Practice Policies & Patient Information
Chaperones Notice
Complaints
In the first instance, complaints should be made to the Practice Manager. In more serious cases, you may be requested to put the complaint in writing however if you are unable or prefer not to do this yourself or if you feel that you need some help with this then please discuss this with the Practice Manager. As a patient, you have the right to be treated in a courteous and non- discriminatory manner. Your requests will be dealt with efficiently.
If you feel that you cannot approach the practice you can contact by post:
NHS England
PO Box 16738
Redditch
B97 9PT
Email: england.contactus@nhs.net
Telephone: 0300 311 22 33
If a complaint remains dissatisfied at the end of the Practice complaints process you then have the right to request an independent review. The complainant must do this through the Health Authority by writing to the above address within 28 days requesting an independent review. Ultimately complaints have the right to refer complaints to the NHS Commissioner Ombudsman.
Post:
The Parliamentary and Health Service Ombudsman
Millbank Tower
Millbank
London
SW1P 4QP Email: phso.enquiries@ombudsman.org.uk
Telephone: 0345 015 4033
Compliments and Suggestions
There is a comments book situated in the reception area for any comments or suggestions. This is audited regularly by the practice manager. |
Confidentiality
If you wish to speak to the receptionist or other team member in confidence please ask at reception and you will be taken to a confidential booth.
COVID-19 Privacy Notice
(This Privacy Notice is to run alongside our standard Practice Privacy Notice)
Due to the unprecedented challenges that the NHS and we, [Practice Name] face due to the worldwide COVID-19 pandemic, there is a greater need for public bodies to require additional collection and sharing of personal data to protect against serious threats to public health.
In order to look after your healthcare needs in the most efficient way we, [PRACTICE NAME] may therefore need to share your personal information, including medical records, with staff from other GP Practices including Practices within our Primary Care Network, as well as other health organisations (i.e. Clinical Commissioning Groups, Commissioning Support Units, Local authorities etc.) and bodies engaged in disease surveillance for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
The Secretary of State has served notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) to require organisations to process confidential patient information in the manner set out below for purposes set out in Regulation 3(1) of COPI.
Purpose of this Notice
The purpose of this Notice is to require organisations such as [PRACTICE NAME] to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI. This Notice is necessary to require organisations such as [PRACTICE NAME] to lawfully and efficiently process confidential patient information as set out in Regulation 3(2) of COPI for purposes defined in regulation 3(1), for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
Requirement to Process Confidential Patient Information
The Secretary of State has served notice to recipients under Regulation 3(4) that requires [PRACTICE NAME] to process confidential patient information, including disseminating to a person or organisation permitted to process confidential patient information under Regulation 3(3) of COPI.
[PRACTICE NAME] is only required to process such confidential patient information:
- where the confidential patient information to be processed is required for a Covid-19 Purpose and will be processed solely for that Covid-19 Purpose in accordance with Regulation 7 of COPI
- from 20th March 2020 until 31 March 2021.
Covid-19 Purpose.
A Covid-19 Purpose includes but is not limited to the following:
- understanding Covid-19 and risks to public health, trends in Covid-19 and such risks, and controlling and preventing the spread of Covid-19 and such risks
- identifying and understanding information about patients or potential patients with or at risk of Covid-19, information about incidents of patient exposure to Covid-19 and the management of patients with or at risk of Covid-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from Covid-19
- understanding information about patient access to health services and adult social care services and the need for wider care of patients and vulnerable groups as a direct or indirect result of Covid-19 and the availability and capacity of those services or that care
- monitoring and managing the response to Covid-19 by health and social care bodies and the Government including providing information to the public about Covid-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services
- delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with Covid-19, including the provision of information, fit notes and the provision of health care and adult social care services
- research and planning in relation to Covid-19.
Recording of processing
A record will be kept by [PRACTICE NAME] of all data processed under this Notice.
Sending Public Health Messages
Data protection and electronic communication laws will not stop [PRACTICE NAME] from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.
Digital Consultations
It may also be necessary, where the latest technology allows [PRACTICE NAME]to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.
Research and Pandemic Planning
The Secretary of State has directed NHS Digital to collect, process and analyse data in connection with COVID-19 to support the Secretary of State’s response to COVID-19 and support various COVID-19 purposes set out in the COVID-19 Public Health Directions 2020, 17 March 2020 (as amended) (COVID-19 Direction) and below. This enables NHS Digital to collect data and analyse and link the data for COVID-19 purposes with other data held by NHS Digital.
The purpose of the data collection is also to respond to the intense demand for General Practice data to be shared in support of vital planning and research for COVID-19 purposes, including under the general legal notice issued by the Secretary of State under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI).
NHS Digital has therefore been requested by the joint co-chairs of the Joint GP IT Committee (JGPITC) (the BMA and RCGP) to provide a tactical solution during the period of the COVID-19 pandemic to meet this demand and to relieve the growing burden and responsibility on General Practices. On 15 April 2020 the BMA and RCGP therefore gave their support via JGPITC to NHS Digital’s proposal to use the General Practice Extraction Service (GPES) to deliver a data collection from General Practices, at scale and pace, as a tactical solution to support the COVID-19 response in the pandemic emergency period.
It is a requirement of the JGPITC that all requests by organisations to access and use this data will need to be made via the NHSX SPOC COVID-19 request process, that will triage and prioritise these requests and refer appropriate requests on to the NHS Digital Data Access Request Service (DARS). NHS Digital will consult with representatives of the BMA and the RCGP on all requests for access to the data. An outline of the process for this agreed with the BMA and the RCGP is published here. Requests by organisations to access record level data from this collection will also be subject to Independent Group Advising on the Release of Data (IGARD) consideration. Data applicants will need to demonstrate they have a lawful basis to access the data for COVID-19 purposes.
