Last updated: 15th March 2019 Issue 5
Introduction / Welcome
We are Dr Jefferies and Partners, a NHS GP practice based at 292 Munster Road and at 286 Munster Road.
- 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.
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.
or please write to our Data Protection Officer at the following address:
Dr Jefferies and Partners
286 Munster Road
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 you 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 keep your information confidential and safe
Everyone working for our organisation is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information
applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this.
The health records we use 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. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.
We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection Act 2018
- Human Rights Act
- Common Law Duty of Confidentiality
- NHS Codes of Confidentiality and Information Security
- Health and Social Care Act 2015
- And all applicable legislation
We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.
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.
Improvements in information technology are also making it possible for us to share data with other healthcare organisations for providing you, your family and your community with better care. For example, it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing section below.
Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.
You may choose to withdraw your consent to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start.
Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.
You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.
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.
Child Health Information
We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS CLCH health visitors and school nurses, and with NWL Commissioning Support Unit, who provide the Child Health Information Service on behalf of NHS England.
Information may be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.
Sometimes anonymised data may be used for research purposes – but we will always ask your permission before releasing any information for this purpose which could be used to identify you.
Improving Diabetes Care and long-term condition management
Information that does not identify individual patients is used to enable focused discussions to take place at practice-led local diabetes and long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.
Individual Funding Request
An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for funding of specialised healthcare which falls outside the range of services and treatments that CCG has agreed to commission for the local population. An Individual Funding Request is taken under
consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition
who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.
Invoice validation is an important process. It involves using your NHS number to check which CCG is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.
Local Information Sharing
Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a local health or care professional outside of your usual practice services, such as in an Evening and Weekend GP HUB services, Emergency Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent.
Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to
view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or EMIS remote consulting system).
In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).
National Fraud Initiative - Cabinet Office
The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see:
National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.
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.
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 ongoing 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
This pilot will allow your clinician to send a picture through their smartphone for your skin condition to a specialist through an application with Inhealthcare built by NWL CCG that is Compliant with data protection.
The clinician will be seeking your consent first and will be giving you a leaflet to explain the process.
To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.
Summary Care Record (SCR)
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.
Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.
Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, fax or phone. If you wish to opt- out of having an SCR please return a completed opt-out form to the practice.
Supporting Medicines Management
NWL CCGs use pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the CCG medicines management team may provide relating to obtaining medications on behalf of your GP Practice to support your care.
Supporting Locally Commissioned Services
CCGs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality. The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.
We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.
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
- GP Federations
- 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
- Other ‘data processors’
Specific details of the organisations with whom we share your data can be seen here:
We will never share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function.
Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below).
This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence.
Right to withdraw consent to share personal information (Opt- Out)
If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you do not want your information to be used for
any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.
There are two main types of opt-out.
Type 1 Opt-Out
If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease.
Type 2 Opt-Out
NHS Digital collects information from a range of places where people receive care, such as hospitals and community services. If you do not want your personal confidential information to be shared outside of NHS Digital, for purposes other than for your direct care, you can register a ‘Type 2 Opt-Out’. For further information about Type 2 Opt-Outs, please contact NHS Digital Contact Centre at email@example.com
referencing ‘Type 2 Opt-Outs – Data Requests’ in the subject line; or call NHS Digital on (0300) 303 5678; or visit the website http://content.digital.nhs.uk/article/7092/Information-on-type-2-opt-outs
If you wish to discuss or change your opt-out preferences at any time please contact the Practice.
Access to your information
Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.
If you wish to have a copy of the information we hold about you, please contact the Practice Manager.
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 are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.
Mobile telephone number
If you provide us with your mobile phone number we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.
The Data Protection Act 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.
We are registered as a data controller and our registration can be viewed online in the public register at: http://ico.org.uk/what_we_cover/register_of_data_controllers
Any changes to this notice will be published on our website and in a prominent area at the Practice.
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.
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.
Device Information - We may collect information about your mobile device, such as a unique device identifier.
Third Party Sites and Services
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.
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.
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.
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.
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.
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.
If you have concerns or are unhappy about any of our services, please contact the Customer Services Manager Sally Collins on 02073851965
For independent advice about data protection, privacy and data-sharing issues, you can contact:
The Information Commissioner
Wilmslow Cheshire SK9 5AF
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:
Information Commissioner's Office
Telephone: 0303 123 1113 (local rate)