How We Use Your Data
We use the information we receive from you, together with information we have obtained from our dealings with you (including in relation to services we provide to you) to continue to allow us to provide services that you request, to communicate with you, and to personalise information sent to us regarding your health from other Health Care Providers. Examples of how we may personalise information include using your information in generating referrals for you, looking at treatment options for you and deciding on further healthcare needs you may have in the future.
We are also a Research Practice and may contact you in regards to research trials that the surgery have been invited to take part in. We may invite you to take part in a study, your information will not be divulged to any research trial without your explicit consent.
Information to be provided where personal data is collected from the data subject
Where personal data relating to a data subject is collected from the data subject, the controller shall, at the time when personal data is obtained, provide the data subject with all of the following information:
The identity and the contact details of the controller and, where applicable, of the controller’s representative
The contact details of the data protection officer, where applicable
The purposes of the processing for which the personal data are intended as well as the legal basis for the processing
The recipients or categories of recipients of the personal data, if any;
We do not sell, trade, or rent your personal information to others.
We store all the information you provide us, including information provided via forms you complete on our secure server. Our server is secured in line with GDPR regulations and is fully risk assessed annually. Any new information you provide us may be used to update an existing record we hold for you. If you provide a work or home email address we will not be responsible for third parties having access to any communications we send.
Third parties, for instance pharmacies may deliver some of our products to you, or provide all or part of the service requested by you. In these instances, while the information you provide will be disclosed to them, it will only be used for the administration of the service provided (for instance prescriptions).
We ask for your home, mobile phone number, and email address to enable us to contact you in regards to your healthcare.
We make outbound phone calls for a number of reasons including changing of appointments or other administrative tasks. We will only call the number that is contained within your medical record. We cannot call you back to a number that is not contained within the registration portal on your medical record.
We may invite you in for an appointment based on your healthcare needs. We will only ever write to the address that is contained within your medical record.
If we provide information to a third party it is for healthcare purposes if the party we are sending to process data we will exercise the strictest control over the third party contractually, requiring it and any of its agents and/or suppliers to:
- maintain the security and confidentiality of the information and restrict access to those of its own employees
- use the data for the agreed purpose only and prevent it being used for any other purpose by any other party
- refrain from communicating with you other than concerning the healthcare issue in question
- once you have left the practice we will hold your data in the timeframe laid down in GDPR regulations
In addition, we will restrict the information disclosed to the absolute minimum necessary, for example, to provide the product or service.
Our own security procedures mean that we may occasionally have to request proof of identity.
In the event of phone calls from you, we also reserve the right to ask security questions (which we in our sole discretion deem appropriate) in order to satisfy ourselves that you are who you say you are.
As a primary care provider and part of the National Health Service we do participate in medical research projects. Please rest assured that your data is not shared with any research provider without your express consent. All research projects are undertaken with NIHR Clinical Research Network or providers that are ISO2700 and ICH-GCP certified and also NHS IG compliant. We also ensure that all research providers adhere fully with the DPA 1988 and GDPR legislation.
NHS Digital Data Collection from the Practice
The NHS needs data about the patients it treats to plan and deliver its services and to ensure that care and treatment provided is safe and effective. The General Practice Data for Planning and Research data collection will help the NHS to improve health and care services for everyone by collecting patient data that can be used to do this. For example patient data can help the NHS to:
- monitor the long-term safety and effectiveness of care
- plan how to deliver better health and care services
- prevent the spread of infectious diseases
- identify new treatments and medicines through health research
GP practices already share patient data for these purposes, but this new data collection will be more efficient and effective.
This means that GPs can get on with looking after their patients, and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it, to improve health and care for everyone.
Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality.
NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and GP practices.
NHS Digital purposes for processing patient data
Patient data from GP medical records kept by GP practices in England is used every day to improve health, care and services through planning and research, helping to find better treatments and improve patient care. The NHS is introducing an improved way to share this information - called the General Practice Data for Planning and Research data collection.
NHS Digital will collect, analyse, publish and share this patient data to improve health and care services for everyone. This includes:
- informing and developing health and social care policy
- planning and commissioning health and care services
- taking steps to protect public health (including managing and monitoring the coronavirus pandemic)
- in exceptional circumstances, providing you with individual care
- enabling healthcare and scientific research
Any data that NHS Digital collects will only be used for health and care purposes. It is never shared with marketing or insurance companies.