Benefits of this sharing
Organisations, including the Government, health and social care organisations and researchers need access to this vital data for a range of COVID-19 purposes, to help plan, monitor and manage the national response to the COVID-19 pandemic, which will help save lives. COVID-19 purposes for which this data may be analysed and used may include:
- understanding COVID-19 and risks to public health, trends in COVID-19 and such risks, and controlling and preventing the spread of COVID-19 and such risks
- identifying and understanding information about patients or potential patients with, or at risk of COVID-19, information about incidents of patient exposure to COVID-19 and the management of patients with or at risk of COVID-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID19
- understanding information about patient access to health services and adult social care services as a direct or indirect result of COVID-19, and the availability and capacity of those services • monitoring and managing the response to COVID-19 by health and social care bodies and the Government including providing information to the public about COVID-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services
- delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with COVID-19, including the provision of information, fit notes and the provision of health care and adult social care services; and
- research and planning in relation to COVID-19.
Data may be analysed and linked to other data held by NHS Digital or held by other organisations to which access to the data is granted for COVID-19 purposes, through the process described above.
Data will be collected nationally from all GP Practices by NHS Digital every fortnight. All requests to access this data will be triaged through the NHSX SPOC COVID-19 request process and assessed and fulfilled by NHS Digital through DARS. This will significantly reduce the burden on General Practice at a time when demand on resources is high, enabling General Practice to focus on delivering health care and support to patients. It will also reduce compliance burden and risk for General Practice associated with sharing data and complying with the terms of the general legal notice issued under COPI, which applies to General Practices.
Legal Basis for this collection
NHS Digital has been directed by the Secretary of State under section 254 of the 2012 Act under the COVID-19 Direction to establish and operate a system for the collection and analysis of the information specified for this service: GPES Data for Pandemic Planning and Research (COVID-19). A copy of the COVID-19 Direction is published here: https://digital.nhs.uk//about-nhs-digital/corporate-information-and-documents/directions-anddata-provision-notices/secretary-of-state-directions/covid-19-public-health-directions-2020.
Details of the information to be collected can be found on the NHS Digital website – Specification of this DPN. Type 1 objections will be upheld in collecting this data from General Practices and therefore the data for those patients who have registered a Type 1 objection with their GP will not be collected. The Type 1 objection prevents an individual’s personal identifiable confidential information from being shared outside of their GP Practice except when it is being used for the purposes of their direct care. The National Data Opt-Out will not apply to the collection of the data, as this is a collection which is required by law.
This information is required by NHS Digital under section 259(1)(a) of the 2012 Act to comply with the COVID-19 Direction. In line with section 259(5) of the 2012 Act, all organisations in England that are within the scope of this Notice, as identified below under Health and Social Care Bodies within the scope of the collection, must comply with the requirement and provide information to NHS Digital in the form, manner and for the period specified in this Notice. This Notice is issued in accordance with the procedure published as part of NHS Digital’s duty under section 259(8) of the 2012 Act.
In August 2020, the NHS announced that the seasonal national flu immunisation programme criteria for 2020 – 2021 will be expanded to include patients on the SPL. Therefore, to provide information that will support the identification of patients at moderate or high risk of complications from flu, a revision to the weekly extract of data has taken place. This, version three of the extract for the purpose of maintaining and updating the SPL, will continue until the expiry of the COVID-19 Direction. This is currently 31 March 2022 but will be reviewed in September 2020 and every six months thereafter. The frequency of the data collection may change in response to demand.
Data collection extracted on a weekly basis week commencing 13 April 2020
Revised weekly data collection. The first collection is due week commencing 28 September 220
All patients with defined long-term medical conditions which pose a COVID-19 risk, identified as clinically extremely vulnerable to that risk and/or on certain drug treatments as below:
All patients with defined long-term medical conditions which pose a COVID-19 risk, identified as clinically extremely vulnerable/potentially clinically vulnerable to that risk and/or on certain drug treatments as below:
Medical Conditions that provide information on clinically vulnerable patients
- Severe asthma and dust related lung disease with relevant treatment in the last 12 months (asthma treatment & prednisolone OR high dose cortiscosteroid safety card)
- COPD emphysema, and associated lung diseases with relevant treatment in the last 12 months (COPD drugs OR high dose high dose cortiscosteroid safety card
- Non-asthma and non-COPD respiratory disease
- Cancer(haem and others)
- Genetic, metabolic or autoimmune disease
- Immunosuppression drugs in the last 12 months
- Flu-like symptoms or respiratory tract infections from 1 November 2019
- Transplants with severe Immunosuppression drug treatment in the last 12 months
- Pregnant in last 9 months
Medical Conditions that provide information on clinically vulnerable patients
- Severe asthma and dust related lung disease with relevant treatment in the last 12 months (asthma treatment & prednisolone OR high dose cortiscosteroid safety card)
- COPD emphysema, and associated lung diseases with relevant treatment in the last 12 months (COPD drugs OR high dose high dose cortiscosteroid safety card
- Non-asthma and non-COPD respiratory disease
- Cancer(haem and others)
- Genetic, metabolic or autoimmune disease
- Immunosuppression drugs in the last 12 months
- Flu-like symptoms or respiratory tract infections from 1 November 2019
- Transplants with severe Immunosuppression drug treatment in the last 12 months
- Pregnant in last 9 months
No change
- Patients designated separately as at risk from COVID-19 using high/medium/low risk SNOWED CT Codes, for example
- Patients designated separately as at risk from COVID-19 using high/medium/low risk SNOWED CT Codes, for example
No change
Patients with a COVID-19 activity code
Patients with a COVID-19 activity code
No change
Clinically vulnerable patients (eligible for seasonal flu vaccination)
- Chronic Respiratory disease
- Unresolved asthma with recent asthma drug treatment (in the last 12 months) or has ever had an emergency hospital admission due to asthma
- Chronic heart disease
- Unresolved chronic kidney disease stage3,4 and 5
- Unresolved diabetes mellitus
- Unresolved immunosuppression diagnosis
