Changes to how we share you information during the Covid 19 Pandemic. Valid to September 2020.
The health and social care system is facing significant pressures due to the Covid-19 outbreak. Health and care information is essential to deliver care to individuals, to support health and social care services and to protect public health. Information will also be vital in researching, monitoring, tracking and managing the outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations.
Existing law which allows confidential patient information to be used and shared appropriately and lawfully in a public health emergency is being used during this outbreak. Using this law the Secretary of State has required NHS Digital; NHS England and Improvement; Arms Length Bodies (such as Public Health England); local authorities; health organisations and GPs 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 the data. Further information is available here. There is also a new GP Practice Transparency Notice which explains what information we share with NHS Digital for use in pandemic planning and research.
In order to look after your health and care needs we may share your confidential patient information including health and care records with clinical and non clinical staff in other health and care providers, for example neighbouring GP practices, hospitals and NHS 111. We may also use the details we have to send public health messages to you, either by phone, text or email.
The GP Practice Privacy Notice
This practice is supporting vital health and care planning and research by sharing your data with NHS Digital. For more information about this see the GP Practice Privacy Notice for General Practice Data for Planning and Research.
Why we need your personal information
The information we collect is used for medical purposes that include:
- preventative medicine
- medical diagnosis
- medical research
- provision of direct care and treatment
We collect your personal information so that your care team has accurate and up-to-date information to plan your treatment options.
The new data protection law
The General Data Protection Regulation (GDPR) is a new law which allows and regulates the processing of personal data for health and social care, where data are processed by a public authority, such as this organisation.
Health, social care and genetic data are amongst special categories of data requiring special protection and subject to additional controls.
What information we collect about you
Health and care organisations have a legal duty to keep complete, accurate and up-to-date information about your health. This is so that you can receive the best possible care, both now and in the future.
This information is known as your ‘health record’ and is stored securely on managed systems. The information stored includes:
- Identifiers: Your name, date of birth, NHS Number.
- Contact details: Your address, telephone number, email address (if provided).
- Support contact details: Names, contact details of carers, relevant close relatives, next of kin, representatives.
- Physical, social or mental health situation or condition: Your medical history, treatments, test results, referrals, care plans, care packages, medication, medical opinions and other relevant support you are receiving.
- Protected characteristics: Your ethnicity, religion, sexual orientation, gender, which are required for equality monitoring and ensuring that the services are suitable and provided in the right way for the people being cared for.
Who we share your information with
We will share your information with those health and care partners who are directly involved in your care. These may include:
- local NHS hospitals
- local voluntary and private care providers
- urgent and emergency care services, such as NHS 111 and the London Ambulance Service
You may be receiving care from other people as well as the NHS, for example social care services. Health and social care providers may need to receive or share some information about you if they have a genuine need to. This may help them form a complete picture of your health needs and provide care and treatment that is most suited to your needs and preferences. They should only share information with your permission.
We will not normally give your information to any other third party for any reason outside your individual care and treatment without your permission. However, there may be exceptional circumstances where we do, such as if someone’s health and safety is at risk or if the law requires us to pass on information.
If you would like to understand the structure of the NHS in England, core organisations and their roles, please visit the NHS England website
Why we share your information
People often access a range of services available to them to support their health and care needs. Care organisations are increasingly providing services in partnerships.
These services are not restricted by geographical boundaries or by organisational structures. There is also crossover in the information these services need to make sure the care they deliver is safe and of the highest quality. Health and care services use a range of IT systems and increasingly there is the ability to share special category personal data between systems. Care professionals and others supporting your care use IT systems developed and monitored according to strict rules to share your personal data securely and lawfully.
If care services do not share information about you, then they may be making decisions without the best available information. This may affect the quality and safety of care they give you.
You have a legal right to opt out of having your data shared between your care professionals. However, you should be aware of the risks to the safety and the quality of the care you receive.
Sharing information helps care professionals to work together across organisational boundaries. Up-to-date information about your health and care improves the quality of clinical decision making by care professionals. Health and care providers are increasingly using digital technology, subject to strict rules, to further improve your health. We will always inform you about new digital technology and point you to resources to help you access and use it securely. We will always respect your right to opt out if you do not wish to make use of it.
Integrating your care with our partners
Health and care partners in south east London, such as your GP, hospitals, and mental health, community and social care services, work together to make best use of your personal data to improve your treatment and care. This collaborative work helps us to build a more complete picture of all your health and care needs.
Integrated care records in south east London securely connect the electronic health record systems in your GP practice with similar systems in other care settings. These include south east London hospitals, care professionals in urgent and emergency care services (such as NHS 111 or 999), the London Ambulance Service and the National Record Locator Service, which is run by the NHS in England.
Integrating your care records means that your care teams can view your medications, previous treatments, test results and any other relevant care information at the touch of a button. This improves communication between your health and care providers, making best use of clinical resources during your appointments or hospital stay.
Sharing health records is helping to improve your care by providing your care team with essential clinical information at the touch of a button. This reduces the need for repeated phone calls and delayed letters.
