Fair Processing Notice under the Data Protection Act 2018 - How we use your personal information
This fair processing notice explains why the GP surgery 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 solutions to ensure that your information is kept confidential and secure. Records which this surgery hold about you may include the following information:
- Details about you, such as your address, carer, legal representative, emergency contact details, next of kin
- Any contact the surgery has had with you, such as appointments, telephone, eConsults, emails submitted by you, 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 surgery 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 – if this information needs to be identifiable, the surgery will always gain your explicit consent before releasing the information for this purpose.
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. Any visitor to the premises who will or could be exposed to your identifiable information will sign a confidentiality agreement.
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.
This page was last updated: Tuesday 29th June 2021
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 surgery. A risk score is then arrived at through an analysis of your anonymised 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.
The surgery 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 by pharmacists and Technicians employed by West Hampshire Clinical Commissioning Group and / or ESP Network Ltd. They are bound by the same confidentiality rules as our staff are.
The surgery works alongside ESP Network (Eastleigh Southern Parishes Network Ltd.) who employs the Care Navigators (CNs). These CNs are non-clinical staff whose role is to prevent hospital admissions for vulnerable elderly patients. They have access to patient's records via their own clinical system when the patient has explicitly consented to this.
The Hub is an organisation that operates across the five ESP Network practices. It offers evening, weekend and bank holiday appointments with a GP, Nurse or Musculoskeletal Practitioner. It operates from Botley Medical Centre. By booking an appointment with The Hub, patients are explicitly consenting to The Hub staff accessing their medical records to provide medical care.
Who are our partner organisations?
- NHS Trusts / Foundation Trusts
- 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
- Other ‘data processors’ which you will be informed of
You will be informed who your data will be shared with and in some cases asked for explicit consent for this to 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.
Who are our partner software suppliers / businesses?
We use a number of pieces of software and organisations outside of the NHS to facilitate your healthcare and enable our staff to contact you. These are as follows:
|Name||Description||Can employees of the organisation access patient information?||GDPR Statement|
|Healthcare Computing||The surgery’s primary general IT support provider||Healthcare Computing support staff are able to remotely dial in with the consent of our staff for problem solving.||Healthcare Computing GDPR Policy|
|EMIS||Clinical system that holds patient demographic and medical information||The servers and the connection to the surgery are encrypted, so EMIS staff are not able to access patient information in this way. EMIS support staff are able to dial in remotely with the consent of our staff for problem solving.||EMIS Group Privacy Notice|
|eConsult||Provides the platform for online consultations requests||Patient data is encrypted, consultation information is stored in pseudonymised form on eConsult's servers.||eConsult Privacy Notices|
|accuRx||SMS system between the surgery and patients||
Patient’s EMIS (clinical system) numbers are uploaded to the accuRx website. This website has an encrypted link to the patient database which is interrogated for the patient’s name and mobile number. accuRx employees would only have access to this identifiable information when troubleshooting – they will sometimes dial into a Bursledon Surgery staff member’s PC with the consent of the member of staff to fix a problem.
accuRx also provides our COVID-19 vaccine appointment system.
|Royal Mail||Royal Mail is an external mailing agency which we use to send individual letters||
All letters / parcels are sealed in a labeled envelope.
|CFH Docmail||Docmail is an external printing and mailing agency which we use to send individual and larger batches of letters||Docmail staff can dial in remotely with the consent of our staff for problem solving.||CFH Docmail Terms of Service|
|Health Intelligence||Manage recall and screening of diabetic patients for diabetic retinopathy||The Diabetic Eye Screening Programme is operated by Health Intelligence (commissioned by NHS England). This supports invitation for eye screening and ongoing care. This data may be shared with any Hospital Eye Services a patient is under the care of to support further treatment and with other healthcare professionals involved in patient care.||HIOW DESP Privacy Notice|
|Numed||Numed provides software and support for our ECG machine||Numed support staff can remotely dial in with the consent of our staff for problem solving.||Numed GDPR Statement of Compliance|
|Jayex||Jayex provide our patient check-in screen and caller display board located in the reception area||Jayex support staff can remotely dial in with the consent of our staff for problem solving.||Jayex Privacy Notice|
|MDU / MPS / MDDUS / NHS Resolution||Indemnity organisations||We will sometimes send by email or discuss by phone identifiable information when the organisation is supporting a GP in a patient complaint or litigation. Information will be redacted where possible.|
|Tree View Designs||Website provider||Any patient data that is submitted via this website is encrypted and is stored on Tree View Designs' servers.||Tree View Designs Privacy & Transparency Notice|
Access to personal information / Subject Access Requests
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 should be made in writing to the GP surgery, this can be made by email or letter (note for information from the hospital you should write directly to them)
- We will initially offer you online access to your Detailed Coded Record. This contains your electronic medical record and summarised paper record. It does not contain any letters from the hospitals or other attachments on your record. The advantage of applying for access to this record is that it updates as your medical record updates, so you will always have the most current information.
- If the Detailed Coded Record is not adequate for your needs, we will email you a copy of your medical record. If you are not able to receive an email containing your medical record, you will print a copy for yourself. There may be a charge to have a printed copy of the information held about you if the administrative burden of photocopying and printing is excessive.
- We are required to respond to you within a month
- 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
- If you are collecting this request in person, you may need to show photographic ID in order to obtain your request
Objections / Complaints
Should you have any concerns about how your information is managed at the GP, please contact the Surgery Manager via the contact us page or via a letter for the attention of the Surgery Manager.
If you are still unhappy following a review by the GP surgery, you can then complain to the Information Commissioners Office (ICO) www.ico.gov.uk, email@example.com, telephone: 0303 123 1113 (local rate).
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 surgery.
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.
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 surgery 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 Bursledon Surgery.
If you are still unhappy following a review by the surgery you can then complain to the Information Commissioners Office (ICO). www.ico.org.uk, firstname.lastname@example.org, telephone: 0303 123 1113 (local rate).
Who is the Data Protection Officer?
As a public authority, we have to appoint a Data Protection Officer (DPO). The DPO for this surgery is detailed below. They assist us in monitoring internal compliance, provides advice regarding Data Protection Impact Assessments (DPIAs), and helps us demonstrate compliance with an enhanced focus on accountability.
Name: Judith Jordan
E-Mail Address: email@example.com