- Immunosuppression procedure in the last 12 months
- Chronic Liver disease
- Chronic neurological disease
- Pregnant in the last 9 months (different cluster to clinically extremely vulnerable group)
- In patients aged 16 and over : BMI of 40 in the last 12 months
- In patients aged 16 and over : Latest BMI in the last 3 years was 40
- Learning disability (including Down’s)
- Has a “requires flu vaccination” code
- Identified as a healthcare worker in the last 12 months
- Household contact of an immunocompromised individual
Other Potentially clinically Vulnerable patients
- Unresolved hypertension
- Pulmonary hypertension
- Dementia
- Systemic lupus
- Discoid and non-systemic lupus
- Psoriasis
- Rheumatoid arthritis and associated disorders
Additional Data items for Patients from the above groups
- Latest ethnic category code (all groups)
- Earliest code indicating that the patient has died (all groups)
- Latest smoking status (all groups)
- Blood pressure from the last 2 years (all groups)
- In patients aged 16 and over: all BMI and weight in last 5 years plus height (all groups)
- IFCC-HbA1c in the last 2 years (for diabetic patients in the flu group only)
- Latest COPD resolved and admission codes (for COPD Patients in the clinically extreme vulnerable group only)
- ACE inhibitors, ARBs and non-steroidal anti-inflammatory drugs in the last 12 months (all groups)
- Latest asthma emergency admission codes (for asthma patients in flu group only)
- Asthma-related drug treatments in the last 12 months (for asthma patients in the flu group only)
The Secretary of State has directed NHS Digital to collect, process and analyse data in connection with COVID-19 to support the Secretary of State’s response to COVID-19 and support various COVID-19 purposes set out in the COVID-19 Public Health Directions 2020, 17 March 2020 (COVID-19 Direction) (as amended) (COVID-19) Direction) and below. This enables NHS Digital to collect data and analyse and link the data for COVID-19 purposes with other data held by NHS Digital. The rationale for changing the data extraction is that the initial data collection was based on an existing specification for flu vaccination eligibility. This data extraction was then refined in order to more accurately reflect the patients who are clinically extremely vulnerable to COVID-19 and also to minimise the data we are collecting. A further refinement of the data extraction has taken place leading to the inclusion of new data being extracted. This will provide information to inform vaccination programmes. This General Practice Extraction
Service (GPES) data will be extracted weekly and be used to assist in producing a weekly update of the SPL. The objective of this collection is on an ongoing basis to identify patients registered at General Practices who may be: • clinically extremely vulnerable if they contract COVID-19 • at moderate or high risk of complications from flu or COVID-19. The data collected will be analysed and linked with other data NHS Digital or other organisations hold to identify: • a list of clinically extremely vulnerable patients who will be advised to take shielding measures to protect themselves. Advice given to these patients has been published by Public Health England and is available here: https://www.gov.uk/government/publications/guidance-on-shielding-and-protectingextremely-vulnerable-persons-from-covid-19/guidance-on-shielding-and-protectingextremely-vulnerable-persons-from-covid-19#what-do-we-mean-by-extremelyvulnerable • a list of patients at moderate or high risk of complications from flu to inform the flu call/recall vaccination programme.
Further information on the flu programme can be found here: https://www.england.nhs.uk/wpcontent/uploads/2020/05/Letter_AnnualFlu_2020-21_20200805.pdf
The extract may also be used for future direct care purposes relating to the COVID-19 outbreak. The methodology NHS Digital has used to produce the SPL is explained in detail and is published on the NHS Digital SPL website page here:
https://digital.nhs.uk/coronavirus/shielded-patient-list Patients
added to the SPL will be contacted by post, email (and/or SMS message where this is necessary) by the NHS on behalf of the Chief Medical Officer, Chris Whitty, to:
• advise of the measures they can take to reduce their risk of contracting the virus and sign-post them to the Extremely Vulnerable Persons service operated by gov.uk at https://www.gov.uk/coronavirus-extremely-vulnerable
• offer a flu vaccination or to contact non-responders who remain unvaccinated (as per NHS England specifications for the service). The SPL will also be used to inform GPs of their individual patients on the SPL, by flagging those patient records on GP patient record systems. The SPL will be shared with a variety of other organisations involved in the care and support of those patients and for planning, commissioning and research purposes associated with COVID-19. Full details of those with whom information has been shared can be found on the NHS Digital SPL website here:
https://digital.nhs.uk/coronavirus/shielded-patient-list/distribution.
Requests by organisations to access record level data from this collection will be subject to Independent Group Advising on the Release of Data (IGARD) consideration. Data applicants will need to demonstrate they have a lawful basis to access the data for COVID-19 purposes.
Benefits of the collection
Organisations, including Government, health and social care organisations need to access this vital data for a range of COVID-19 purposes, to help plan, monitor and manage the national response to the COVID-19 pandemic, which will help save lives. COVID-19 purposes for which this data may be analysed and used may include: • understanding COVID-19 and risks to public health, trends in COVID-19 and such risks, and controlling and preventing the spread of COVID-19 and such risks • identifying and understanding information about patients or potential patients with, or at risk of COVID-19, information about incidents of patient exposure to COVID-19 and the management of patients with or at risk of COVID-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID19. Data will be analysed and linked to other data held by NHS Digital or held by other organisations to which access to the data is granted for COVID-19 purposes, through the process described above. Data will be collected nationally from all General Practices by NHS Digital every week. All requests to access this data will be through Data Access Request Service (DARS). This will significantly reduce the burden on General Practice at a time when demand on resources is high, enabling General Practice to focus on delivering health care and support to patients. It will also reduce compliance burden and risk for General Practice associated with sharing data and complying with the terms of the general legal notice issued under the National Health Service (Control of Patient Information Regulations) 2002 (COPI), which applies to General Practices Patients facing the greatest risk if they contract COVID-19 and/or are in the moderate to high risk of complications from flu:
• will be identified and known to health organisations
• will have a greater awareness of the recommended preventative shielding measures
• will be able to follow clear advice
• will be able to ask for help and support, including social care support and essential food supplies, through the Extremely Vulnerable Persons service operated by gov.uk.
