Coronavirus (COVID-19) pandemic and your information
The ICO recognises the unprecedented challenges the NHS and other health professionals are facing during the Coronavirus (COVID-19) pandemic. The ICO also recognise that 'Public bodies may require additional collection and sharing of personal data to protect against serious threats to public health.'
The Government have also taken action in respect of this and on 20th March 2020 the Secretary of State for Health and Social Care issued a Notice under Regulation 3(4) of The Health Service (Control of Patient Information) Regulations 2002 requiring organisations such as GP Practices to use your information to help GP Practices and other healthcare organisations to respond to and deal with the COVID-19 pandemic.
In order to look after your healthcare needs during this difficult time, we may urgently need to share your personal information, including medical records, with clinical and non clinical staff who belong to organisations that are permitted to use your information and need to use it to help deal with the Covid-19 pandemic. This could (amongst other measures) consist of either treating you or a member of your family and enable us and other healthcare organisations to monitor the disease, assess risk and manage the spread of the disease.
Please be assured that we will only share information and health data that is necessary to meet yours and public healthcare needs.
The Secretary of State for Health and Social Care has also stated that these measures are temporary and will expire on 30th September 2020 unless a further extension is required. Any further extension will be will be provided in writing and we will communicate the same to you. Please also note that the data protection and electronic communication laws do not stop us from sending public health messages to you, either by phone, text or email as these messages are not direct marketing. It may also be necessary, where the latest technology allows us 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.
If you are concerned about how your information is being used, please contact our DPO using the contact details provided in our Privacy Notice.
Summary Privacy / Fair Processing Notice
Clarendon Surgery and The Angel Medical Practice has a legal duty to explain how we use any personal information we collect about you, as a registered patient, at the practice. Staff at this practice maintain records about your health and the treatment you receive in electronic and paper format.
What information do we collect about you?
We will collect information such as personal details, including name, address, next of kin, records of appointments, visits, telephone calls, your health records, treatment and medications, test results, X-rays, etc. and any other relevant information to enable us to deliver effective medical care.
It is important that you tell us 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.
How we will use your information
Your data is collected for the purpose of providing direct patient care; however, we can disclose this information if it is required by law, if you give consent or if it is justified in the public interest. The practice may be requested to support research; however, we will always gain your consent before sharing your information with medical research databases where the law allows.
In order to comply with its legal obligations, this practice may send data to NHS Digital when directed by the Secretary of State for Health under the Health and Social Care Act 2012. Additionally, this practice contributes to national clinical audits and will send the data that is required by NHS Digital when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form; for example, the clinical code for diabetes or high blood pressure.
Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the General Date Protection Regulations (GDPR).
We may also have to share your information, subject to strict agreements on how it will be used, with the following organizations or receive information from the following organizations:-
NHS Trusts / Foundation Trusts
Other GP Practices and GP Organizations
Independent Contractors e.g. dentists, opticians, pharmacists
NHS Commissioning Support Units
Private Sector Providers
Voluntary Sector Providers
Clinical Commissioning Groups
Social Care Services
Fire and Rescue Services
Police & Judicial Services
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 explicit 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.
Maintaining confidentiality and accessing your records
We are committed to maintaining confidentiality and protecting the information we hold about you. We adhere to the General Data Protection Regulation (GDPR), the NHS Codes of Confidentiality and Security, as well as guidance issued by the Information Commissioner’s Office (ICO). You have a right to access the information we hold about you, and if you would like to access this information, you will need to complete a Subject Access Request (SAR). Please ask at reception for a SAR form and you will be given further information. Furthermore, should you identify any inaccuracies, you have a right to have the inaccurate data corrected.
Risk stratification is a mechanism used to identify and subsequently manage those patients deemed as being at high risk of requiring urgent or emergency care. Usually this includes patients with long-term conditions, e.g. cancer. Your information is collected by a number of sources; this information is processed electronically and given a risk score which is relayed to your GP who can then decide on any necessary actions to ensure that you receive the most appropriate care.
Your information may be shared if you have received treatment to determine which Clinical Commissioning Group (CCG) is responsible for paying for your treatment. This information may include your name, address and treatment date. All of this information is held securely and confidentially; it will not be used for any other purpose or shared with any third parties.
You have a right to object to your information being shared. Should you wish to opt out of data collection, please contact a member of staff who will be able to explain how you can opt out and prevent the sharing of your information; this is done by registering to opt out online (national data opt-out programme) or if you are unable to do so or do not wish to do so online, by speaking to a member of staff.
In accordance with the NHS Codes of Practice for Records Management, your healthcare records will be retained for 10 years after death, or if a patient emigrates, for 10 years after the date of emigration.
The practice has prepared a series of Privacy Notices providing more information in relation to how we process your data. For more information please ask at reception
- Contact the practice’s Data Protection Officer (DPO), Dr Jeremy Tankel via 0161 211 7373.
- The practice is the data controller for the data held about its patients. You can write to the data controller at Clarendon Surgery
- Ask to speak to the practice manager Janine Crowshaw (Practice Manager) or Elaine Tidswell (Deputy Manager) or any reception staff in his absence
Should you have any concerns about how your information is managed at this Practice, please contact the Practice Manager. If you are still unhappy after we have responded to your concerns, you can then complain to the Information Commissioners Office (ICO) via their website (www.ico.org.uk).
To view the full document please see the attached link
GP Fair Processing Notice v2.
DATA IMPACT ASSESSMENTS
As part of Information Governance and GDPR we are required to publish our Data Protection Impact Assessments. Any sharing of information is risk assessed for security.
We would only share information where it benefits patient care.
See below for active DPIA’s.
DPIA AccuRX V1 Sep19