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PRACTICE FAIR PROCESSING & PRIVACY NOTICE
Your Information, Your Rights
Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR). We are committed to protecting and respecting your privacy.
The following notice reminds you of your rights in respect of the above legislation and how your GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of our practice. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Park Private Clinic complies with the Data Protection Act 1998 and the new GDPR (General data Protection Regulation) beginning from 25th May 2018. All information provided by a Patient is kept confidential.
This notice reflects how we use information for:
- The management of patient records;
- Communication concerning your clinical, social and supported care;
- Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
- Participation in health and social care research; and
- The management and clinical planning of services to ensure that appropriate care is in place for our patients today and in the future.
Data Controller
As your Private GP practice, we are the data controller for any personal data that we hold about you.
What information do we collect and use?
All personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to your care.
We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:
- ‘Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data. This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS GP details.
And
- ‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.
Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services). These records may be electronic, a paper record or a mixture of both. We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.
Why do we collect this information?
The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training. To do this we will need to process your information in accordance with current data protection legislation to:
- Protect your vital interests;
- Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
- Perform tasks in the public’s interest;
- Deliver preventative medicine, medical diagnosis, medical research; and
- Manage the health and social care system and services.
- To ensure that content from our site is presented in the most effective manner for you and for your computer;
- To provide our Site and our on-line business information service to you;
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To notify you about changes to our service.
How is the information collected?
Your information will be collected either electronically using our secure online database, email, or in paper form. Addition physical information may be sent to your NHS GP practice but only with your consent to do so. This information will be retained within your GP’s electronic patient record or within your physical medical records.
- Information that you provide by filling in forms on our site our website www.parkprivateclinic.co.uk (our site). This may include any information provided at the time of accessing our on-line business information service, posting material or requesting further services or information. We may also ask you for information if you report a problem with our Site;
- If you contact us, we may keep a record of that correspondence and your contact details;
- Details of your visits to our Site including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Who will we share your information with?
In order to deliver and coordinate your health and social care, we may share information with the following organisations:
- Local NHS and/or Private GP Practices and hospitals in order to deliver extended care services
- NHS
- 111 and Out of Hours Service
- Local Social Services and Community Care services
- Voluntary Support Organisations commissioned to provide services
Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.
Your information will not be transferred outside of the European Union.
Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information that has been collected lawfully. Every member of staff who works for us has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.
Information is not held for longer than is necessary. We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.
Consent and Objections
Do I need to give my consent?
The GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation. However, consent is only one potential lawful basis for processing information. Therefore, your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice. Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice. Your consent will be documented within your electronic patient record and we will also ask you to fill out a quick form when you come in. If you would like to be sent this form instead please let us know.
What will happen if I withhold my consent or raise an objection?
You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing. Please contact your GP Practice for further information and to raise your objection.
Health Risk Screening / Risk Stratification
Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health. By using selected information such as age, gender, NHS GP details, diagnosis, existing long-term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.
To summarise Risk Stratification is used in our practice to:
- Help decide if a patient is at a greater risk of suffering from a particular condition;
- Prevent an emergency admission;
- Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
- Review and amend provision of current health and social care services.
As mentioned above, you have the right to object to your information being used in this way. However, you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.
All information you provide to us is stored securely
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Electronic patient records are kept in most places where you receive healthcare. Our local electronic system is Writeupp. We do not transfer electronic patient records via this system with other organisations. Paper notes also have restricted staff access and stored securely in a multiple-lock and fire proof location.
IP addresses and use of Cookies on our website
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Site and to deliver a better and more personalised service.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you use our Site.
Your Right of Access to Your Records
The Data Protection Act and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format. This is known as the “right of subject access”. If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information. This can be your GP, or a provider that is or has delivered your treatment and care. You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party. If you would like access to your GP record, please submit your request in writing to:
Park Private Clinic, 16 Regent Street, Nottingham, NG1 5BQ
Complaints
In the event that your feel your GP Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager at:
Park Private Clinic, 16 Regent Street, Nottingham, NG1 5BQ
If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at: Wycliffe House, Water Lane, Wimslow, Cheshire SK9 5AF
Enquiry Line: 01625 545700
or online at www.ico.gov.uk