Dr Jefferies and Partners, NHS Doctors in Fulham.

Privacy Notice - GDPR

Last updated: 22nd May 2018- Issue 2

Introduction / Welcome

We are Dr Jefferies and Partners, a NHS GP practice based at 292 Munster Road and at 286 Munster Road.
This privacy and cookie policy describes how we collect, use and share personal data when using this website. Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.
We encourage you to read the Privacy Policy in full. However, to summarise:
  • We will always use your data within the law.
  • We will never sell your data
  • We will always respect your wishes about how you would like to be contacted.

Updates to this Privacy Policy

We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you and post a notice on our Site prior to such changes(s) taking effect. In the event that such a change could materially affect your privacy, you will be notified without delay by appropriate means.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at drjefferiesandpartners@nhs.net or please write to our Data Protection Officer at the following address:

Dr Jefferies and Partners
286 Munster Road
Fulham
SW6 6BQ

Why do we collect your data?

We obtain and use your personal details and your next of kin in order to establish and deliver our contracted services to you.

Where you access our service through your health insurance provider we will need to share personal information including medical information with your health insurance provider with your explicit consent.

Where you access our service through the NHS we will need to share personal information including medical information with the NHS with your explicit consent.

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

We obtain and use your medical information as this is necessary for medical purposes, including medical diagnosis and treatment.

We also store your medical information for regulatory purposes, such as notes from consultations, for regulatory compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the General Medical Council, MHRA, and Care Quality Commission, Health Intelligence or as otherwise required by law or regulation.

We use your email address, postal address and telephone to send you occasional updates about your health where you have given your consent or where you have not opted out, based on our legitimate interest in marketing our services to you, and subject to your right to opt out at any time.

We use your telephone in order to communicate with you regarding appointment bookings, resolving of queries or complaints.

How we use your information

This privacy notice explains why the GP Practice collects information about you, and how that information may be used.

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 this GP Practice may hold about you may include the following information:
  • Details about you, such as address and next of kin
  • 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 for clinical audit to monitor the quality of the service provided.  

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 endeavour to gain your consent before releasing the information. 

Risk Stratification 

Risk stratification tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular 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 using software managed by the North West London Commissioning Support Unit as the data processor and is only provided back to your GP or member of your care team as data controller in an identifiable form. Risk stratification enables your GP to focus on the 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.  

Should you have any concerns about how your information is managed at the surgery please contact the Practice Manager to discuss how the disclosure of your personal information can be limited. 

Health Intelligence 

The Practice shares your diabetes related data with the Diabetic Eye Screening Programme operated by Health Intelligence (commissioned by NHS England). This supports your invitation for eye screening (where you are eligible and referred by the Practice) and on-going care by the screening programme. This data may be shared with any Hospital Eye Services you are under the care of to support further treatment and with other healthcare professionals involved in your care, for example your Diabetologist.

For further information, take a look at Health Intelligence’s Privacy Notice on the diabetic eye screening website: www.nwldesp.co.uk

Invoice Validation 

If you have received treatment within the NHS, North West London Commissioning Support Unit may require access to your personal information in order to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.  

Information such as your name, address and date of treatment may be passed on to enable the billing process. These details are held in a secure environment and kept confidential. This information will only be used to validate invoices, and will not be shared for any further commissioning purposes.  

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 the Data Protection Act 1998 (which is overseen by the Information Commissioner’s Office), Human Rights Act, the Common Law Duty of Confidentiality, and the NHS Codes of Confidentiality and Security.   

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. Anyone who receives information from an NHS organisation has a legal duty to keep it confidential. 

We maintain our duty of confidentiality to you at all times. 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), or where the law requires information to be passed on. 

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 
  • Specialist Trusts 
  • Independent Contractors such as dentists, opticians, pharmacists 
  • Private Sector Providers 
  • Voluntary Sector Providers 
  • Ambulance Trusts 
  • Clinical Commissioning Groups 
  • Social Care Services 
  • Local Authorities 
  • Education Services 
  • Fire and Rescue Services 
  • Police
  • Other ‘data processors’ 

Information we may collect from you

  • Information you provide;
  • Personal details - Basic information about yourself that you provide by filling in forms on our Site or speaking to us on the telephone; such as your name, date of birth, physical address and email address, telephone numbers.
  • Medical information - Information about your symptoms, consultations, medications and procedures.

Passive information collection and use

As you navigate through the Site, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, internet tags and navigational data collection.

Please read our Cookie Policy and review the Cookie Settings for detailed information about cookies and other tracking technologies used on our site. In this policy you will also find information on how to disable cookies and tracking technologies if you do not agree to their use as well as the consequence(s), if any of disabling each specific cookie/tracking technology. If you do not disable any cookies or tracking technologies we will infer your consent to their use.

We and our third party service providers may passively collect and use information in a variety of ways, including: 

Through your browser - Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.

IP Address - Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.

Using pixel tags, web beacons, clear GIFs, or other similar technologies -  These may be used in connection with some Site pages and HTML-formatted e-mail messages to, among other things, track the actions of Site users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about Site usage and response rates.

Online behavioural advertising -  The use of cookies, pixel tags, web beacons, clear GIFs, or other similar technologies allows our third-party vendors to deliver advertisements about our products and services when you visit the Site or other web sites or web properties across the Internet.  These vendors may place pixel tags, web beacons, clear GIFs, or similar technologies on the Site and other websites or web properties, and also place or recognize third-party cookies when you visit the Site or other sites or web properties.  They may use information about your visits to the Site and other web sites or web properties to provide advertisements about goods and services that may be of interest to you. 

Device Information - We may collect information about your mobile device, such as a unique device identifier.

Third Party Sites and Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any App) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates.

Social Media and Sharing Tools

On some pages, we may also feature embedded 'Share' buttons or widgets that enable you to share content with friends through a number of popular social networking sites (e.g. Twitter and Facebook etc).
These sites may set cookies which can identify you as an individual when you are also logged in to their services. This means they may be collecting information about what you are doing online, including on our Sites. We do not control these cookies and you should check the relevant third-party website to see how your information is used and how to opt out. 

Security

We use reasonable organisational, technical and administrative measure to protect personal information under our control and in accordance with this privacy policy. 
Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk. 

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section.

Cross-Border Transfers

Personal information other than medical data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms to send communication emails to our users.

Data Retention

We retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law or to otherwise fulfil a legal obligation.

Use of Site by Minors

This site is directed to adults. It is not directed to individuals under the age of 16, and we request that these individuals do not provide personal information through this Site without their parent or guardian support and authorisation.

Cookies

Use of Cookies

We use Google Analytics software on this site to anonymously track how visitors interact with this website. This includes identifying:
  • The pages visited on this site
  • How long the visitor spends on each page on this site
  • How visitors got to the site
  • What visitors click on while visiting the site
We do this to help make sure the site is meeting the needs of visitors and help us make improvements, for instance improving site search.

We don't use Cookies to

We don't use cookies to track the identity of visitors or the information they have entered into the site.

Consent to Use Cookies

You give us consent to using cookies for analytic purposes if you continue to use this site.

Alternatively, you can switch off cookies in your browser and the site will still work normally.

For more information on how to do this visit About Cookies.

Your rights

You have the right to:

Access the personal data which the practice holds about you. This is called a Subject Access Request (SAR) and must be made to the Data Protection Manager using the details in the ‘Contact Us’ section.

You may use this process to exercise your right to:
  • Have your personal data rectified if it is inaccurate or incomplete.
  • Request that we erase information we hold about you.
  • Restrict the processing of your personal data, for example ask us not to contact you.
  • Object to the processing of your data for specific purposes such as communications or direct marketing.
  • Ask for the transfer of your data electronically to be provided to a third party (data portability)
You also have the right to lodge a complaint with the Information Commissioner’s Office:

Address:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113 (local rate)