Privacy Policy
This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you.
This privacy notice applies to personal information processed by or on behalf of the practice.
This Notice explains
- Who we are, how we use your information and our Data Protection Officer
- What kinds of personal information about you do we process?
- What are the legal grounds for our processing of your personal information (including when we share it with others)?
- What should you do if your personal information changes?
- For how long your personal information is retained by us?
- What are your rights under data protection laws?
The General Data Protection Regulation (GDPR) was incorporated into the UK's Data Protection Act on 25th May 2018. This is a single EU-wide regulation on the protection of confidential and sensitive information.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), and the Data Protection Act 2018 (currently in Bill format before Parliament) the practice responsible for your personal data.
This Notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights
How we use your information and the law.
The practice will be what’s known as the ‘Controller’ of the personal data you provide to us.
We collect basic personal data about you which does not include any special types of information or location-based information. This does however include name, address, contact details such as email and mobile number etc.
We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare setting) ethnicity, and sex during the services we provide to you and or linked to your healthcare through other health providers or third parties.
Why do we need your information?
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which the Practice hold about you may include the following information;
- Details about you, such as your address, carer, 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
To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.
How do we lawfully use your data?
We need to know your personal, sensitive and confidential data in order to provide you with Healthcare services as a General Practice, under the General Data Protection Regulation we will be lawfully using your information in accordance with: -
Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”
Article 9, (h) processing is necessary for the purposes of preventive 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
This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.
Risk Stratification
Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information is only provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way.
Medicines Management
The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection Act 2018
- The General Data Protection Regulations 2016
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality, Information Security and Records Management
- Information: To Share or Not to Share Review
Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles.
Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.
All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a sub-contractor acts as a data processor for the practice an appropriate contract (art 24-28) will be established for the processing of your information.
In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent. If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.
Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose in an identifiable format. In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes.
With your consent we would also like to use your information to
We would however like to use your name, contact details and email address to inform you of services that may benefit you, with your consent only. There may be occasions were authorised research facilities would like you to take part on innovations, research, improving services or identifying trends.
At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place. This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO as below.
Where do we store your information Electronically?
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.
No 3rd parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place. We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;
- NHS Trusts / Foundation Trusts
- GP’s
- eMBED Health
- Independent Contractors such as dentists, opticians, pharmacists
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services
- NHS England (NHSE) and NHS Digital (NHSD)
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Voluntary Sector Providers
- Private Sector Providers
- Other ‘data processors’ which you will be informed of
You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.
We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure. All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for the practice an appropriate contract (art 24-28) will be established for the processing of your information.
How long will we store your information?
We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements. More information on records retention can be found online at (https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016)
How can you access, amend move the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes
Access to your personal information
Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
- Your request should be made to the Practice – for information from the hospital you should write direct to them
- There is no charge to have a copy of the information held about you
- We are required to respond to you within one month
- You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.
What should you do if your personal information changes?
You should tell us so that we can update our records please contact the Practice Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.
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 or visit the ICO website
Appendix A – The Practice will share patient information with these organisations where there is a legal basis to do so.
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Activity |
Rationale |
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Commissioning and contractual purposes Planning Quality and Performance
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Purpose – Anonymous data is used by the Integrated Care Board (ICB) for planning, performance and commissioning purposes, as directed in the practices contract, to provide services as a public authority.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Patients may opt out of having their personal confidential data used for Planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/ to apply a National Data Opt Out
Processor – NHS Sussex |
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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 –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
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 |
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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 be required.
Where you have opted out of having your identifiable information shared for this Planning or Research your information will not be shared.
Legal Basis –
· Articles 6(1)(a) and 9(1)(h) – explicit consent; or · Article 6(1)(c) (where we are legally obligated to share your personal data) for your standard personal data and Article 9(2)(j) (scientific research) for your health data.
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
Sharing of aggregated non identifiable data is permitted.
Processor – Research Organisations |
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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 standard NHS contract.
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 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 but this may affect the decision to provide individual funding.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Data processor – Please contact the Practice Manager |
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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 and to protect the safety of individuals.
Consent is not required to share information for this purpose.
Legal Basis – Direct Care under UK GDPR:
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
Data Processor – ICS and West Sussex Safeguarding / Schools |
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Safeguarding Children |
Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Consent may not be required to share this information.
Data Processor –– ICS and West Sussex Safeguarding / Schools |
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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 –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processors – NHS England/ICB/Sussex Community Foundation Trust |
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Public Health Screening programmes (identifiable) Notifiable disease information (identifiable) Smoking cessation (anonymous) Sexual health (anonymous) Vaccination Programmes
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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 to name a few. The law allows us to share your contact information, and certain aspects of information relating to the screening with Public Health England so that you can be appropriately 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.
Patients may not opt out of having their personal information shared for Public Health reasons. Patients may opt out of being screened at the time of receiving an invitation.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Data Processors – Identify where your Public Health are situated |
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Direct Care NHS Trusts Community Providers Pharmacies Enhanced care providers Nursing Homes Other Care Providers |
Purpose – Personal information is shared with other secondary care trusts and providers in order to provide you with individual 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 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
Processors – West Sussex ICB |
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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 UK GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy-statement
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
Processors – Care Quality Commission |
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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.
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data. NB only organisations that provide your care will see your identifiable data.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
Data Processors - Optum, Cerner |
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Payments |
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 amounts 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 (QOF), 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 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
Data Processors – NHS England, ICB, Public Health |
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Patient Record data base |
Purpose – Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date. Your record will follow you as you change surgeries throughout your life. Closed records will be archived by NHS England
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – EMIS and PCSE |
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Medical reports Subject Access Requests |
Purpose – Your medical record may be shared in order that:
Solicitors/persons acting on your behalf can conduct certain actions as instructed by you.
