General Data Protection Regulations 2018 (formerly Data Protection Act 1998)

How we use your personal information

This fair processing notice explains why the GP Direct 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.
Records which this GP Practice hold 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 service 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.

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 deidentified information using software managed by our clinical system provider, 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.

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 Harrow 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:

  • General Data Protection Regulations 2018 (formerly Data Protection Act 1998)
  • 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 within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.

Who are our partner organisations?

  • NHS Trusts / Foundation 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 & Judicial Services
  • Voluntary Sector Providers
  • Private Sector Providers
  • Care Quality Commission (CQC)
  • Driver and Vehicle Licensing Agency (DVLA)

You will be informed who your data will be shared with and in some cases asked for explicit consent for this happen when this is required. We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.

Third Party Applications / Providers

To run an efficient service at the practice we employ the use and may also share your information, subject to strict agreements on how it will be used with the following third party applications / providers:

EMIS Web – Our main clinical system for delivering integrated healthcare. EMIS Web allows healthcare professionals to record, share and use vital information so they can provide better, more efficient care. EMIS Web currently uses Amazon Web Services (AWS) for patient data storage.

Mjog – provides advanced, multi-channel digital two-way messaging, that delivers appointment reminders, results, Patient surveys and health campaigns, automatically via SMS.

Horizon – is a complete hosted communications service that provides businesses with an extensive range of fixed telephony capabilities. Horizon is hosted on the Gamma Network.

accuRx – is a messaging service that allows us to directly text patients. It can be used to send advice, notify a patient of normal results, remind them to book appointments.

Apollo Medical Software Solutions – manages the extraction of medical information from your medical record to the whole systems integrated care dashboard which is governed by a data sharing agreement. The information is accessible to third party organisations with a legitimate interest in your care, such as the virtual wards (which provide patients with care in their own homes) and end of life care teams, who support in the delivery of care to patients who are in the end of life stage of care.

Docmail – a facility to send large volumes of letters to patients

Health Intelligence – is a leading software provider of information management solutions for health organisations in the UK. The main areas of focus are on Diabetic Eye Screening services and population based data analysis to improve Long Term Conditions diagnosis, promote prevention.

NHS Mail – is a secure email service approved by the Department of Health for sharing patient identifiable and sensitive information. Any organisation commissioned to deliver NHS healthcare or related activities can use NHSmail.

Open Exeter – Open Exeter is a secure online platform which gives access to patient data held on the National Health Application and Infrastructure Services (NHAIS) systems, including cervical screening, breast screening, organ donor, blood donor and home oxygen.

Egton – provide support in the running of our IT equipment, from our self-arrive touch screens to the surgery’s main server.

Patient Partner – Our automated telephone line giving the option to call the surgery ‘around the clock’ to book, cancel, check and change appointments.

Access to personal information

You have a right under the General Data Protection Regulations 2018 to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. In order to request this, you need to do the following:

  • Your request must be made in writing to the GP – for information from the hospital you should write direct to them
  • There may be a charge to have a printed copy of the information held about you if the request is deemed to be excessive in nature
  • 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

GDPR & Safeguarding

The General Data Protection Regulation and the Data Protection Act 2018 states that, as a public authority, we have the authority to process(share) personal data in the exercise of our official duties without seeking parental consent.

The “public task basis” as described in the legislation allows authorities to use data when they can demonstrate that the processing is to perform tasks that are set by national law.  This means parental consent is not necessary for the obtaining and sharing of information between agencies when that information is for child protection or safeguarding purposes or for an assessment of a child or children’s needs.

The information that is shared and obtained by the local authority will be key in the decision regarding the need to undertake an assessment.  The outcome of the assessment could be an offer of support to families and children under Section 17 of the Children Act 1989, parents have the right to decline an offer of help or support following an assessment We are obliged to inform parents of how their information has been collected and used and this will be available on request.

Objections / Complaints

Should you have any concerns about how your information is managed at the GP, please contact the GP Practice Manager. If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) via their website (www.ico.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.

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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.

Notification

The General Data Protection Regulations 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

This information is publicly available on the Information Commissioners Office website www.ico.org.uk

The practice is registered with the Information Commissioners Office (ICO).

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential is: GP Direct

Complaints

Should you have any concerns about how your information is managed by the Practice please contact the Practice Manager at the following address:

GP Direct
3-7 Welbeck Road
Harrow
Middx
HA2 0RQ

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