Privacy Policy

Patient privacy notice

How we use your personal information

We are transparent, and providing accessible information to patients about how we will use your personal information is a key element of the GDPR regulations.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 the local NHS system.

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
  • The management and clinical planning of services to ensure that appropriate care is in place

Data controller

As your registered GP practice, we are the data controller for any personal data that we hold about you.

What information do we collect and use

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

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. Personal data means any information relating to an identifiable person who can be directly or indirectly identified from the data.

This includes:

  • Date of birth
  • Full postcode and address
  • Next of kin
  • NHS number

Personal data may also refer to special category and sensitive personal data, such as medical history including details of the following:

  • Appointments and contact with you
  • Clinical notes
  • Emergency appointments and admissions
  • Medication
  • Race, ethnic origin, sexual orientation and genetics
  • Results of investigations
  • Social care status
  • Supportive care arrangements
  • Treatments

We will also collect the following types of information from you or about you from a third party engaged in the delivery of your care:

  • Any contact the surgery has had with you, such as appointments, clinic visits, and emergency appointments
  • Details about you, such as your address, legal representative, and emergency contact details
  • Details about your treatment and care
  • Notes and reports about your health
  • Relevant information from other health professionals, relatives or those who care for you
  • Results of investigations such as laboratory tests and X-rays

Furthermore, your records will be retained in accordance with the NHS code of practice for records management. Your healthcare records contain information about your health and any treatment or care you have received previously. They will also contain where and from who you received the treatment, which may include an acute hospital, a GP surgery, a community care provider, a mental health care provider, a walk-in centre or 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:

  • Deliver preventative medicine, medical diagnosis, medical research, and
    manage the health and social care system and services
  • Perform tasks in the public’s interest
  • 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

How do we use this information

To ensure that you receive the best possible care, your records will be used to facilitate the care you receive. Information held about you may be used to protect the health of the public and to help us manage the NHS. Information may also be used for clinical audit to monitor the quality of the service provided.

In addition, your information will be used to identify whether you are at risk of a future unplanned hospital admission and/or require support to effectively manage a long term condition.

How is the information collected

Your information will be collected either electronically using secure NHS mail, or a secure electronic transfer over an NHS encrypted network connection. In addition, physical information will be sent to your practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.

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 people and organisations:

  • Ambulance trusts
  • Clinical commissioning groups
  • Education services
  • Fire and rescue services
  • GPs
  • Independent contractors such as dentists, opticians, and pharmacists
  • Local authorities
  • NHS commissioning support units
  • NHS digital
  • NHS trusts and foundation trusts
  • Other data processors, for which you will be informed
  • Police and judicial services
  • Private sector providers
  • Social care services
  • Voluntary sector providers

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.

Who do we receive information from

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.

In addition, we receive data from NHS digital, as directed by the department of health, such as the uptake of flu vaccinations and disease prevalence in order to assist us to improve out of hospital 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 an NHS organisation 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.

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.

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 the practice for further information and to raise your objection.

Health risk screening and 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 number, diagnosis, existing long term conditions, 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 the NHS to:

  • Help decide if a patient is at a greater risk of suffering from a particular condition
  • Identify if a patient needs medical help to prevent a health condition from getting worse
  • Prevent an emergency admission
  • Review and amend provision of current health and social care services

Your GP may use computer based algorithms or calculations to identify their registered patients who are at most risk, with support from the local commissioning support unit or a third party accredited risk stratification provider.

Your GP will routinely conduct the risk stratification process outside of your GP appointment. This process is conducted electronically and without human intervention. The resulting report is then reviewed by a multidisciplinary team of staff within the practice. This may result in contact being made with you if alterations to the provision of your care are identified.

A Section 251 Agreement is where the secretary of state for health and social care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers. 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.

The national data opt-out service allows patients to decide if they want to share their personally identifiable data to be used for planning and research purposes. Please see information in the practice for more details, or refer to www.digital.nhs.uk.

Sharing of electronic patient records within the NHS

Electronic patient records are kept in most places where you receive healthcare. Our local electronic systems EMIS enables your record to be shared with organisations involved in your direct care, such as:

  • Care homes
  • Child health services that undertake routine treatment or health screening
  • Community hospitals
  • Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
  • GP practices
  • Hospitals
  • Mental health trusts
  • Palliative care hospitals
  • Pharmacies
  • Social Care organisations
  • Urgent care organisations, minor injury units or out of hours services

In addition, NHS England have implemented the Summary Care Record which contains information about medication you are taking, allergies you suffer from and any bad reactions to medication that you have had in the past.

Your electronic health record contains lots of information about you. In most cases, particularly for patients with complex conditions and care arrangements, the shared record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health.

Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so. The shared record means patients do not have to repeat their medical history at every care setting.

Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to disable this function or restrict access to specific elements of your record. This will mean that the information recorded by your GP will not be visible at any other care setting.

You can also reinstate your consent at any time by giving your permission to override your previous dissent.

Invoice validation

If you have received treatment within the NHS, the local Commissioning Support Unit, also known as a CSU, may require access to your personal information to determine which CCG is responsible for paying for the treatment or procedures you have received.

Information such as your name, address, date of treatment and associated treatment code may be passed onto the CSU to enable them to process the bill. These details are held in a secure environment and kept confidential. This information is only used to validate invoices in accordance with the current Section 251 Agreement, and will not be shared for any further commissioning purposes.

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.

If you have changed your address, telephone number or name, you can inform us by filling out our online Change of Personal Details Form. It is important that we have up to date contact details in case we need to contact you.

Your Right of Access to Your Records

The general data protection regulations allow 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 be aware that some details within your health records may be exempt from disclosure. However, this will be 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:

  • Carol Armstrong, Blackford House Medical Centre, 137 Croft Lane, Bury, BL9 8QA

Complaints

In the event that you 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 the address above.

If you remain dissatisfied with our response you can contact the Information Commissioner’s Office:

  • The Office of the Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Website privacy notice

At Blackford House Medical Centre, we respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website, regardless of where you visit it from, and will tell you about your privacy rights and how the law protects you.

It is important that you read this privacy notice together with any other privacy notice, or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices, and is not intended to override them.

Controller

The practice Blackford House Medical Centre is the controller, and is responsible for your personal data. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the practice manager.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, also known as anonymous data.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together AS follows:

  • Contact data, including billing address, delivery address, email address and telephone numbers
  • Financial data, including bank account and payment card details
  • Identity data, including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
  • Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Profile data, including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Technical data, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Transaction data, including details about payments to and from you and other details of products and services you have purchased from us
  • Usage data, including information about how you use our website, products and services.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data in law, as this data does not directly or indirectly reveal your identity.

We may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health, genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

How your personal data is collected

We use different methods to collect data from and about you, including through direct interactions. For example, you may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests, or those of a third party, and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Opting-out

You can ask us or third parties to stop sending you marketing messages at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented and we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data we consider: the amount, the nature, and the sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. We may anonymise your personal data, so that it can no longer be associated with you, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have listed your rights below.

You have the right to request access to your personal data, commonly known as a data subject access request. This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it

You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

You have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request

You have the right to object to processing of your personal data where we are relying on a legitimate interest, or those of a third party, and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Lastly, you have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data, or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Choices

Information about your health and care helps us to improve your individual care, speed up diagnosis, plan your local services and research new treatments. The NHS is committed to keeping patient information safe and always being clear about how it is used.

How your data is used

Information about your individual care such as treatment and diagnoses is collected about you whenever you use health and care services. It is also used to help us and other organisations for research and planning such as research into new treatments, deciding where to put GP clinics, and planning for the number of doctors and nurses in your local hospital.

It is only used in this way when there is a clear legal basis to use the information to help improve health and care for you, your family, and future generations. Wherever possible, we try to use data that does not identify you, but sometimes it is necessary to use your confidential patient information.

You have a choice

You do not need to do anything if you are happy about how your information is used. If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service. You can change your mind about your choice at any time.

Will choosing this opt-out affect your care and treatment

No, choosing to opt out will not affect how information is used to support your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.

What do you need to do

If you are happy for your confidential patient information to be used for research and planning, you do not need to do anything.

To find out more about the benefits of data sharing, how data is protected, or to make/change your opt-out choice visit www.nhs.uk/your-nhs-data-matters