Insurance companies seeking a medical reports where you have applied for services offered by then can have a copy to your medical history for a specific purpose.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – Solicitors and insurance organisations |
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Medicines Management Team Medicines Optimisation |
Purpose – your medical record is shared with the medicines management team pharmacists, in order that your medication can be kept up to date and any necessary changes to medication can be implemented.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – NHS Sussex |
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GP Federation E.g services they provide GP Extended Access Video consultations Minor injuries services
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Purpose – Your medical record will be shared with the IPC in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics. The Federation will be acting on behalf of the GP practice.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – Innovations in Primary Care |
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Primary Care Network (PCN) |
Purpose – Your medical record will be shared with the Lancing & Sompting PCN in order that they can provide direct care services to the patient population.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – The Orchard Surgery, Ball Tree Surgery & New Pond Row Surgery |
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Smoking cessation |
Purpose – personal information is shared in order for the smoking cessation service to be provided.
Only those patients who wish to be party to this service will have their data shared
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – West Sussex County Council Public Health |
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Social Prescribers |
Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their health social care needs.
Only those patients who wish to be party to this service will have their data shared
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – Adur and Worthing District Council – Wellbeing Team |
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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 consent will not always 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. Or where the information is necessary to protect a person or community.
Legal Basis – UK GDPR · Article 6(1)(c) – to comply with a legal obligation; and · Article 9(2)(j) – ‘for reasons of substantial public interest’
Processor – Police Constabulary |
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Coroner
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Purpose – Personal health records or information relating to a deceased patient may be shared with the coroner.
Legal Basis – UK GDPR Article 6(1)(c) - to comply with a legal obligation and article 9(2)(h) health data
Processor – The Coroner |
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Medical Examiner Service(Change to community Medical Examiners name - |
Purpose: Purpose: Medical records associated with deceased patients are outside scope of the UK GDPR. However, next of kin details are within the scope of the UK GDPR. We will share specified deceased patient records and next of kin details with the Medical Examiners within West Sussex ICB
Legal Basis: Article 6(1)(c) – necessary under a legal obligation to which the controller is subject”; and Article 9(2)(h)– “processing is necessary for the purposes of preventive 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”
Processor: Medical Examiners service
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Non-commissioned, private healthcare providers (e.g. BUPA, Virgin Care, etc.) |
Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with Private Providers.
Legal Basis – Articles 6(1)(a) and 9(2)(a) Consented and under contract between the patient and the provider
Provider - |
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Messaging Service
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Purpose – Personal identifiable information shared with the messaging service in order that messages including; appointment reminders; results; campaign messages related to specific patients health needs; and direct messages to patients, can be transferred to the patient in a safe way.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Provider - AccuRX - NHSAPP, Mjog, Iplato, econsult, engage consult, |
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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 the patient with urgent medical advice.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Patients may be videoed or asked to provide photographs with consent. 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, |
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MDT meetings |
Purpose – For some long term conditions, 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. Personal data will be shared with other agencies in order that mutual care packages can be decided.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – District Nurses/Palliative Care/Social Services etc |
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General Practice Extraction Service (GPES)
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Purpose – GP practices are required to provide data extraction of their patients personal confidential information for various purposes to NHS England. 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 England for this purpose under section 259(1)(a) and (5) of the The Health and Social Care Act 2012
Further detailed legal basis can be found in each link.
Any objections to this data collection should be made directly to NHS England. enquiries@nhsdigital.nhs.uk
Processor – NHS England |
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Medication/Prescribing |
Purpose: Prescriptions containing personal identifiable and health data will be shared with organisations who provide medicines management including chemists/pharmacies, in order to provide patients with essential medication regime management, medicines and or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Pharmacists may be employed to review medication, Patients may be referred to pharmacists to assist with diagnosis and care for minor treatment, patients may 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 care and medication
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor – Pharmacy of choice |
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Professional Training |
Purpose – We are a training surgery. Our clinical team are required to be exposed to on the job, clinical experience, as well as continual professional development. On occasion you may be asked if you are happy to be seen by one of our GP registrars, pharmacists or other clinical team to assist with their training as a clinical professional. 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 –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.
Processor – RCGP, HEE, iConnect, Fourteen Fish |
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Telephony |
Purpose – The practice use an internet based telephony system that records telephone calls, for their own purpose and to assist with patient consultations. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients.
Legal Basis – While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way.
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Provider – Surgery Connect – X-ON, |
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Learning Disability Mortality Programme LeDer |
Purpose: The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with this criteria will be shared with NHS England.
Legal Basis: It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information who fit within a certain criteria.
Processor : ICB, NHS England |
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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 England, 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 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor: NHS England |
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Local shared care record |
Purpose: Health and Social care services are developing shared systems to share data efficiently and quickly. It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment. It is also quicker for staff to access a shared record than to try to contact other staff by phone or email.
Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job. Systems do not share all your data, just data which services have agreed is necessary to include.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor: NHS Digital |
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Anticoagulation Monitoring |
Purpose: Personal Confidential data is shared with LumiraDX in order to provide an anticoagulation clinic to patients who are on anticoagulation medication. This will only affect patients who are within this criteria.
Legal Basis –
· Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’
Processor : LumiraDX INRStar |
We keep our Privacy Notice under regular review. This notice was last reviewed in September 2023.