Personal health records
These are secure online services, where you can book or cancel appointments, order repeat prescriptions, view parts of your GP record, including information about medication, allergies, vaccinations, previous illnesses and test results and some clinical correspondence such as hospital discharge summaries, outpatient appointment letters and referral letters.
You can also make a subject access request for copies of your health records. For more information see the section below titled 'your legal rights'.
Our practice has decided to outsource our medical reporting work to an NHS Digital accredited company called Medi2data. Medi2data will be processing your medical report via eMR and providing online access via their secure encrypted portal. If you wish to contact Medi2data directly, please email email@example.com or call on 03333 055774.
Other uses of your personal information
Using information for commissioning or regulatory compliance
Commissioning is when organisations plan and pay for health care services. Health and care commissioners need information from your GP practice, hospitals and other care providers about your treatment to review and plan health services. To do this, they need to be able to see information about your care but they do not need to know who you are.
The commissioners use intermediary services called Data Services for Commissioners Regional Office (DSRCO). DSRCOs specialise in analysing and converting coded clinical information within a secure environment into a format that commissioners can legally use. This is specific data about your care that does not reveal your identity or contact details.
NHS Digital, formally known as the Health and Social Care Information Centre (HSCIC), can provide coded data about your care securely to commissioners under the Health and Social Care Act (2012).
NHS Digital, through its DSCROs, is allowed by law to collect, hold and process your personal data. This is for purposes beyond direct patient care, to support care commissioning organisations and the commissioning functions within local authorities.
Service evaluation contributes to the overall quality and effectiveness of clinical services to you and a group of people with a similar condition. This routine quality assessment of care services falls outside the scope of your direct care. It covers:
- care services management
- preventative care and medicine
- health and social care research
Service evaluations are routinely undertaken using anonymised data. Where identifiable information is to be used, the NHS will always do it lawfully and securely in a way that will always protect your privacy.
Using information for research
Our practice works with researchers to find ways to develop better treatments for care. The information in your health records can also be used to help NHS researchers understand more about the causes of illnesses and how best to treat them. They need to follow strict rules to make sure your personal data is always kept secure and confidential.
Where possible, researchers will make efforts to take out any information that could identify you, such as your name, address and postcode. If they cannot practically take out such information, it is their legal responsibility to ask for your explicit permission (consent).
Health services work with researchers and technical experts to develop computer systems and encryption techniques, such as pseudonymisation (using special codes), to enhance your privacy and protect your confidentiality before using your information for research. For more information on such local research systems and initiatives, visit the King’s Health Partners website.
In more exceptional cases, researchers may seek special support from the Secretary of State under the health service (control of patient information) regulations (also known as ‘section 251 support’). This can allow researchers to use your personal data without your permission, only when it is not practical to do seek permission. They must also have reassured an independent committee who have reviewed the purpose and data security arrangements. You can find more information on trials where researchers have used this special support known as ‘section 251’ support.
You can give your care coordinator an advance permission for researchers to contact you in the future if you match the criteria of a trial. Your advance permission, known as ‘consent for contact’ will be noted in your health records. You will only hear from a research nurse, who will explain what that study will entail in more detail.
Clinical data linkages
Partnerships between care providers, such as between your GP practice and NHS hospitals and universities is leading to better opportunities to use clinical data for better care services and treatments by securely joining or ‘linking’ information from different clinical sources within a secure and regulated NHS environment. This joins two or more independent healthcare data sources, for example someone’s GP record and their hospital record, in order to improve the quality of information and to enable NHS researchers to look at your healthcare in more detail. Any information that may identify individuals are all removed prior to any researchers.
Other ways your information is used
We may also use your personal data in the following areas:
- any complaints you have made about services.
- any incidents you may have been involved in while you were receiving treatment and care from us.
- any paid, un-paid work with us, including your involvement in volunteering, public engagement or other projects
- any training, education, supervision delivered to you by us
- CCTV (closed-circuit television) and use of multimedia device.
How we keep your information secure
Your health and care providers store and use large volumes of sensitive personal data every day, such as your health records. The majority of health records are stored electronically.
Other personal data and computerised information are stored on various other systems across your health and care providers. These systems are managed by NHS IT departments or under contract with an approved public framework supplier.
The information we collect is used by people in their work for the purposes stated in this notice. We take our duty to protect your personal information and confidentiality very seriously. We are committed to taking all reasonable measures to ensure the confidentiality and security of personal data for which we are responsible, whether computerised or on paper.
- We encrypt all outgoing email containing personal data
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems
- We provide training to all staff on how to handle all types of data
At the most senior level, we have:
- a senior information risk owner who is accountable for the management of all information and any associated risks and incidents
- a Caldicott guardian who is responsible for the management of patient information and patient confidentiality
- a Data Protection Officer oversees all activities related to the use of data. They make sure data use is done within the law and best practice.
If you have any questions, please contact our Practice Manager, Sandra Connolly
Your legal rights
You have several rights under the data protection law:
a. Right to be informed: you have a right to be informed about uses of your information, with an emphasis on transparency. This fair processing notice, in support of other privacy notices makes sure that your right to be informed is upheld.
b. Right of access: you have a right to receive:
- confirmation of what information is recorded about you
- confirmation of how your information is used
- access to your personal health information and other information we hold
To exercise your right of access, you will be asked to complete a subject access request (SAR) form, provide proof of identification and may be asked to explain exactly what information you require.
Your request must be made in writing addressed to the practice. Please hand this to our receptionists. If you have a query about access to your reocrds, please ask to speak to our reception supervisor who is responsible for coordinating these requests.
We deal with subject access requests without undue delay, but are required to act on them within 1 month of the request being made. The NHS target is to respond within 20 days. In exceptional circumstances we can extend the time to respond by a further two months if the request is complex or we have received a number of requests from the individual.
You will not be charged for this service.
Other people can also apply to access your health records on your behalf. These include anyone authorised by you in writing (such as a solicitor), or any person appointed by a court to manage your affairs if it decides you cannot manage them yourself.
c. Right to rectification: rectification means correcting inaccuracies or incomplete data we hold about you. This often applies to factual information only such as identifiers and next of kin. We are unable to remove or alter professional opinions that you may disagree with. You do however have the right to include your personal statements alongside professional opinions.
- To rectify your information please contact your clinical team.
d. Right to deletion: in some circumstances you can request that we delete the information we hold about you. This right will apply only if the processing has been based on consent which is withdrawn, the processing of data is found not to be lawful or the information is no longer required. We will tell you about activities to which this right applies
There are exceptions to the right to deletion. Your health and care providers are legally required to maintain your records in accordance with the retention guide in the Record management code of practice for health and social care
e. Right to object: you do not have a general right to object to processing of your personal information for your individual care, however you can object if the information is used for a secondary purpose, such as:
- scientific or historical research
- statistical purposes
- purposes in the public interest or under an official authority (eg NHS Act 2006)
- public patient involvement groups
f. Right to restrict processing: the right to restrict processing means that, if you have disputed the accuracy of information, objected to its use or require data due for destruction to be maintained for a legal claim, you can have the data stored by the Trust but not allow other uses until the dispute is settled. To request restriction to processing, please contact the data protection officer.
We will respect your rights under the data protection legislation whether you are an adult or a child. We will respects the wishes of parents’ (or legal guardians’) in respect of data rights of children who are younger than 14 years old.
You should also tell us how you would like us to contact you. Your preferences may include post, text messaging and phone. You should notify your care team about your preferences and ask it to be recorded in your health and care record. You can change your mind later as long as you give timely notifications to your care team about any changes to your preferences.
What other information we collect
We collect information on all staff we employ, as well as volunteers, people with honorary contracts and agency staff for the purposes of running our services. We use the information for administrative, academic and statutory purposes and to support health and safety.
The information we collect includes:
- Names, addresses and telephone numbers for employment contracting
- Spouse, partner, emergency contact, close relative, next of kin names, address, telephone and email details for emergency contact
- Employment records (including professional membership, references, appraisals, professional development plans, education and training records) a statutory requirement of employment, performance management, professional development
- Bank, National Insurance number and pension details for payment of salaries and other expenditure claims
- Nationality / domicile for proof of eligibility to work in the UK
- Ethnicity for equality monitoring, equal opportunities
- Medical information including physical health or mental condition for appropriate adjustments to work arrangements, management of disability rights and other occupational health services
- Religious beliefs for spiritual support, equal opportunities, equality monitoring
We maintain electronic staff records and other corporate systems, such as employment, payroll and finance.
There are some exceptional circumstances where we must share information with official bodies or other organisation about employees without their express permission. These include circumstances owing to a legal or statutory obligation. These bodies may include:
- Disclosure and Barring Service
- Her Majesty’s Revenue and Customs (HMRC)
- financial institutes for e.g. banks and building societies for approved mortgage references
- educational, training and academic bodies
- Department for Work and Pensions (DWP)
- Home Office
We do not share information about patients for the purpose of invoicing of any patients not entitled to free NHS treatment. Disclosures are only made where a disclosure is essential to prevent a serious threat to public health, national security, the life of the individual or a third party, or to prevent or detect serious crime. This includes crimes such as murder, manslaughter, rape, treason, kidnapping and abuse of children or other vulnerable people, serious harm to the security of the state or to public order and serious fraud.
If you want to complain
If you think that information in your NHS health records is wrong, please talk to the doctor looking after you and ask to have the record amended. You can also ask for the information to be amended by contacting our practice manager.
If your request to have your records amended is turned down because the information is not wrong, we will add a statement of your views to the record.
If you are unhappy with our response, you have the right to complain to the Information Commissioner’s Office (ICO), which regulates and enforces the Data Protection Act. For details of how to do this:
- visit the ICO website
- telephone 0303 123 1113
Please talk to a member of our team if you want to know more about how we use your health records or if you do not want your information used in any of the ways described here.
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