It will enable the SPL to be updated weekly to identify new patients and changes to patients on the List and will enable support provisions to be more dynamic and responsive to both social and clinical need.
It will also enable vital planning, commissioning, and research to be carried out for COVID-19 purposes. If patients facing the greatest risk follow advice, it is hoped that this will contribute to the delay and mitigation of the spread of COVID-19 and save lives.
Visitors to The Practice
We have an obligation to protect our staff and employees’ health, so it is reasonable for staff at [PRACTICE NAME]to ask any visitors to our practice to tell us if they have visited a particular country, or are experiencing COVID-19 symptoms. This must only be in pre-approved circumstances and we would also ask all patients to consider government advice on the NHS 111 website and not attend the practice.
Where it is necessary for us to collect information and specific health data about visitors to our practice, we will not collect more information than we need, and we will ensure that any information collected is treated with the appropriate safeguards.
Review and Expiry of this Notice
This Notice will be reviewed on or before 31 March 2021 and may be extended by The Secretary of State. If no further notice is sent to [PRACTICE NAME] by The Secretary of State this Notice will expire on 31 March 2021.
Data Sharing
Data Sharing & Risk Stratification in North Staffordshire
We are introducing a system called Risk Stratification within North Staffordshire GP practices. This system uses confidential information from your medical record to identify patients who may need more care and support. We particularly want to be able to identify people at high risk of emergency hospital admission so we can offer more care to help improve their health and try to avoid a hospital admission. Identifying each person’s risk of future admission is called Risk Stratification.
The information from your record along with your postcode and NHS number will be sent to a secure system where it can be linked with information from hospitals if you have been in hospital recently. Your personal results can only be seen by those caring for you in your own GP Practice. Anonymised information which does not identify you can also be used to help those planning NHS Services in Staffordshire – but they will not be able to link this information to you as an individual in any way.
Please note that this local use of information for Risk Stratification is NOT the same as the Summary Care Record which is a national shared record, neither is it the same as the local sharing of records in the Local Health Record Network.
YOU HAVE A CHOICE
If you are happy for your information to be used in this way you do not have to anything.
If you DO NOT want your records to be used for Risk Stratification locally please speak to a member of the reception staff who will assist you.
Please click here to see Private Code of practice
Freedom Of Information Act
Dr Borse & Partner
Freedom of Information Publication Scheme
Welcome to Dr Borse & Partner Publication Scheme. This is a guide to the General Practitioners within the Practice Publication Scheme as required by the Freedom of Information Act 2000.
Introduction
This Publication Scheme is a complete guide to the information routinely made available to the public by Dr Borse Surgery. It is a description of the information about our General Practitioners and the Practice, which we make publicly available. It will be reviewed at regular intervals and we will monitor its effectiveness.
How much does it cost?
The publications are all free unless otherwise indicated.
How is the information made available?
The information within each class is available in hard copy. To obtain a copy your request should be directed to the Practice Manager.
Your rights to information
- Ø In addition to accessing the information identified in the Publication Scheme, you are entitled to request information about Dr Borse Surgery under the NHS Openness Code 1995.
- Ø The Freedom of Information Act 2000 recognises that members of the public have the right to know how public services are organised and run, and how much they cost and how the decisions are made.
- Ø From 1st January 2005 it will oblige the General Practice to respond to requests about information that it holds, and is recorded in any format and it will create a right of access to that information. These rights are subject to some exemptions, which have to be taken into consideration before deciding what information it can release.
- Ø New environmental information regulations may be introduced as early as 2003. These will enable similar access to environmental information as under the Freedom of Information Act 2000.
- Ø Under the Data Protection Act 1998, you are also entitled to access your clinical records or any other personal information held about you and you can contact the Practice Manager to do this.
Feedback
If you have any comments about the operation of the Publications Scheme, or how we have dealt with your request for information from the Scheme, please write to:
CLASSES OF INFORMATION
All information at Surgery Name is held, retained and destroyed in accordance with NHS guidelines. Our commitment to publish information excludes any information, which can be legitimately withheld under the exemptions set out in the NHS Openness Code or Freedom of Information Act 2000. Where individual Classes are subject to exemptions, the main reasons are e.g. the protection of commercial interests and personal information under the Data Protection Act 1998. This applies to all Classes within the Publication Scheme. The information on this Scheme is grouped into the following categories:
1. Who we are
Surgery Name operates as part of NHS Stoke-on-Trent. The practice adheres to a Personal Medical Services contract with NHS Stoke-on-Trent.
The practice aims to follow National Institute for Clinical Excellence and National Service Frameworks Guidelines. The NHS is a very large part of the public sector. A full list of local General Practices is available from NHS Stoke on Trent. Surgery Name provides Personal Medical Services for the geographical area of Hanley and the surrounding area.
The Doctor
Practice Nurses
Practice Manager
2. Our Services
The range of services we provide under contract to the NHS includes: Child Health Surveillance; contraceptive services; maternity medical services (including midwife clinics); baby clinics; disease management clinics (asthma, diabetes, CHD etc); smoking cessation; travel advice and vaccinations; cervical cytology; and immunisations.
A language line service is available for any patients who do not speak English.
The Practice is open from
Outside the hours
cover is provided by the North Staffs Urgent Care Services, Basford.
This service is to be used in the event of an emergency and is not to be used by patients unable to attend normal surgery hours.
