Privacy Policy - Raleigh Surgery

 

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How Raleigh Surgery uses your information to provide you with healthcare

This practice keeps medical records confidential and complies with the General Data Protection Regulation

We hold your medical record so that we can provide you with safe care and treatment.

We will also use your information so that this practice can check and review the quality of the care we provide. This helps us to improve our services to you.

  • We will share relevant information from your medical record with other health or social care staff or organisations when they provide you with care. For example, your GP will share information when they refer you to a specialist in a hospital. Or your GP will send details about your prescription to your chosen pharmacy.
  • This practice is a member of the East Devon Health Federation of GP practices and works collaboratively with other member practices for the purpose of delivering the best possible healthcare to patients in east Devon. To enable us to optimise the available resources with your needs you may be referred to other member health partners for treatment and will be given access to your health record to facilitate this treatment. You have the right to opt out if you do not wish your data to be shared under this arrangement. For more information on how we share your information with other GP practices and any other organisation who are directly involved in your care please ask to speak to Debbie Sargeant, Practice Manager
  • Healthcare staff working in A&E and out of hours care will also have access to your information. For example, it is important that staff who are treating you in an emergency know if you have any allergic reactions. This will involve the use of your Summary Care Record. For more information click here or alternatively speak to your practice.
  • You have the right to object to information being shared for your own care. Please speak to the practice if you wish to object. You also have the right to have any mistakes or errors corrected.
 

Other information important about how your information is used to provide you with healthcare

General Practice Data for Planning and Research Data Collection (GPDfPR)

As well as using your information to support the delivery of care to you, your data may be used by NHS Digital to help improve the way health and social care is delivered to patients and service users throughout England. From the 1st September 2021, NHS Digital will securely extract your information to provide access to patient data to the NHS and other organisations who need to use it, to improve health and social care for everyone.

NHS Digital will primarily use your information in a way that does not identify you (your information will be pseudonymised). However, they will be able to use their software to identify you in certain circumstances, and where there is a valid legal reason to do so. NHS Digital may also share your information with third parties such as Local Authorities, primary care networks (PCNs), clinical commissioning groups (CCGs), research organisations, including universities, and pharmaceutical companies.

At the time of publication (May 2021), patients who have a “type 1” opt- out, will  be excluded from this programme and will not have their data extracted for this purpose.  

MORE INFORMATION

We will rely on Legal Obligation (Article (6)(1)(c)), Health and Social Care (Article 9(2)(h)) and Public Health (Article (9)(2)(i)) as the legal basis for processing your data for this purpose

 

Registering for NHS care

  • All patients who receive NHS care are registered on a national database.
  • This database holds your name, address, date of birth and NHS number but it does not hold information about the care you receive.
  • The database is held by NHS Digital a national organisation which has legal responsibilities to collect NHS data.
  • More information can be found here the phone number for general enquires at 0300 303 5678
 

Identifying patients who might be at risk of certain diseases

  • Your medical records will be searched by a computer programme so that we can identify patients who might be at high risk from certain diseases such as heart disease or unplanned admissions to hospital.
  • This means we can offer patients additional care or support as early as possible.
  • This process will involve linking information from your GP record with information from other health or social care services you have used.
  • Information whcih identifies you will only be seen by this practice.
  • For more information please speak to Debbie Sargeant, Practice Manager.
 

Safeguarding

  • Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm.
  • These circumstances are rare.
  • We do not need your consent or agreement to do this.
  • Please speak to Debbie Sargeant, Practice Manager, for more information on our Safeguarding Policies.
 

e-Consult - Consulting your doctor online

 

Not a patient but perhaps a relative, friend, next of kin or otherwise have an involvement with a patient?

It is possible that we also hold information on you as part of someone else's record. The nature of the information held about you will depend on the circumstances that the information was collected for. For instance if you have been named as patient Next of Kin we will hold your name and a means of contacting you such as a phone number or address. Under Data Protection law you will be entitled to receive a copy of this information unless there is good reason not to provide it.

 

We are required by law to provide you with the following information about how we handle your information

Data Controller contact details

Raleigh Surgery
33 Pines Road
Exmouth
EX8 5NH

Email Practive Manager

 

Data Protection Officer contact details

Email Bex Lovewell

 

Purpose of the processing

  • To give direct health or social care to individual patients.
  • For example, when a patient agrees to a referral for direct care, such as to a hospital, relevant information about hte patient will be shared with the other healthcare staff to enable them to give appropriate advice, investigations, treatments and/or care.
  • To check and review the quality of care. (This is called audit and clinical governance).
  • Sharing of Special Patient Notes (SPN's) with out of hours services to assist in the delivery of patient care. This includes information such as End of life status, challenging behaviour, domestic circumstances and other relevant information that may influence the manner in which health care services are delivered.
  • Data is shared with other organisations to ensure that care is delivered effectively and safely to patients.
  • Data is shared with other organisations to ensure that that vulnerable patients including children are safeguarded. Data will be shared with other organisations to safeguard providers of health care from harm or risk to their wellbeing.
 

Lawful basis for processing

These purposes are supported under the following sections of the GDPR:

  • Article 6(1)(c) "...necessary in order to protect the vital interest of the data subject or another natural person."
  • Article 6(1)(f) "...necessary for the purpose of legitimate interest..."
  • Article 9(2)(b) "...necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law..." (specifically the safeguarding of children and vulnerable adults)
  • 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 hte purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services..."

Healthcare staff will also respect and comply with their obligations under the common law duty of confidence.

 

Recipient or categories of recipients of the processed data

The data will be shared with:

  • Healthcare Professionals and staff in this surgery
  • NHS Trusts
  • Specialist Trusts
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Out Of Hours Services (specifically Devon Doctors Ltd)
  • Clinical Commissioning Groups
  • Social Care Services
  • Local Authorities
  • Educational Services
  • Fire and Rescue Services
  • Police
  • Other organisations involved in the provision of direct care to individuals
 

Rights to object

  • You have the right to object to information being shared between those who are providing you with direct care.
  • This may affect the care you receive - please speak to the practice
  • You are not able to object to your name, address and other demographics information being sent to NHS Digital.
  • This is necessary if you wish to be registered to receive NHS care.
  • You are not able to object when information is legitimately shared for safeguarding reasons.
  • In appropriate circumstances it is legal and professional requirement to share information for safeguarding reasons.
  • The information will be shared with the local safeguarding service.
 

Right to access and correct

  • You have the right to access your medical record and have any errors or mistakes corrected. Please speak to a member of staff.
  • We are not aware of any circumstances in which you will have the right to delete correct information from your medical record; although you are free to obtain your own legal advice if you believe there is no lawful purpose for which we hold the information and contact us if you hold a different view.
 

Retention period

GP medical records will be kept in line with the law and national guidance. Information on how long records are kept can be found here or speak to the practice.

 

Right to complain

Please let us know if you are unhappy with how we have used your personal information. Details of our Complaints Procedure can be obtained from a member of the practice team.

You have the right to complain to the Information Commissioner's Office. If you wish to complain please click here or call the helpline 0303 123 1113

 

Data we get from other organisations

We receive information about your health from other organisations who are involved in providing you with health and social care. For example, if you go to hospital for treatment or an operation the hospital will send us a letter to let us know what happens. This means your GP medical record is kept-up-to date when you receive care from other parts of the health service.

 

Processing of data for the purpose of Public Protection

The practice may provide information to and receive information from other agencies for the purpose of protecting the public from individuals who may pose a risk (eg MAPPA). The practice may process this information either as a public task function or because it has a legal duty to do so. Further information including the other agencies involved in the data sharing can be found here.

 

Covid-19 and your information - Updated on 8th April 2020

Supplementary privacy note on Covid-19

This notice describes how we may use your information to protect you and others during the Covid-19 outbreak. It supplements our main Privacy Notice which is available on this page.

The health and social care system is facing significant pressures due to the Covid-19 outbreak. Health and care information is essential to deliver care to individuals, to support health and social care services and to protect public health. Information will also be vital in researching, monitoring, tracking and managing the outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations.  

Existing law which allows confidential patient information to be used and shared appropriately and lawfully in a public health emergency is being used during this outbreak. Using this law the Secretary of State has required NHS Digital; NHS England and Improvement; Arms Length Bodies (such as Public Health England); local authorities; health organisations and GPs to share confidential patient information to respond to the Covid-19 outbreak. Any information used or shared during the Covid-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use the data. Further information is available on gov.uk here and some FAQs on this law are available here.  

During this period of emergency, opt-outs will not generally apply to the data used to support the Covid-19 outbreak, due to the public interest in sharing information. This includes National Data Opt-outs. However in relation to the Summary Care Record, existing choices will be respected. Where data is used and shared under these laws your right to have personal data erased will also not apply. It may also take us longer to respond to Subject Access requests, Freedom of Information requests and new opt-out requests whilst we focus our efforts on responding to the outbreak. 

In order to look after your health and care needs we may share your confidential patient information including health and care records with clinical and non clinical staff in other health and care providers, for example neighbouring GP practices, hospitals and NHS 111. We may also use the details we have to send you public health messages, information relevant to your health, and invitations to take part in research studies, either by phone, text or email. 

During this period of emergency we may offer you a consultation via telephone or video- conferencing. By accepting the invitation and entering the consultation you are consenting to this. Your personal/confidential patient information will be safeguarded in the same way it would with any other consultation. 

We will also be required to share personal/confidential patient information with health and care organisations and other bodies engaged in disease surveillance for the purposes of protecting public health, providing healthcare services to the public and monitoring and managing the outbreak. Further information about how health and care data is being used and shared by other NHS and social care organisations in a variety of ways to support the Covid-19 response is here.

NHS England and Improvement and NHSX have developed a single, secure store to gather data from across the health and care system to inform the Covid-19 response. This includes data already collected by NHS England, NHS Improvement, Public Health England and NHS Digital. New data will include 999 call data, data about hospital occupancy and A&E capacity data as well as data provided by patients themselves. All the data held in the platform is subject to strict controls that meet the requirements of data protection legislation. 

In such circumstances where you tell us you’re experiencing Covid-19 symptoms we may need to collect specific health data about you. Where we need to do so, we will not collect more information than we require and we will ensure that any information collected is treated with the appropriate safeguards.

We may amend this privacy notice at any time so please review it frequently. The date at the top of this Covid section will be amended each time this Covid notice is updated.  

 

Update log

  • Version 2 - updated by CThurlow 25th October 2018. e-Consult notification included.
  • Version 3 - updated by CThurlow/Mark Brincat 28th May 2019. OOH information included
  • Version 4 - updates by A Clatworthy/Mark Brincat 7th October 2019. Not a patient but perhaps a relative, friend, next of kin or otherwise.
  • Version 5 - updates by Mark Brincat 18th December 2019. Addition of 'Processing of data for the purpose of Public Protection' section.
  • Covid-19 and your information - Updated on 8th April 2020
  • GPDfPR - Updated on 15th June 2021