Fair Processing Notice

Supplementary Privacy Notice for Patients during Covid-1Supplimentary Privacy Notice for Patients during Covid-19

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

NHS Wales is facing significant pressures due to the Covid-19 pandemic, and action is being taken to manage and ease the spread and impact of the outbreak. To do this we are working closely with other health and care organisations to provide the services people need as quickly and as easily as possible. In the current emergency it has become even more important to share health and care information across relevant organisations so that they can better support you during this outbreak.

Existing law which allows personal information to be used and shared appropriately and lawfully in a public health emergency is being used during this outbreak. Data protection processes are in place to enable us to provide the right information to the right organisations in order to ensure appropriate services can be put in place as this outbreak develops. We will ensure that any information collected, used or shared is treated with the appropriate safeguards, and subject to strict controls that meet with the requirements of data protection legislation.   

Organisations which we may share your information with can include those within NHS Wales, Welsh Government, social care services, local authorities and those in the voluntary and private sectors delivering critical services to support health and care. For example, we may need to tell these organisations if you are one of the people who will need extra support e.g. you are in the group of people identified as being more vulnerable to the virus due to having existing health issues.

In circumstances where you tell us you’re experiencing Covid-19 symptoms we may need to collect specific health information about you.  Where we need to do so, we will not collect more information than we need. We will be required to share limited information for the purposes of protecting public health and monitoring and managing the outbreak.

Any information used or shared during the Covid-19 outbreak will be limited to the period of the outbreak. This rapid action is only being taken due to the current Covid-19 outbreak.

Please note: It may also take us longer to respond to Individual Rights Requests whilst we focus our efforts on responding to the outbreak. We respectfully ask that if your request for information is not urgent, you consider whether your request for information could be delayed.

If you have any further queries / or would like further information, please contact us

The following link provide further information on the Health Service (Control of Patient Information) Regulations 2002 (COPI). Further details can be found on the ICO website for the Data Protection Act 2018 (DPA) and the General Data Protection Regulation 2016 (GDPR) or visit the ICO’s Data protection and the coronavirus information hub

We may amend this privacy notice at any time so please review it frequently – Version 1 – 25th April 2020

Fair Processing Notice

Your Information, Your Rights – How we use your personal information

Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the GDPR Regulations.

The following notice reminds you of your rights in respect of the above legislation and how your 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 is in place.

Data Controller

As your registered GP practice, we are the data controller for any personal data that we hold about you.

Data Protection Officer

Data Protection Officer as a Service - NHS Wales Informatics Service (NWIS), Information Governance, Data Protection Officer Support Service

Address - 4th Floor, Tŷ Glan-yr-Afon, 21 Cowbridge Road East, Cardiff CF11 9AD

Contact via - nwisinformationgovernance@wales.nhs.uk

What information do we collect and use?

All personal data must be processed fairly and lawfully, whether it is received directly from you or from a third party in relation to your care and we are committed to protecting your privacy.

‘Personal data’ means 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 personal data’ includes 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.

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:

  • Details about you, such as your address, legal representative, emergency contact details
  • Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
  • Notes and reports about your health
  • Details about your treatment and care
  • Results of investigations such as laboratory tests, x-rays etc
  • Relevant information from other health professionals, relatives or those who care for you
  • Your records will be retained in accordance with the NHS Code of Practice for Records Management

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 may be 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, 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?

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.

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:

  • NHS Hospitals/Health Boards/NCN
  • Local GP practices in order to deliver extended primary care services
  • NHS Supporting Groups
  • Out of Hours Service
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Allied Health Care Professionals providing services to registered patients of the practice
  • Clinical Commissioning Groups
  • Social Care Services
  • Local Authorities
  • Education Services
  • Police & Judicial Services

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.

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.

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

Consent and Objections

Do I need to give my consent?

The GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation. 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.

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 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;
  • 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 may 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.

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.  

Invoice Validation

If you have received treatment within the NHS, the local Health Board may require access to your personal information to determine which 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 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 purposes.

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.

Your Right of Access to Your Records

The 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 to the practice.

Complaints

In the event that you 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 with the Practice Manager of the practice

If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wimslow, Cheshire SK9 5AF – Enquiry Line: 01625 545700 or online at www.ico.gov.uk

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