The practice is fully computerised and your medical records are held on computer. We also need to share information with the Health Authority, hospitals and other NHS bodies to provide for your care. We feel that it is essential for the care of our patients and to help improve NHS services.
Under the Data Protection Act 1998 you have the right to see your records and have the right to have inaccurate data corrected. There is a charge for this.
The Doctor, Nurse and attached staff use the computer to record clinical data.
The practice staff use the computer to prepare prescriptions, arrange appointments and recall patients. The staff are required to treat patient information in the strictest confidence and have been given training in their responsibilities under the Data Protection Act 1998.
People who work with the practice, but do not directly provide your care may read patient records. The people are properly trained and have the same duty of confidentiality as the practice staff.
To provide the best possible patient care the practice may at times need to share information with other agencies (for example when referring to a hospital)
Patients have the right to object to their medical records being used like this. Should a patient inform us of this we will enter this into their records. Such requests will be respected except where disclosure is essential to protect the patient or someone else from risk or serious harm.
In any situation where the practice is being asked to release personal information about a patient (when the patient’s identity is part of the data) the practice will only do this with the patients consent.
There are strict security measures in place at the practice, the Health Authority and other NHS bodies to keep your records confidential. Any research project that is undertaken at the practice has to be approved by the Local Ethics Research Committee.
3. Financial and funding information
Dr Borse surgery has a contract with NHS Stoke-on-Trent to provide services to our patients. We have an annual budget for providing these services, and an additional prescribing budget.
The amounts for the above budgets are available
4. Regular publications and information for the public
The practice provides a practice information leaflet which gives details of the services we provide for patients. We also provide a newsletter with up to date information on services provided, along with any changes to the practice.
Leaflets and newsletters are available at reception.Results of practice surveys can be found on our website
5. Complaints
The practice always tries to provide the best service possible to patients, but there may unfortunately be times when patients feel that this has not happened. The practice has an in-house complaints procedure to deal with complaints and grievances. The practice liaises closely with NHS Stoke-on-Trent when dealing with any complaints. We encourage patients to use this procedure to allow us to look into, and if necessary, correct any problems that have be been identified or mistakes that have been made. The practice respects its duty of confidence to patients and a patient’s consent is necessary if a complaint is made by a third party, and not the patient in person.
If a patient wishes to complain we request that they speak to, or write to our Practice Manager, or complete a complaints form. Full details are taken regarding the complaint and a decision will be made on how best to undertake an investigation into that complaint. The practice feels that it is important to deal with complaints swiftly, and patients will be offered an appointment to discuss the details, within 10 working days.
A copy of the practice in-house complaints procedure can be found in Appendix 1
6. Our policies and procedures
The practice has some in-house policies and procedures in place to ensure the safety and well being of both patients and staff.
7. This Publication Scheme
In this class we will publish any changes we make to the Publication Scheme, the criteria on which our information management policies are made and a referral point for all enquiries regarding information management generally in the practice We will also publish any proposed changes or additions to publications already available.
Appendix 1
In-House Practice Complaints Procedure
Patient Information Leaflet
If you have a complaint or concern about the service you have received from the doctors or any of the staff working in this practice, please let us know. We operate an in-house complaints procedure where we liaise closely with NHS Stoke-on-Trent, as part of the NHS system for dealing with complaints. Our complaints system meets national criteria.
How to Complain
We hope that most problems can be sorted out quickly and easily, often at the time that they arise and with the person concerned. If your problem cannot be sorted out in this way and you wish to make a complaint, we would like you to let us know as soon as possible, ideally within a few days or at most a few weeks, this will then enable us to establish what happened more easily. If this is not possible, please let us have details of you complaint:
- Within 6 months of the incident that caused the problem; or
- Within 6 months of discovering that you have a problem, provided this is within 12 months of the incident.
Complaints, in the first instance, should be addressed to the Practice Manager. Alternatively, you may ask for an appointment with the Practice Manager in order to discuss your concerns. He/ She will explain the complaints procedure to you and will make sure that your concerns are dealt with promptly. It would be a great help if you are as specific as possible about your complaint.
How We Will Deal With Your Complaint
The practice will acknowledge your complaint within 2 working days and aim to have looked into it within 10 working days of the date when you raised it with us. We will then be in the position to offer you a full explanation, or a meeting with the people involved. When we look into your complaint, we shall aim to:
- Find out what happened and what went wrong
- Make it possible for you to discuss the problem with those concerned, if you would like this
- Make sure that you receive an apology, where this is appropriate
- Identify what we can do to make sure the problem doesn’t arise again.
Complaining on Behalf of Someone Else
Please note that we keep strictly to the rules of medical confidentiality. If you are complaining on behalf of someone else, we have to know that you have their permission to do so. A note signed by the person concerned will be needed, unless they are incapable (because of illness) of providing this.
Complaining to your PCT
Our In-House complaints procedure does not affect your right to approach your local PCT which is NHS Stoke-on-Trent. If you feel you cannot raise your complaint with us or you are dissatisfied with the result of our investigation.
Please contact:
Complaints Department
4th Floor London House
Hide Street
Stoke on Trent
ST4 1NF
Tel: 01782 401055
General Data Protection Regulation
All personal data including patient information relating to living individuals that are held in either electronic or manual systems are subject to this act. This practice is registered with the Data Protection Registrar. |
GP Earnings
All GP practices are required to declare the mean earnings (e.g. average pay) for GPs working to deliver NHS services to patients at each practice.
The average pay for GPs who worked at this practice in the last financial year was £106,246 before tax and National Insurance. This is for 2 full time GPs, 1 part time GP and 1 locum GP who worked in the practice for more than 6 months.
GPDPR
The current NHS Digital (NHSD) extract of GP data for Research purposes (known as the GPDPR) has been delayed due to NHSD wishing to review the way in which this data will be collected, to conduct more public involvement and information about the plans and change the way in which patients can opt out of the extract of their GP data.