What patient data NHS Digital collect
This collection will start from 1 September 2021. Patient data will be collected from GP medical records about:
- any living patient registered at a GP practice in England when the collection started - this includes children and adults
- any patient who died after the data collection started, and was previously registered at a GP practice in England when the data collection started
We will not collect your name or where you live. Any other data that could directly identify you, for example NHS number, General Practice Local Patient Number, full postcode and date of birth, is replaced with unique codes which are produced by de-identification software before the data is shared with NHS Digital.
This process is called pseudonymisation and means that no one will be able to directly identify you in the data. The diagram below helps to explain what this means. Using the terms in the diagram, the data we collect would be described as de-personalised.
NHS Digital will be able to use the same software to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason. Only NHS Digital has the ability to do this. This would mean that the data became personally identifiable data in the diagram above. An example would be where you consent to your identifiable data being shared with a research project or clinical trial in which you are participating, as they need to know the data is about you.
More information about when we may be able to re-identify the data is in the who we share your patient data with section below.
The Data NHS Digital collect
We will only collect structured and coded data from patient medical records that is needed for specific health and social care purposes explained above.
Data that directly identifies you as an individual patient, including your NHS number, General Practice Local Patient Number, full postcode, date of birth and if relevant date of death, is replaced with unique codes produced by de-identification software before it is sent to NHS Digital. This means that no one will be able to directly identify you in the data.
NHS Digital will be able to use the software to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason. This would mean that the data became personally identifiable in the diagram above. It will still be held securely and protected, including when it is shared by NHS Digital.
NHS Digital will collect
- data on your sex, ethnicity and sexual orientation
- clinical codes and data about diagnoses, symptoms, observations, test results, medications, allergies, immunisations, referrals and recalls, and appointments, including information about your physical, mental and sexual health
- data about staff who have treated you
More detailed information about the patient data we collect is contained in the Data Provision Notice issued to GP practices.
NHS Digital Does not collect.
- your name and address (except for your postcode in unique coded form)
- written notes (free text), such as the details of conversations with doctors and nurses
- images, letters and documents
- coded data that is not needed due to its age – for example medication, referral and appointment data that is over 10 years old
- coded data that GPs are not permitted to share by law – for example certain codes about IVF treatment, and certain information about gender re-assignment
Opting out of NHS Digital collecting your data (Type 1 Opt-out)
If you do not want your identifiable patient data (personally identifiable data in the diagram above) to be shared outside of your GP practice for purposes except for your own care, you can register an opt-out with your GP practice. This is known as a Type 1 Opt-out.
Type 1 Opt-outs were introduced in 2013 for data sharing from GP practices, but may be discontinued in the future as a new opt-out has since been introduced to cover the broader health and care system, called the National Data Opt-out. If this happens people who have registered a Type 1 Opt-out will be informed. More about National Data Opt-outs is in the section Who we share patient data with.
NHS Digital will not collect any patient data for patients who have already registered a Type 1 Opt-out in line with current policy. If this changes patients who have registered a Type 1 Opt-out will be informed.
If you do not want your patient data shared with NHS Digital, you can register a Type 1 Opt-out with your GP practice. You can register a Type 1 Opt-out at any time. You can also change your mind at any time and withdraw a Type 1 Opt-out.
Data sharing with NHS Digital will start on 1 September 2021.
If you have already registered a Type 1 Opt-out with your GP practice your data will not be shared with NHS Digital.
If you wish to register a Type 1 Opt-out with your GP practice before data sharing starts with NHS Digital, this should be done by returning this form to your GP practice. If you have previously registered a Type 1 Opt-out and you would like to withdraw this, you can also use the form to do this. You can send the form by post or email to your GP practice or call 0300 3035678 for a form to be sent out to you.
If you register a Type 1 Opt-out after your patient data has already been shared with NHS Digital, no more of your data will be shared with NHS Digital. NHS Digital will however still hold the patient data which was shared with us before you registered the Type 1 Opt-out.
If you do not want NHS Digital to share your identifiable patient data (personally identifiable data in the diagram above) with anyone else for purposes beyond your own care, then you can also register a National Data Opt-out. There is more about National Data Opt-outs and when they apply in the National Data Opt-out section below.
NHS Digital legal basis for collecting, analysing and sharing patient data
When we collect, analyse, publish and share patient data, there are strict laws in place that we must follow. Under the UK General Data Protection Regulation (GDPR), this includes explaining to you what legal provisions apply under GDPR that allows us to process patient data. The GDPR protects everyone's data.
