identified from it). The following organisations may use data in this way to inform policy or make decisions about general provision of healthcare, either locally or nationally.

      • Lancashire County Council: Public Health, Adult or Child Social Care Services

      • Chorley & South Ribble Clinical Commissioning Group

      • NHS Digital (Formerly known as (HSCIC)

      • Other data processors which you will be informed of as appropriate.

    In order to comply with its legal obligations we may send data to NHS Digital when directed by the Secretary of State for Health under the Health and Social Care Act 2012.

    This practice contributes to local & national clinical audits and will send the data which are required by NHS Digital when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form, for example, the clinical code for diabetes or high blood pressure. Such data is often pseudonymised (this means using your NHS number instead of your name or other details) to ensure additional security. 

    In a few cases, where specific information is asked for, such as under the National Diabetes audit, you have the choice to opt out of the audit.

    For research purposes:

    Research data is usually shared in a way that individual patients are non-identifiable. Occasionally where research requires identifiable information you may be asked for your explicit consent to participate in specific research projects. The surgery will always gain your consent before releasing any information for this purpose.

    For safeguarding purposes, life or death situations or other circumstances when we are required to share information:

    We may also disclose your information to others in exceptional circumstances (ie life or death situations) or in accordance with Dame Fiona Caldicott’s information sharing review (Information to share or not to share).

    For example, your information may be shared in the following circumstances:

      • When we have a duty to others e.g. in child protection cases

      • Where we are required by law to share certain information such as the birth of a new baby, infectious diseases that may put you or others at risk or where a Court has decided we must.

         

    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 preventative 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 the software managed by Chorley and South Ribble CCG, and is only provided back to your GP as a 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.

    Medicines Management

    The Practice may conduct Medicines Management Reviews of medications prescribed to it patients. The 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 the Chorley and South Ribble Commissioning Group.

     

    How do we maintain the confidentiality of your records?

    We are committed to protecting your privacy and only use information collected lawfully in accordance with:

    •  Data Protection Act 1998 (from 25.05.2018 – GDPR)
    •  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 organisation 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 (i.e. life or death situations), where the law requires information to be passed on and; 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 with the framework set out by the Caldicott principles. This should be supported by the policies of their employers, regulators and professional bodies.

    Who are partner organisations?

    •  NHS Trusts / Foundation Trusts
    •  GP’s
    •  NHS Commissioning Support Units
    •  Independent Contractors such as dentists, opticians, pharmacies
    •  Private Sector Providers
    •  Voluntary Sector Providers
    •  Ambulance Trusts
    •  Clinical Commissioning Groups
    •  Social Care Services (Safeguarding)
    •  Health and Social Care Information Centre (HSCIC)
    •  Local Authorities
    •  Education Services
    •  Fire and Rescue Services
    •  Police and Judicial Services
    •  Voluntary Sector Providers
    •  Private Sector Providers
    •  NHS Digital (e.g. National Diabetes Audit)
    •  DVLA

     

    Only with your explicit consent can Withnell Health Centre release information about you from your GP record to relevant organisations. These may include.



      • Your employer

      • Insurance Companies

      • Solicitors

      • Local Authorities

      • Police

     

    Your right to opt-out of sharing your information

    You have the right to opt out or to object to ways in which your information is shared.

    Advice

    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

    Telephone: 08456 306060

     

    Website: www.ico.gov.uk

     

    Complaints

    If you have concerns or are unhappy about any of our services, please contact the Practice Manager at the Surgery.

     

    Further Information

    If you would like any further information about uses of your GP record or about any other aspect of NHS data sharing, then please contact the Surgery’s Caldicott Guardian (Dr M Siddiqui) or the Information Governance Lead (Practice Manager).



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