How we use your personal information
This Privacy Notice explains why the GP Health Centre collects information about you and how that information may be used.
Health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. Local Health Board, 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 Health Centres and technology to ensure that your information is kept confidential and secure. Records this GP Health Centre hold about you may include the following information:
- Details about you, such as your name, address, 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.
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 within the Health Centre 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 gain your consent before releasing the information for this purpose.
Risk stratification data 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 Health Centre. A risk score is then arrived at through an analysis of your de-identified information using software and is only provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on 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 of your data being used in this way.
The Health Centre 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. This service is provided within the Health Centre by our Clinical Pharmacist.
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:
- Data Protection Act 1998 and General Data Protection Regulation 2016;
- 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 and / or 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.
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;
- Local and National Health Boards;
- Relevant Primary Care Support Units;
- Independent Contractors such as dentists, opticians, pharmacists;
- Private Sector Providers;
- Voluntary Sector Providers;
- Ambulance Trusts;
- Social Care Services;
- Relevant National and Local Informatics Centres for example NWIS Local Authorities;
- Education Services;
- Fire and Rescue Services;
- Police & Judicial Services;
- Voluntary Sector Providers;
- Private Sector Providers;
- Other ‘data processors’ which you will be informed of
You will be informed who your data will be shared with and in some cases asked for explicit consent for this happen when this is required.
We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.
Access to personal information
You have a right under the Data Protection Act 1998 to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. In order to request this, you need to do the following:
- Your request must be made in writing to the GP – for information from the hospital you should write direct to them;
- There may be a charge to have a printed copy of the information held about you;
- We are required to respond to you within 40 days;
- 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.
Objections / Complaints
Should you have any concerns about how your information is managed at the GP, please contact the Health Centre Manager. If you are still unhappy following a review by the Health Centre, you can then complain to the Information Commissioners Office (ICO) via their website (www.ico.gov.uk).
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 have any concerns about how your data is shared then please contact the Health Centre.
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 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 Data Protection Act 1998 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 Health Centre is registered with the Information Commissioners Office (ICO).
Who is the Data Controller?
The Data Controller, responsible for keeping your information secure and confidential is the Health Centre’s Operations Manager.
Should you have any concerns about how your information is managed by the Health Centre please contact the Operations Manager at the following address:
Plas Menai Health Centre
If you are still unhappy following a review by the Health Centre you can then complain to the Information Commissioners Office (ICO). www.ico.org.uk, email@example.com, telephone: 0303 123 1113 (local rate) or 01625 545 745
Supplementary Privacy Notice during COVID-19
This notice describes how the Plas Menai Health Centre may use your information to protect you and others during the Covid-19 outbreak. It supplements our main Privacy Notice which which is available to you at www.plasmenaihealthcentre.co.uk
NHS Wales is facing significant pressures due to the Covid-19 pandemic, and action is being taken to manage and ease the spread and impact of the outbreak. To do this we are working closely with other health and care organisations to provide the services people need as quickly and as easily as possible. In the current emergency it has become even more important to share health and care information across relevant organisations so that they can better support you during this outbreak.
Existing law which allows personal information to be used and shared appropriately and lawfully in a public health emergency is being used during this outbreak. Data protection processes are in place to enable us to provide the right information to the right organisations in order to ensure appropriate services can be put in place as this outbreak develops. We will ensure that any information collected, used or shared is treated with the appropriate safeguards, and subject to strict controls that meet with the requirements of data protection legislation.
Organisations which we may share your information with can include those within NHS Wales, Welsh Government, social care services, local authorities and those in the voluntary and private sectors delivering critical services to support health and care. For example, we may need to tell these organisations if you are one of the people who will need extra support e.g. you are in the group of people identified as being more vulnerable to the virus due to having existing health issues.
We want to assure you that any information that is part of your health record will only be shared if it is absolutely necessary in order to secure the best care for you. For example, we may need to share your information with neighbouring GP Practices, Hospitals and Community Pharmacies to enable them to provide you with treatment. In circumstances where you tell us you’re experiencing Covid-19 symptoms we may need to collect specific health information about you. Where we need to do so, we will not collect more information than we need. We will be required to share limited information for the purposes of protecting public health and monitoring and managing the outbreak.
Any information used or shared during the Covid-19 outbreak will be limited to the period of the outbreak. This rapid action is only being taken due to the current Covid-19 outbreak.
Please note: It may also take us longer to respond to Individual Rights Requests whilst we focus our efforts on responding to the outbreak. We respectfully ask that if your request for information is not urgent, you consider whether your request for information could be delayed.
If you have any further queries/or would like further information, then please so contact us at: firstname.lastname@example.org.
The following links provide further information on the Health Service (Control of Patient Information) Regulations 2002 (COPI). Further details can be found on the ICO website for the Data Protection Act 2018 (DPA) and the General Data Protection Regulation 2016 (GDPR) or visit the ICO’s Data protection and the coronavirus information hub