NHS Digital has been directed by the Secretary of State for Health and Social Care under the General Practice Data for Planning and Research Directions 2021 to collect and analyse data from GP practices for health and social care purposes including policy, planning, commissioning, public health and research purposes.
NHS Digital is the controller of the patient data collected and analysed under the GDPR jointly with the Secretary of State for Health and Social Care.
All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the Data Provision Notice issued by NHS Digital to GP practices.
NHS Digital has various powers to publish anonymous statistical data and to share patient data under sections 260 and 261 of the 2012 Act. It also has powers to share data under other Acts, for example the Statistics and Registration Service Act 2007.
Regulation 3 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) also allow confidential patient information to be used and shared appropriately and lawfully in a public health emergency. The Secretary of State has issued legal notices under COPI (COPI Notices) requiring NHS Digital, NHS England and Improvement, arm's-length bodies (such as Public Health England), local authorities, NHS trusts, clinical commissioning groups and GP practices to share confidential patient information to respond to the COVID-19 outbreak. Any information used or shared during the COVID-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use confidential patient information.
The legal basis under GDPR for General Practice Data for Planning and Research
How NHS Digital use patient data
NHS Digital will analyse and link the patient data we collect with other patient data we hold to create national data sets and for data quality purposes.
NHS Digital will be able to use the de-identification software to convert the unique codes back to data that could directly identify you in certain circumstances for these purposes, where this is necessary and where there is a valid legal reason. There are strict internal approvals which need to be in place before we can do this and this will be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD).
These national data sets are analysed and used by NHS Digital to produce national statistics and management information, including public dashboards about health and social care which are published. We never publish any patient data that could identify you. All data we publish is anonymous statistical data.
We may also carry out analysis on national data sets for data quality purposes and to support the work of others for the purposes set out in Our purposes for processing patient data section above.
Who NHS Digital share patient data with
All data which is shared by NHS Digital is subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the relevant health and social care purpose will be shared.
All requests to access patient data from this collection, other than anonymous aggregate statistical data, will be assessed by NHS Digital’s Data Access Request Service, to make sure that organisations have a legal basis to use the data and that it will be used safely, securely and appropriately.
These requests for access to patient data will also be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD). Organisations approved to use this data will be required to enter into a data sharing agreement with NHS Digital regulating the use of the data.
There are a number of organisations who are likely to need access to different elements of patient data from the General Practice Data for Planning and Research collection. These include but may not be limited to:
- the Department of Health and Social Care and its executive agencies, including Public Health England and other government departments
- NHS England and NHS Improvement
- primary care networks (PCNs), clinical commissioning groups (CCGs) and integrated care organisations (ICOs)
- local authorities
- research organisations, including universities, charities, clinical research organisations that run clinical trials and pharmaceutical companies
If the request is approved, the data will either be made available within a secure data access environment within NHS Digital infrastructure, or where the needs of the recipient cannot be met this way, as a direct dissemination of data. We plan to reduce the amount of data being processed outside central, secure data environments and increase the data we make available to be accessed via our secure data access environment. For more information read about improved data access in improving our data processing services.
Data will always be shared in the uniquely coded form (de-personalised data in the diagram above) unless in the circumstances of any specific request it is necessary for it to be provided in an identifiable form (personally identifiable data in the diagram above). For example, when express patient consent has been given to a researcher to link patient data from the General Practice for Planning and Research collection to data the researcher has already obtained from the patient.
It is therefore possible for NHS Digital to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason which permits this without breaching the common law duty of confidentiality. This would include:
- where the data was needed by a health professional for your own care and treatment
- where you have expressly consented to this, for example to participate in a clinical trial
- where there is a legal obligation, for example where the COPI Notices apply - see Our legal basis for collecting, analysing and sharing patient data above for more information on this
- where approval has been provided by the Health Research Authority or the Secretary of State with support from the Confidentiality Advisory Group (CAG) under Regulation 5 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) - this is sometimes known as a ‘section 251 approval’
This would mean that the data was personally identifiable in the diagram above. Re-identification of the data would only take place following approval of the specific request through the Data Access Request Service, and subject to independent assurance by IGARD and consultation with the Professional Advisory Group, which is made up of representatives from the BMA and the RCGP. If you have registered a National Data Opt-out, this would be applied in accordance with the National Data Opt-out policy before any identifiable patient data (personally identifiable data in the diagram above) about you was shared. More about the National Data Opt-out is in the section below.
Details of who we have shared data with, in what form and for what purposes are published on our data release register.
Where NHS digital stores patient data
NHS Digital only stores and processes patient data for this data collection within the United Kingdom (UK).
Fully anonymous data (that does not allow you to be directly or indirectly identified), for example statistical data that is published, may be stored and processed outside of the UK. Some of our processors may process patient data outside of the UK. If they do, we will always ensure that the transfer outside of the UK complies with data protection laws.
Our telephone system records all telephone calls. Recordings are retained for up to three years, and are used periodically for the purposes of seeking clarification where there is a dispute as to what was said and for staff training Access to these recordings is restricted to named senior staff.
Before you provide any data to us we will endeavor to make it clear why we need it. As a Health Care Provider we need to use what is called sensitive personal data (this is your medical history). When this is required we will obtain your consent first. Consent is required for each instance of access when the request comes from another data controller or provider that does not process their data in line with that of GDPR Article 9:
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 on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;
Certain exceptions may be made in regards to the collection of medications by your spouse or nominated person. These exceptions have been fully risk assessed and a copy of this assessment is available upon request. The nominated person must detail on the patient record when picking up a controlled drug.
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Disclosure of information to third parties
As previously mentioned, we do not sell, trade or rent your information, and will never disclose information about you (including information obtained from our dealings with you) to third parties, except:
We may of course be obliged at law to pass on your information to the police or any other statutory or regulatory authority and in some cases, exemptions may apply under the GDPR Act, whereby we can legitimately release personal data as required to by law.
Subject access requests
You have a statutory right of access to accessible personal and/or sensitive personal data that we hold about you. In order to exercise this right, your application must be in writing for security reasons.
Subject Access Requests will be provided free of charge except:
Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the controller may either:
Charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
Refuse to act on the request.
The controller shall bear the burden of demonstrating the manifestly unfounded or excessive character of the request.
Without prejudice to Article 11 of the Act, where the controller has reasonable doubts concerning the identity of the natural person making the request referred to in Articles 15 to 21, the controller may request the provision of additional information necessary to confirm the identity of the data subject.
Union or Member State law to which the data controller or processor is subject may restrict by way of a legislative measure the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34, as well as Article 5 of GDPR in so far as its provisions correspond to the rights and obligations provided for in Articles 12 to 22, when such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society to safeguard:
The prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security
Other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary and taxation a matters, public health and social security
The protection of judicial independence and judicial proceedings;
The prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;
A monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official authority in the cases referred to in points (a) to (e) and (g);
The protection of the data subject or the rights and freedoms of others;
The enforcement of civil law claims.
In particular, any legislative measure referred to in the paragraph above shall contain specific provisions at least, where relevant, as to:
The purposes of the processing or categories of processing
The categories of personal data
The scope of the restrictions introduced
The safeguards to prevent abuse or unlawful access or transfer
The specification of the controller or categories of controllers
The storage periods and the applicable safeguards taking into account the nature, scope and purposes of the processing or categories of processing
The risks to the rights and freedoms of data subjects
The right of data subjects to be informed about the restriction, unless that may be prejudicial to the purpose of the restriction
Security of Processing
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, as the controller we shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
The pseudonymisation and encryption of personal data;
The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services
The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
A process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, un-authorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
As the controller we shall take steps to ensure that any natural person acting under the authority of us as the controller who has access to personal data does not process them except on instructions from the controller, unless he or she is required to do so by Union or Member State law.
IP addresses and log file data The Vale of the Red Horse Health Care Centres site, does not automatically capture or store personal information, other than logging the user’s IP Address or the location of your computer or network on the Internet, for systems administration and troubleshooting purposes. (If you are connected to the Internet you have an IP address, for example, an IP address might read “184.108.40.206”). We do not use IP addresses in the aggregate to track which pages people visit in order to improve the quality of the site.
Data collection and use You may be asked for personal information if you complete one of the forms on this site. We will only use the information about you for the purpose for which you provide it. Personal information to our website is stored on secure servers. We will never sell or share your personal information with other organisations for their direct marketing purposes without your explicit consent. We do not hold any personal information about you on our website. If you would like further information our data protection officer will be happy to assist you.
Online Registration When you register with the practice on our site or subscribe to our emails, we ask you for information such as name address telephone number previous GP etc. This is used only to register you as a patient on our clinical system this information is not kept in any other format or file.
How we protect your information Our website has security measures in place to protect against the loss, misuse or alteration of the information under our control. When you contribute online, we use a secure server to protect your personal information during transmission.