Currently the only way to opt out is to complete a Type 1 opt out form and return this to the practice by the 1st September. However, this extract will not be taken until the NHSD have changed the way it will take the data and respect the patient’s choice for using their data. NHSD are introducing the following changes to the opt out process which will mean that patients will be able to change their opt-out status at any time::-
- Patients do not need to register a Type 1 opt-out by 1st September to ensure their GP data will not be uploaded.
- NHS Digital will create the technical means to allow GP data that has previously been uploaded to the system via the GPDPR collection to be deleted when someone registers a Type 1 opt-out.
- The plan to retire Type 1 opt-outs will be deferred for at least 12 months while we get the new arrangements up and running and will not be implemented without consultation with the RCGP, the BMA and the National Data Guardian.
This means that you can opt out at any time in the future and NHSD will delete data that they already have taken for research purposes, the deadline of the 01/09/2020 has been delayed until a new system of opt out is developed. Hopefully, this will be a simple centralised approach via the NHS app or NHS website to avoid paper form and administration work for your GP.
We will update you when we know more about the NHSD plans to change how you can control who has access to your data.
Important Information regarding your medical records
Click here to view Your records are safe with us.
Click here to view our poster.
Click here to view our leaflet.
Click here to view our opt out form.
Click here to view “Your Data Matters to the NHS” leaflet
Please note all patients have a named allocated GP and you can contact the surgery to find out who your specific GP is.
Patient Access
What is Patient Access?
With Patient Access, you can now view, book and cancel appointments at your local GP surgery from home, work or on the move — wherever you can connect to the internet. What is more, because Patient Access is a 24 hour online service you can do this in your own time, day or night.
Plus, Patient Access is not just for booking GP appointments, you can also:
- Order repeat prescriptions.
- Change your address details.
- Send secure messages to your practice.
- View your medical record securely online
Please note: your local practice may not offer every Patient Access feature. Ask at your surgery to find out which are available to you.
How do I register?
If your practice offers Patient Access, they will provide you with an access code. Once you have the access code, you can register here.
Is my information secure?
All information that is sent to your surgery via Patient Access is secure. Your personal details are encrypted and protected using the highest standard internet security, so it cannot be intercepted. Only you and your GP surgery are able to see this information.
Click here to view Statement of Intent Practice Online Services
Patient Records
How we use your Records:
• To Provide a good basis for all health decisions made by you and care professionals
• Allow you to work with those providing care
• Make sure your care is safe and effective, and
• Work effectively with others providing you with care
Others may also need to use records about you to:
• check the quality of care (such as clinical audit)
• protect the health of the general public
• keep track of NHS spending
• manage the health service
• help investigate any concerns or complaints you or your family have about your health care
• teach health workers and other healthcare professionals
• help with research
Information may be required for research, auditing and statistical purposes, but in these circumstances the information required will remain anonymous. If you do require any further information in relation to this, please ask to speak to the practice manager.
Patients Rights & Responsibilities
Your Patient Rights
You have the right to confidentiality under the Data Protection Act 1998 (DPA), the Human Rights Act 1998 and the common law duty of confidence (the Disability Discrimination and the Race Relations Acts may also apply).
• You also have the right to ask for a copy of all records about you (you may have to pay a fee)
• Your request must be made in writing to the organisation holding your information
• There may be a charge to have a printed copy of the information held about you
• We are required to respond to you within 21 days
• You will need to give adequate information (for example full name, address, date of birth NHS number etc.,)
• You will be required to provide id before any information is released to you.
If you think anything within your medical record is inaccurate or incorrect, please inform the organisation holding your information.
Your rights and responsibilities to your GP Practice
• Every UK resident has the right to be registered with a GP Practice.
• Your GP Practice is your gateway to all other health services.
• You can see a GP within 48 hours if you want to be seen that quickly.
• You can book appointments in advance so that the appointment is as convenient as possible for you.
• Your GP Practice may offer a telephone discussion with a GP or Nurse if that is convenient to you.
• You can have at least 10 minutes with your GP / Practice Nurse to fully discuss any health issues.
• Your GP Practice can offer you general health advice or advice / treatment in relation to smoking, diet, exercise, alcohol consumption, drug usage, etc. They are not just there for when you are ill.
• Use your NHS services wisely, if you have an appointment booked but then don’t need it or can’t make it, then please remember to contact the surgery and cancel it.
• Everyone will be treated with dignity and respect – patients and staff alike.
• If you change your address or telephone number, please inform your GP Practice so that they have accurate information if they need to contact you.
• You are free to change your GP practice and choose another so if you wish to change your GP practice (for whatever reason) then you can –
• Just turn up at a practice and if you live within their geographical boundary you will be able to register and join the practice
• You will be offered an initial appointment with the Nurse or GP.
• The NHS Constitution brings together the principles, values, rights and responsibilities that underpin the NHS. For patients and the public this means clarity about:
• What they have a right to expect from the NHS
• What to do if they do not get what they expect
• The responsibilities they have for making the NHS work effectively
The NHS Constitution can be found at www.dh.gov.uk/nhsconstitution
Privacy Policy
Fair Processing Notice (Privacy Notice)
Your Personal Information – what you need to know
Your information, what you need to know
This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.
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. These records help to provide you with the best possible healthcare and help us to protect your safety.
We collect and hold data for the purpose of 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 will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form
Our Commitment to Data Privacy and Confidentiality Issues
As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation. This includes the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.
Data we collect about you
Records which this GP Practice will hold or share about you will include the following:
- Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
- Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.
- Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
- Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place
- Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.
How we use your information
Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of 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 at Appendix A.
Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
- improving the quality and standards of care provided
- research into the development of new treatments
- preventing illness and diseases
- monitoring safety
- planning services
- Risk stratification
- Population Health Management
Safeguarding of children or vulnerable adults
If we have significant concerns or hear about an individual child or vulnerable adult being at risk of harm, we may share relevant information with other organisations, such as local authorities and the Police, involved in ensuring their safety.
Statutory disclosures
Sometimes we are duty bound by laws to disclose information to organisations such as the Care Quality Commission, the Driver and Vehicle Licencing Agency, the General Medical Council, Her Majesty’s Revenue and Customs and Counter Fraud services. In these circumstances we will always try to inform you before we are required to disclose and we only disclose the minimum information that the law requires us to do so.
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law or with consent.
Pseudonymised or anonymised data is generally used for research and planning so that you cannot be identified.
A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.
How long do we hold information for?
All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice.
Individuals Rights under GDPR
Under GDPR 2016 the Law provides the following rights for individuals. The NHS uphold these rights in a number of ways.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (not an absolute right) only applies in certain circumstances
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Your right to opt out of data sharing and processing
The NHS Constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’.
Type 1 Opt Out
This is an objection that prevents an individual’s personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If patients wish to apply a Type 1 Opt Out to their record they should make their wishes know to the practice manager.
National data opt-out
The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.
The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to National data opt out programme
To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.
On this web page you will:
- See what is meant by confidential patient information
- Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
- Find out more about the benefits of sharing data
- Understand more about who uses the data
- Find out how your data is protected
- Be able to access the system to view, set or change your opt-out setting
- Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
- See the situations where the opt-out will not apply
Right of Access to your information (Subject Access Request)
Under Data Protection Legislation everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access and you may find information has been redacted or removed for the following reasons;
- Does not cause harm to the patient
- That legal confidentiality obligations for the non-disclosure of third-party information are adhered to
Patients do not need to give a reason to see their data. And requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require.
Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the extra copies.
Patients will need to provide proof of identity to receive this information. We will not share information relating to you with other individuals without your explicit instruction or without sight of a legal document.
Patients may also request to have online access to their data, they may do this via the NHS APP.
Change of Detail
It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.
Mobile telephone number
If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile.
Email address
Where you have provided us with your email address, with your consent we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email please let us know.
Notification
Data Protection Legislation 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: http://ico.org.uk/what_we_cover/register_of_data_controllers
Any changes to this notice will be published on our website and in a prominent area at the Practice.
Data Protection Officer
Should you have any data protection questions or concerns, please contact our Data Protection Officer mlcsu.dpo@nhs.net
01782 916875
What is the right to know?
The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However you can request this under a right of access request – see section above ‘Access to your information’.
Right to Complain
If you have concerns or are unhappy about any of our services, please contact the Practice Manager.
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
Phone: 0303 123 1113 Website: https://ico.org.uk/global/contact-us
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 Data Protection Legislation.
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 programs 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
Appendix A – The Practice will share your information with these organisations where there is a legal basis to do so.
Activity | Rationale |
Commissioning and contractural purposes
Invoice Validation Planning Quality and Performance |
Purpose – Anonymous data is used by the ICB for planning, performance and commissioning purposes, as directed in the practices contract, to provide services as a public authority.
Legal Basis – UK GDPR 6 1(b) Contractual obligation as set out in the Health and Social Care Act for Quality and Safety 2015
Processor – Home – Staffordshire and Stoke-on-Trent ICB |
Summary Care Record
Including additional information |
Purpose –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.
Legal Basis – Direct Care under UK GDPR :
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine The relevant COPI notice states that its purpose: “…is to require organisations to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI.” Full details of the Summary Care Record supplementary privacy notice can be found here Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that by opting out of having your information shared with the Summary Care Record could result in a delay to care that may be required in an emergency. Processor – NHS England and NHS Digital |
Research | Purpose – We may share anonymous patient information with research companies for the purpose of exploring new ways of providing healthcare and treatment for patients with certain conditions. This data will not be used for any other purpose.
Where personal confidential data is shared your consent will need to be sought.
Where you have opted out of having your identifiable information shared for this Planning or Research your information will not be shared.
Legal Basis – consent is not required to share anonymous data that does not identify a patient.
Where identifiable data is required for research, patient consent will be needed, unless there is a legitimate reason under law to do so or there is support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales
Processor – not applicable |
Individual Funding Requests | Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our contracts.
Legal Basis – The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time
Data processor – IFR Panel ifrteam@nhs.net
|
Safeguarding Adults | Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns.
Legal Basis – Because of public Interest issues, e.g. to protect the safety and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.
Data Processor – Adult Social Care Home (ssaspb.org.uk) |
Safeguarding Children | Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns.
Legal Basis – Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.
DataProcessor ChildProtectionTeam eds.team.manager@staffordshire.gov.uk |
Risk Stratification – Preventative Care | Purpose – ‘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.
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.
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data
Legal Basis GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2020 NHS England Risk Stratification which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.
|
Public Health
Screening programmes (identifiable) Notifiable disease information (identifiable) Smoking cessation (anonymous) Sexual health (anonymous)
|
Purpose – Personal identifiable and anonymous data is shared.
The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme. More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes [Or insert relevant link] or speak to the practice Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Data Processors – Public Health England
|
Direct Care
NHS Trusts Other Care Providers |
Purpose – Personal information is shared with other secondary care trusts in order to provide you with direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.
Legal Basis – The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions as stated below: In some cases patients may be required to consent to having their record opened by the third party provider before patients information is accessed. Where there is an overriding need to access the GP record in order to provide patients with life saving care, their consent will not be required.
Processors – www.uhnm.nhs.uk |
Care Quality Commission | Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.
