Fair Processing Notice – Privacy Notice
Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 1998 and the EU General Data Protection Regulations (GDPR).
GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.
This notice reflects how we use information for:
The management of patient records;
Communication concerning your clinical, social and supported care;
Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
Participation in health and social care research; and
The management and clinical planning of services to ensure that appropriate care
This information is publicly available on the Information Commissioners Office website www.ico.org.uk
Data Controller: George Eliot Medical Centre
As your registered GP practice, we are the data controller for any personal data that we hold about you.
What information do we collect and use?
All personal data must be processed fairly and lawfully, NHS records maybe electronic, on paper or a mixture of both. And we use a combination of working practices and technology to ensure that your information is kept secure and confidential.
We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:
Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data. This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS Number; and
Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.
Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services). These records maybe electronic, a paper record or a mixture of both. We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.
Why do we collect this information?
The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training. To do this we will need to process your information in accordance with current data protection legislation to:
Protect your vital interests;
Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
Perform tasks in the public’s interest;
Deliver preventative medicine, medical diagnosis, medical research; and
Manage the health and social care system and services.
How do we use this information? Risk Stratification
To ensure that you receive the best possible care, your records will be used to facilitate the care you receive. Information held about you may be used to protect the health of the public and to help us manage the NHS. Information may also be used for clinical audit to monitor the quality of the service provided. In addition, your information will be used to identify whether you are at risk of a future unplanned hospital admission and/or require support to effectively manage a long term condition. If necessary your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way.
The Practice may conduct Medicine Management Reviews of medicines prescribed to its patients. This service performs a review of prescribed medicines to ensure patients receive the most appropriate, up to date and cost effective treatments.
How is the information collected?
Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection. In addition physical information will be sent to your practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.
Who will we share your information with?
In order to deliver and coordinate your health and social care, we may share information with the following organisations:
Other GP Practices
NHS Trusts/Foundation Trusts
NHS Commissioning Support Units
Private sector providers
Clinical Commissioning Groups
Social Care Services
Health and Social Care Information Centre (HSCIC)
Fire and Rescue Services
Community Health and Care Trust
111 and Out of Hours Service
West Midlands Ambulance Service
Coventry City Council (Adult Social Services and Community Care)
Voluntary Support Organisations
Children’s Local Safeguarding Board
Police and Judicial Serves
Other data processors which you will be informed of
Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations. You will be informed who your data will be shared with and in some cases asked for explicit consent when required.
We may also use external companies to process information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.
Who do we receive information from?
Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.
In addition we received data from NHS Digital (as directed by the Department of Health) such as the uptake of flu vaccinations and disease prevalence in order to assist us to improve “out of hospital care”.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information that has been collected lawfully. Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.
Information is not held for longer than is necessary. We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.
Consent and Objections
Do I need to give my consent?
The GDPR sets a high standard for consent. However consent is only one potential lawful basis for processing information. Therefore your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice. Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice. Your consent will be documented within your electronic patient record.
What will happen if I withhold my consent or raise an objection?
You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing. Please contact your GP Practice for further information and to raise your objection.
- Heer George Eliot Medical Centre, 178 Foleshill Road, Coventry, CV1 4JH
Health Risk Screening / Risk Stratification
Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health. By using selected information such as age, gender, NHS number, diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.
To summarise Risk Stratification is used in the NHS to:
Help decide if a patient is at a greater risk of suffering from a particular condition;
Prevent an emergency admission;
Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
Review and amend provision of current health and social care services.
Your GP will use computer based algorithms or calculations to identify their registered patients who are at most risk, with support from the local Commissioning Support Unit and/or a third party accredited Risk Stratification provider. The risk stratification contracts are arranged by NHS Coventry and Rugby Clinical Commissioning Group in accordance with the current Section 251 Agreement. Coventry CCG will not at any time have access to your personal or confidential data. They will only act on behalf of your GP to organise the risk stratification service with appropriate contractual technical and security measures in place.
Your GP will routinely conduct the risk stratification process outside of your GP appointment. This process is conducted electronically and without human intervention. The resulting report is then reviewed by a multidisciplinary team of staff within the Practice. This may result in contact being made with you if alterations to the provision of your care are identified.
A Section 251 Agreement is where the Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers.
As mentioned above, you have the right to object to your information being used in this way. However you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.
Sharing of Electronic Patient Records within the NHS
Electronic patient records are kept in most places where you receive healthcare. Our local electronic systems EMIS enables your record to be shared with organisations involved in your direct care, such as:
Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
Child health services that undertake routine treatment or health screening
Urgent care organisations, minor injury units or out of hours services
Palliative care hospitals
Mental Health Trust
Social Care organisations
In addition, NHS England have implemented the Summary Care Record which contains information about medication you are taking, allergies you suffer from and any bad reactions to medication that you have had in the past.
Your electronic health record contains lots of information about you. In most cases, particularly for patients with complex conditions and care arrangements, the shared record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health. Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so. The shared record means patients do not have to repeat their medical history at every care setting.
Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to disable this function or restrict access to specific elements of your record. This will mean that the information recorded by your GP will not be visible at any other care setting.
You can also reinstate your consent at any time by giving your permission to override your previous dissent.
If you have received treatment within the NHS, the local Commissioning Support Unit may require access to your personal information to determine which Clinical Commissioning Group is responsible for payment for the treatment or procedures you have received. Information such as your name, address, date of treatment and associated treatment code may be passed onto the CSU to enable them to process the bill. These details are held in a secure environment and kept confidential. This information is only used to validate invoices in accordance with the current Section 251 Agreement, and will not be shared for any further commissioning purposes.
Your Right of Access to Your Records
The Data Protection Act 1998 and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format. This is known as the “right of subject access”. If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information. This can be your GP, or a provider that is or has delivered your treatment and care. You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party. If you would like access to your GP record please submit your request in writing to:
George Eliot Medical Centre, 178 Foleshill Road, Coventry, CV1 4LJ
There maybe a charge for this and we are required to respond to you within 40 days
In the event that your feel your GP Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager at:
George Eliot Medical Centre, 178 Foleshill Road, Coventry, CV1 4LJ
If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) via their website www.ico.gov.uk. Tele: 0303 123 1113
If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you need not do anything.