Patient’s Personal Clinical Information

How we use Your Personal Information

Foxhill  Surgery takes its responsibilities in relation to patient’s personal information security very seriously and in doing so has implemented this privacy notice to ensure compliance with the General Data protection Regulation 2016 ("GDPR").  

In this duty we are classed as your Data Controller. 

This Privacy Notice explains why we collect information about you and how that information may be used. 

The GDPR identifies Data Concerning Health as a Special Category of Personal Data. 

In recognising this we are under a legal duty to ensure any personal information held is processed according to the following principles: -

• Lawfulness, fairness and transparency
• Purpose limited
• Data minimalized
• Accurate
• Storage is limited
• We are accountable for our actions

We hold your personal data for one or more of the following reasons: -

• For the purposes of preventative medicine and health care and treatment
• For reasons of public interests in the area of public health
• For research or statistical purposes 

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 are used to help to provide you with the best possible healthcare.

NHS health care 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. Examples of the types of records that we hold about you may include the following information;

• Details about you, such as your name, address, your carers, legal representatives and emergency contact details
• 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

Your records are used to facilitate the provision of relevant health care services. Information held about you may be also be used to help protect the health of the public and also for the wider benefit of the NHS. Your personal information may also be used within the GP practice for clinical audit purposes in order 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 individually identified.

Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose.

Call recording

We may record telephone calls you make to our surgery or which we make to you to:

• check for mistakes
• train staff
• prevent, detect, investigate abuse
• help plan and make improvements to NHS services

We do this in the interests of offering a good service to our patients.

If you object to this, please let us know in writing or in person. 

Sometimes, calls may not be recorded if:

• there is a technical fault with the telephony system
• a call handler is using equipment which does not let calls be recorded
• you’ve been transferred to a different line 

Your information will not be transferred outside the UK or European Economic Area.

Sharing call recordings

Your information may be shared with other organisations if they have a legal right to it.

How long we keep your call recording

We will delete call recordings up to 6 months after the call was made. This ensures that any subsequent investigations can be completed.

Reports

We use a processor, iGPR Technologies Limited (“iGPR”), to assist us with responding to report requests relating to your patient data, such as subject access requests that you submit to us (or that someone acting on your behalf submits to us) and report requests that insurers submit to us under the Access to Medical Records Act 1988 in relation to a life insurance policy that you hold or that you are applying for. IGPR manages the reporting process for us by reviewing and responding to requests in accordance with our instructions and all applicable laws, including UK data protection laws.

The instructions we issue to iGPR include general instructions on responding to requests and specific instructions on issues that will require further consultation with the GP responsible for your care.

Your Rights

The information you provided will be managed as required by Data Protection law.

You have the right to receive a copy of the call recording.

You have the right to request that the call recording be deleted if you believe we are processing it for longer than necessary.

The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost effective treatments.

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 GDPR
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management
• Information: To Share or Not to Share Review 

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

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)
• Where the law requires information to be passed on
• In accordance with the new information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies
• Where it is necessary for the purposes of facilitating any health related and/or medical treatment that you have consented to receive
• You register at a new surgery and your medical records will be transferred electronically via a system called GP Connect

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;

• NHS Trusts / Foundation Trusts
• Other GP Surgeries
• NHS Commissioning Support Units
• Independent Contractors such as dentists, opticians, pharmacists
• Local Pharmacies in relation to medication and other clinical issues relating to your health
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• Health and Social Care Information Centre (HSCIC)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Private Sector Providers

 Individuals have a number of rights in relation to the information that we hold about them. These rights include:

•  The right to access information we hold about them and to obtain information about how we process it
• In some circumstances, the right to withdraw their consent to our processing of their information, which they can do at any time. We may continue to process their information if we have another legitimate reason for doing so
• In some circumstances, the right to receive certain information they have provided to us in an electronic format and/or request that we transmit it to a third party
• The right to request that we rectify their information if it’s inaccurate or incomplete
• In some circumstances, the right to request that we erase their information. We may continue to retain their information if we’re entitled or required to retain it
• The right to object to, and to request that we restrict, our processing of their information in some circumstances. Again, there may be situations where individuals object to, or ask us to restrict, our processing of their information but we’re entitled to continue processing their information and/or to refuse that request.

Please ensure that any request concerning our processing of your personal information is provided to us in writing (see below).Ordinarily there will be no charge to have a printed copy of the information held about you,
We are required unless there are extenuating circumstances to respond to you within one month.

Please note that in order to action any request you will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located. 

We will only use and store your Personal Information for as long as it is required for the purposes it was collected for. How long it will be stored for depends on the information in question, what it is being used for and, sometimes, statutory and/or regulatory legal requirements.

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 such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.

The GDPR requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

This information is publicly available on the Information Commissioners Office website www.ico.org.uk

The practice is registered with the Information Commissioners Office (ICO).

If you are still unhappy following a review by the Practice you can then complain to the Information Commissioners Office (ICO).  www.ico.org.uk, casework@ico.org.uk, telephone: 0303 123 1113 (local rate) or 01625 545 745 

Marie Wragg

Business Manager on behalf of the Practice GP Partners.

September 23

We use a processor, iGPR Technologies Limited (“iGPR”), to assist us with responding to report requests relating to your patient data, such as subject access requests that you submit to us (or that someone acting on your behalf submits to us) and report requests that insurers submit to us under the Access to Medical Records Act 1988 in relation to a life insurance policy that you hold or that you are applying for.

iGPR manages the reporting process for us by reviewing and responding to requests in accordance with our instructions and all applicable laws, including UK data protection laws.

The instructions we issue to iGPR include general instructions on responding to requests and specific instructions on issues that will require further consultation with the GP responsible for your care.