Fair processing notice (layered approach) Layer 1

She Alma Medical Centre – Your information, what you need to know

This notice describes why we collect information about you, how your information will be used and your rights in respect of your data.

Why we collect information about you

Your records are used to ensure you get the best possible care. Your information helps them to make the best decisions about your care and helps provide you with proactive advice and guidance. Important information is also collected to help us to remind you about specific treatment which you might need, such as health checks, immunisations for children and reminders for screening appointments. We work with other NHS services to co-ordinate these.

Information held about you may be used to help protect the health of the public and to help us to improve NHS services. Information may be used within the GP practice to monitor the quality of the service provided (known as ‘clinical audit’).

What data do we collect and receive about you?

Records are stored electronically and on paper and include personal details about you such as your address, carers, legal representatives, emergency contact details, as well as:

• Any appointments, visits, emergency appointments
• Notes and reports about your health
• Details about your diagnosis, treatment and care
• Details about any medication you are taking
• Results of investigations such as laboratory tests, x-rays
• Relevant information from health and care professionals, relatives or carers

We also receive information from other organisations that are caring for you that we hold in your record. This will include letters and test results.

How we use your information: For providing your care

Prescriptions

Where you have agreed we will send information on your prescriptions to pharmacies, either by electronic systems or by paper.

Test requests and results

Where we undertake tests on you, such as blood tests, we will send the sample and details of the tests we are requesting to the most appropriate pathology laboratory.  The data shared with the laboratory will include your NHS number, name, the type of test requested and any health information relevant to doing the test and producing the result or report.  We will receive the test results back from the laboratory electronically and these will be stored in your patient record.

Extended services and out of hours

We work closely with neighbouring practices and ‘out of hours’ providers including NHS 111 to ensure that if you need care from a doctor outside of normal hours that they have access to your records when needed to give you the best possible care. This may be delivered over the phone or via video consultation as appropriate. Services may be run by ‘GP Federations’ and ‘Primary Care Networks’.

Patient referrals

With your agreement, your GP or Nurse may refer you to other services not provided by the practice, or they may work with other services to provide your care in the practice. Information will be shared by letters, emails and shared record systems.

Once you have been seen, the other care agency will tell us about the treatment they have provided for you and any support which your GP needs to provide. This information is then included in your record. Referrals can be to lots of different services, such as smoking cessation services, social prescribers, voluntary services and other health and care agencies, as appropriate, for your care.

Hospital, Community or Social Care Services

Sometimes the staff caring for you need to share some of your information with others who are also supporting you. This could include hospital or community based specialists, nurses, health visitors, therapists or social care services. Information will be shared to organisations where you receive care, whether that is local or further away, if you need specialist care or emergency care in another.

Shared computer systems

Health and Social care services are developing shared systems to share data efficiently and quickly. It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and also in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment. It is also quicker for staff to access a shared record than to try to contact other staff by phone or email.

Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job. Systems do not share all your data, just data which services have agreed is necessary to include.

For more information about shared care records, please go to FPN layer 2

Safeguarding of children or vulnerable adults

If we have significant concerns or hear about an individual child or vulnerable adult being at risk of harm, we may share relevant information with other organisations, such as local authorities and the Police, involved in ensuring their safety.

Ensuring medicines work well

We work with the local Medicines Management team of the Clinical Commissioning Group to help get the best out of medicines for patients and ensure they are effective in managing conditions. This generally uses anonymous data, but occasionally they will assist in reviews of medication for patients with complex needs. Doctors may also seek advice and guidance on prescribing queries.

Identifying health risks

Systems known as ‘risk stratification tools’ are used to help determine a person’s risk of suffering particular conditions and enable us to focus on preventing ill health before it develops. Information in these systems comes from a number of sources, such as hospitals and the practice. This can help us identify and offer you additional services to improve your health.

Multi-disciplinary team meetings

For some long term conditions, such as diabetes, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions.

National Services (including screening programmes)

There are some national services like National Diabetes Audit and the National Cancer Screening Programmes that collect and keep information from across the NHS. This is how the NHS knows when to contact you about services like cervical, breast or bowel cancer screening.

You can find out more about how the NHS holds and shares your information for national programmes on the NHS Screening Website

Data may also be shared on anyone who contracts a ‘communicable disease’, such as Covid 19, in order to manage public health and safety.

How we use your information: beyond providing your care

The information collected about you when you use our services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• improving the quality and standards of care
• research into the development of new treatments
• preventing illness and diseases
• monitoring safety
• planning new services
• public health screening
• assisting the Care Quality Commission with any investigations
• investigating fraud

Wherever possible data used for these purposes is anonymised so that you cannot be identified. If information cannot be completely anonymous, then this may only take place when the law allows the information to be used. All these uses help to provide better health and care for you, your family and future generations.

Statutory disclosures

Sometimes we are duty bound by laws to disclose information to organisations such as the Care Quality Commission, the Driver and Vehicle Licencing Agency, the General Medical Council, Her Majesty’s Revenue and Customs and Counter Fraud services. In these circumstances we will always try to inform you before we are required to disclose and we only disclose the minimum information that the law requires us to do so.

Objecting to the of use of data for purposes beyond your care

The NHS Constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’. The Further information can be found on the NHS Constitution website

Type 1 Opt Out

This is an objection that prevents an individual's confidential patient information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to apply a Type 1 Opt Out to their record you should make your wishes known to the practice manager. It does not apply if data extracted is not identifiable.

National data opt-out

The national data opt-out enables patients to opt-out from the use of their personal confidential data for research or planning purposes. To find out more or register to opt out.

If you have any concerns about use of your data not covered by the National Data Opt out, please contact the practice.

How long do we hold information for?

Records are kept for the lifetime of the patient. If you move to a new practice, your record will be transferred. If the practice you have left need to access your record, for example to deal with a historic complaint, they will let you know. When information has been identified for destruction or deletion it will be disposed of using approved confidential disposal procedures.

Your rights:

Data Protection laws give you a number of rights, including access to your data, correction, erasure, objection and restriction of use of your data. Details on how to request access to your data are set out below. If you have any concerns about the accuracy and use of your records, please contact us.

Right of Access to your information (Subject Access Request)

You have the right to have a copy of the information we hold about you. There are some safeguards regarding what you will have access to and you may find information has been removed for the following reasons.

Where your doctor has decided that some information may cause significant harm to you or someone else

Where the information is about someone else (third party) and is confidential to them

You can make a request by asking or writing to the practice. We may ask you to complete a form so that we have a record of your request. You will need to provide proof of identity.

If you would like to access your GP record online contact us

Lawful basis for processing:

The use of personal data for providing care is supported under the following Article 6 and 9 conditions of the GDPR:

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services...”

Change of Details

It is important that you tell us as soon as you can if any of your details such as your name or address, email address or mobile number have changed. This is to make sure no information about you is sent to an old address.

Mobile telephone number

If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile.

Email address

Where you have provided us with your email address we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email, please let us know.

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Data Protection Officer

Should you have any questions or concerns about your data, please contact our Data Protection Officer: Judith Jordan

Right to complain

If you have concerns or are unhappy about any of our services, please contact the Practice Manager.

For independent advice about data protection, privacy and data-sharing issues, you can contact:

The Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone: 0303 123 1113

ICO WEBSITE