More detail on how they ensure compliance with data protection law (including GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy-statement
Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below
Processors – Care Quality Commission
|
Population Health Management | Purpose – Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data in order to:
• Understand the health and care needs of the care system’s population, including health inequalities • Provide support to where it will have the most impact • Identify early actions to keep people well, not only focusing on people in direct contact with services, but looking to join up care across different partners. (NB this links to the Risk Stratification activity identified above)
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data. NB only organisations that provide your care will see your identifiable data.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
|
Payments, Invoice validation | Purpose – Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QUOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.
Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below
Data Processors – NHS England, ICB, Public Health
|
Patient Record data base | Purpose – Your medical record will be shared, in order that a data base can be maintained and managed in a secure way
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – EMIS and Docman |
Medical reports
Subject Access Requests
|
Purpose – Your medical record may be shared in order that solicitors instructed on your behalf or insurance companies seeking a medical report can have a copy to your medical history for a specific purpose.
Legal Basis – Your explicit consent will be required before a GP can share your record for this purpose.
Processor – iGPR |
Medicines Optimisation
|
Purpose – Your anonymous aggregated information will be shared in order to optimise medication. This will enable your GP to provide a more efficient medication regime for your personal care. Some of the anonymous information may be used nationally to drive wider understanding of the medication is used. No patients will be able to identified from the data shared.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
|
Medicines Management Team | Purpose – your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes can be implemented.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
|
Prescription Ordering Direct (POD) | Purpose: The NHS Prescription Ordering Direct (POD) service is provided on behalf of your GP practice who have launched the service as an alternative way for people to order their prescriptions. The service hopes to reduce prescription waste by helping to ensure you order the medication you need when you need it. When you contact POD telephone number you will be asked by a dedicated and fully trained prescription co-ordinator if you consent to your medical record being accessed to process your prescription request. You can also discuss your medication requirements and can be alerted if a medication review is needed.
Legal Basis – Your consent will be required to share your record for this purpose
|
PCN | Purpose – Your medical record will be shared with the other five practices in the PCN in order that they can provide direct care services to the patient population.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – Meir PCN |
Social Prescribers | Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their social care needs.
Only those patients who wish to be party to this service will have their data shared.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller” And Article 9(2)(h) Health data as stated below
Processor – Meir PCN |
Subject Access Requests | Purpose – Personal information will be shared with the person or their representative at their request
Legal Basis – Contractual agreement with the patient – and consented
Processor – Patients and or their representatives – e.g. family members, solicitors, insurance companies |
Medical Reports | Purpose – Personal information will be shared with Insurance companies, or potential or active employers at the patients request
Legal Basis – Consented
Processor – Patients and or their representatives – e.g. Insurance companies, RAF, Navy |
Police | Purpose – Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared no consent will be required.
The Police will require the correct documentation in order to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime.
In some cases consent may be required.
Legal Basis – UK GDPR – Article 6 1 (f) legitimate interest 6 1 (c) Legal Obligation. Article 9 2 (f) requests for legal reasons
Processor – Police Constabulary |
Coroners | Purpose – Personal information relating to a patient may be shared with the coroner upon request.
Legal Basis – UK GDPR Article 6 1 (c) Legal Obligation 9 2 (h) Health data
Processor – The Coroner |
Private healthcare providers | Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patients’ request. Consent from the patient will be required to share data with Private Providers.
Legal Basis – Consented and under contract between the patient and the provider
Provider – Any private provider at the patients request |
Texting Service
|
Purpose – Personal identifiable information shared with the texting service in order that text messages including appointment reminders, campaign messages related to specific patients health needs and direct messages to patients
Legal Basis – UK GDPR Article 6 1 (b) Contract, Article 6 1 (e) Public task, Article 9 2 (h)
Provider – Mjog AccuRx EConsult |
Remote consultation
Including – Video Consultation Clinical photography |
Purpose – Personal information including images may be processed, stored and with the patients consent shared, in order to provide an online consultation service
Legal Basis – Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Patients will be asked to provide consent if required to provide photographs of certain areas of concern. There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children.
Processor AccuRX- E consult |
MDT meetings | Purpose – For some long term conditions, such as diabetes, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions.
During COVID 19 the practice may use secure video meeting platform to discuss patient needs.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor – MS Teams |
General Practice Extraction Service (GPES)
|
Purpose – GP practices are required by law to provide data extraction of their patients personal confidential information for various purposes by NHS Digital. The objective of this data collection is on an ongoing basis to identify patients registered at General Practices who fit within a certain criteria, in order to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction, by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work:
Legal Basis – All GP Practices in England are legally required to share data with NHS Digital for this purpose under section 259(1)(a) and (5) of the 2012 Act
Further detailed legal basis can be found in each link.
Any objections to this data collection should be made directly to NHS Digital. enquiries@nhsdigital.nhs.uk
Processor – NHS Digital |
Medication/Prescribing | Purpose : Prescriptions containing personal identifiable and health data will be shared with chemists/pharmacies, in order to provide patients with essential medication or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Where patients have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver medication
Legal Basis : Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Patients will be required to nominate a preferred pharmacy.
Processor – Pharmacy of choice |
Professional Training | Purpose – We are a GP training surgery. On occasion you may be asked if you are happy to be seen by one of our GP registrars. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE.
Legal Basis – 6 1 (a) consent, patients will be asked if they wish to take part in training sessions. 9 2 (a) – explicit consent will be required when making recordings of consultations
Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.
|
Shared Care Record | Purpose: In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP connect, which is managed by NHS Digital, to enable a shared care record, which will assist in patient information to be used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population.
Where data is used for secondary uses no personal identifiable data will be used.
Where personal confidential data is used for Research explicit consent will be required.
Legal Basis: Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor: NHS Digital, ICS member providers |
Reviews of and Changes to our Privacy Notice
We will keep our Privacy Notice under regular review. This notice was last reviewed on 26/052024
Lawful basis for processing:
The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions 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…”
Sharing Of Patient Data
We store your records as stated in the NHSE retention schedule which can be accessed here: