General Practice Privacy Notice

Protecting Your Data.

The page is all about how our practice handles our patients' data. Privacy information about our website, including cookies, is here.

During the COVID-19 period, we are required to do some additional sharing and processing of information, which is outlined in the Fair Processing Notice below.

GP data and NHS Digital changes from 1st September 2021. Learn more about the national changes to data being shared with NHS Digital at the end of this page.

Introduction

This privacy notice explains in detail why we use your personal data which we, the GP practice, (Data Controller), collects and processes about you. A Data Controller determines how the data will be processed and used with the GP practice and with others who we share this data with. We are legally responsible for ensuring that all personal data that we hold and use is done so in a way that meets the data protection principles under the General Data Protection Regulation (GDPR) and Data Protection Act 2018. This notice also explains how we handle that data and keep it safe.

Caldicott Guardian

The GP Practice also has a Caldicott Guardian. A Caldicott Guardian is a senior person within a health or social care organisation, preferably a health professional, who makes sure that the personal information about those who use its services is used legally, ethically and appropriately, and that confidentiality is maintained. The Caldicott Guardian for the GP practice is:

Dr Rachel Belton, rachel.belton@nhs.net

Data Protection Officer (DPO)

Under GDPR all public bodies must nominate a Data Protection Officer. The DPO is responsible for advising on compliance, training and awareness and is the main point of contact with the Information Commissioner’s Office (ICO). The DPO for the practice is:

Mrs Lisa Nolan, Lisanolan1@nhs.net

We will continually review and update this privacy notice to reflect changes in our services and to comply with changes in the Law. When such changes occur, we will revise the last updated date as documented in the version status in the header of this document.

What we do?

We are here to provide care and treatment to you as our patients. In order to do this, the GP practice keeps personal demographic data about you such as your name, address, date of birth, telephone numbers, email address, NHS Number etc and your health and care information. Information is needed so we can provide you with the best possible health and care. We also use your data to:

  • Confirm your identity to provide these services and those of your family / carers
  • Understand your needs to provide the services that you request
  • Obtain your opinion on our services (with consent)
  • Prevent and detect fraud and corruption in the use of public funds
  • Make sure we meet our statutory obligations, including those related to diversity and equalities
  • Adhere to a legal requirement that will allow us to use or provide information (e.g. a formal Court Order or legislation)

Definition of Data Types

We use the following types of information / data:

Personal Data

This contains details that identify individuals even from one data item or a combination of data items. The following are demographic data items that are considered identifiable such as name, address, NHS Number, full postcode, date of birth. Under GDPR, this now includes location data and online identifiers.

Special categories of data (previously known as sensitive data)

This is personal data consisting of information as to: race, ethnic origin, political opinions, health, religious beliefs, trade union membership, sexual life and previous criminal convictions. Under GDPR, this now includes biometric data and genetic data.

Personal Confidential Data (PCD)

This term came from the Caldicott review undertaken in 2013 and describes personal information about identified or identifiable individuals, which should be kept private or secret. It includes personal data and special categories of data but it is adapted to include dead as well as living people and ‘confidential’ includes both information ‘given in confidence’ and ‘that which is owed a duty of confidence’.

Pseudonymised Data or Coded Data

Individual-level information where individuals can be distinguished by using a coded reference, which does not reveal their ‘real world’ identity. When data has been pseudonymised it still retains a level of detail in the replaced data by use of a key / code or pseudonym that should allow tracking back of the data to its original state.

Anonymised Data

This is data about individuals but with all identifying details removed. Data can be considered anonymised when it does not allow identification of the individuals to whom it relates, and it is not possible that any individual could be identified from the data by any further processing of that data or by processing it together with other information which is available or likely to be available.

Aggregated Data

This is statistical information about multiple individuals that has been combined to show general trends or values without identifying individuals within the data.

Our data processing activities

The law on data protection under the GDPR sets out a number of different reasons for which personal data can be processed for. The law states that we have to inform you what the legal basis is for processing personal data and also if we process special category of data such as health data what the condition is for processing.

The types of processing we carry out in the GP practice and the legal bases and conditions we use to do this are outlined below:

Provision of Direct Care and administrative purposes within the GP practice

Type of Data
Personal Data – demographics Special category of data – Health data
Source of Data
Patient and other health and care providers
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(e) - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

Article 9(2)(h) - Processing is 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 and social care or treatment or the management of health and social care systems
Common Law Duty of Confidentiality basis
Implied Consent

Direct care means a clinical, social or public health activity concerned with the prevention, investigation and treatment of illness and the alleviation of suffering of individuals. This is carried out by one or more registered and regulated health or social care professionals and their team with whom the individual has a legitimate relationship with. In addition, this also covers administrative purposes which are in the patient’s reasonable expectations.

To explain this, a patient has a legitimate relationship with a GP in order for them to be treated and the GP practice staff process the data in order to keep up to date records and to send referral letters etc.

Other local administrative purposes include waiting list management, performance against national targets, activity monitoring, local clinical audit and production of datasets to submit for national collections.

This processing covers the majority of our tasks to deliver health and care services to you. When we use the above legal basis and condition to process your data for direct care, consent under GDPR is not needed. However, we must still satisfy the common law duty of confidentiality and we rely on implied consent. For example, where a patient agrees to a referral from one healthcare professional to another and where the patient agrees this implies their consent.

Medicines Management and Optimisation

Type of Data
Personal Data – demographics
Special category of data – Health data
Source of Data
GP Practice
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(e) - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

Article 9 (2)(h) - Processing is 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 and social care or treatment or the management of health and social care systems
Common Law Duty of Confidentiality basis
Implied Consent

Greater Manchester ICS pharmacists work with GP practices to provide advice on medicines and prescribing queries, process repeat prescription requests and review prescribing of medicines to ensure that it is safe and cost-effective. This may require the use of identifiable information.

In cases where identifiable data is required, this is done with practice agreement and in the case of repeat prescription processing with patient consent. No data is removed from the practice’s clinical system and no changes are made to patient's records without permission from the GP. Patient records are viewed [insert how they are viewed e.g. remotely via secure laptops from the ICS' premises, in the GP practice, in care homes or patient homes].

Where specialist support is required (e.g. to order a drug that comes in solid form in gas or liquid form) Greater Manchester ICS medicines optimisation pharmacists will order this on behalf of a GP to support your care. Identifiable data is used for this purpose.

Identifiable data is also used by our pharmacists in order to review and authorise (if appropriate) requests for high cost drugs which are not routinely funded. In cases where identifiable data is used, this is done with the consent of the patients.

Child Health Information Services

Type of Data
Personal Data – demographics
Special category of data – Health data
Source of Data
GP Practice
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(e) - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

Article 9 (2)(h) - Processing is 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 and social care or treatment or the management of health and social care systems
Common Law Duty of Confidentiality basis
Implied Consent

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due and we are required to share this information with the Child Health Information Service. We share information about childhood immunisations, and the 6-8-week new baby check. This information is automatically transferred from our Practice’s patient record system to SCW CHIS using software supplied by Apollo Medical Software Solutions Ltd.

Purposes other than direct care (secondary use)

This is information which is used for non-healthcare purposes. Generally this could be for research purposes, audits, service management, safeguarding, commissioning, complaints and patient and public involvement.

When your personal information is used for secondary use this should, where appropriate, be limited and de-identified so that the secondary uses process is confidential.

Safeguarding

Type of Data
Personal Data – demographics
Special category of data – Health data
Source of Data
Patient and other health and care providers
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(e) - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

Article 9 (2)(b) - Processing is necessary for the purposes of carrying out the obligations and exercising the specific rights of the controller or the data subject in the field of …social protection law
Common Law Duty of Confidentiality basis
Overriding Public Interest / children and adult safeguarding legislation

Information is provided to care providers to ensure that adult and children's safeguarding matters are managed appropriately. Access to personal data and health information will be shared in some limited circumstances where it's legally required for the safety of the individuals concerned. For the purposes of safeguarding children and vulnerable adults, personal and healthcare data is disclosed under the provisions of the Children Acts 1989 and 2006 and Care Act 2014.

Risk Stratification

Type of Data
Personal Data – demographics
Special category of data – Health data
Source of Data
Patient and other health and care providers
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(e) - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

Article 9 (2)(b) - Processing is necessary for the purposes of carrying out the obligations and exercising the specific rights of the controller or the data subject in the field of …social protection law
Common Law Duty of Confidentiality basis
Overriding Public Interest / children and adult safeguarding legislation

Risk stratification entails applying computer based algorithms, or calculations to identify those patients who are most at risk from certain medical conditions and who will benefit from clinical care to help prevent or better treat their condition. To identify those patients individually from the patient community would be a lengthy and time-consuming process which would by its nature potentially not identify individuals quickly and increase the time to improve care. A GP / health professional reviews this information before a decision is made.

The use of personal and health data for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (known as Section 251 approval). This approval allows your GP or staff within your GP Practice who are responsible for providing your care, to see information that identifies you, but Greater Manchester ICS staff will only be able to see information in a format that does not reveal your identity.

NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help and prevent avoidable admissions.

Knowledge of the risk profile of our population helps to commission appropriate preventative services and to promote quality improvement.

Risk stratification tools use various combinations of historic information about patients, for example, age, gender, diagnoses and patterns of hospital attendance and admission and primary care data collected in GP practice systems.

Our data processor for Risk Stratification purposes is Dr Laura Neilson.

If you do not wish information about you to be included in our risk stratification programme, please contact the GP Practice. We can add a code to your records that will stop your information from being used for this purpose. Please see the section below regarding objections for using data for secondary uses.

National Clinical Audits

Type of Data
Personal Data – demographics
Special category of data – Health data
Pseudonymised
Anonymised
Source of Data
GP Practice and other care providers
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(c) - Processing is necessary for compliance with a legal obligation

Article 9(2)(h) - Processing is 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 and social care or treatment or the management of health and social care systems

Section 251 NHS Act 2006, NHS Constitution (Health and Social Care Act 2012)

The GP practice contributes to national clinical audits and will send the data which are required by NHS Digital when the law allows. This may include demographic data such as data of birth and information about your health which is recorded in coded form, for example, the clinical code for diabetes or high blood pressure.

Research

Type of Data
Personal Data – demographics
Special category of data – health data
Source of Data
GP Practice
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(e) - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

Article 9 (2)(j) - Processing is necessary for…scientific or historical research purposes…

Common law duty of confidentiality – explicit consent or if there is a legal statute for this which you will be informed of

All NHS organisations (including Health & Social Care in Northern Ireland) are expected to participate and support health and care research. The Health Research Authority and government departments in Northern Ireland, Scotland and Wales set standards for NHS organisations to make sure they protect your privacy and comply with the law when they are involved in research. Our research ethics committees review research studies to make sure that the research uses of data about you are in the public interest, and meet ethical standards.

Health and care research may be exploring prevention, diagnosis or treatment of disease, which includes health and social factors in any disease area. Research may be sponsored by companies developing new medicines or medical devices, NHS organisations, universities or medical research charities. The research sponsor decides what information will be collected for the study and how it will be used.

Health and care research should serve the public interest, which means that research sponsors have to demonstrate that their research serves the interests of society as a whole. They do this by following the UK Policy Framework for Health and Social Care Research. They also have to have a legal basis for any use of personally-identifiable information.

How patient information may be used for research

When you agree to take part in a research study, the sponsor will collect the minimum personally-identifiable information needed for the purposes of the research project. Information about you will be used in the ways needed to conduct and analyse the research study. NHS organisations may keep a copy of the information collected about you. Depending on the needs of the study, the information that is passed to the research sponsor may include personal data that could identify you. You can find out more about the use of patient information for the study you are taking part in from the research team or the study sponsor. You can find out who the study sponsor is from the information you were given when you agreed to take part in the study.

For some research studies, you may be asked to provide information about your health to the research team, for example in a questionnaire. Sometimes information about you will be collected for research at the same time as for your clinical care, for example when a blood test is taken. In other cases, information may be copied from your health records. Information from your health records may be linked to information from other places such as central NHS records, or information about you collected by other organisations. You will be told about this when you agree to take part in the study.

Even though consent is not the legal basis for processing personal data for research, the common law duty of confidentiality is not changing, so consent is still needed for people outside the care team to access and use confidential patient information for research, unless you have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales or similar arrangements elsewhere in the UK

Your choices about health and care research

If you are asked about taking part in research, usually someone in the care team looking after you will contact you. People in your care team may look at your health records to check whether you are suitable to take part in a research study, before asking you whether you are interested or sending you a letter on behalf of the researcher.

In some hospitals and GP practices, you may have the opportunity to sign up to a register to hear about suitable research studies that you could take part in. If you agree to this, then research nurses, researchers or administrative staff authorised by the organisation may look at your health records to see if you are suitable for any research studies.

It’s important for you to be aware that if you are taking part in research, or information about you is used for research, your rights to access, change or move information about you are limited. This is because researchers need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw from a study, the sponsor will keep the information about you that it has already obtained. They may also keep information from research indefinitely.

If you would like to find out more about why and how patient data is used in research, please visit the Understanding Patient Data website.
https://understandingpatientdata.org.uk/what-you-need-know

In England you can register your choice to opt out via the “Your Data Matters” webpage on the link below:

https://www.nhs.uk/your-nhs-data-matters/

If you do choose to opt out you can still agree to take part in any research study you want to, without affecting your ability to opt out of other research. You can also change your choice about opting out at any time.

To find out more about GDPR and using personal data for research, please visit the Health Research Authority website on the link below:

https://www.hra.nhs.uk/hra-guidance-general-data-protection-regulation/

Current Research Projects

Complaints

Type of Data
Personal Data – demographics
Special category of data – health data
Source of Data
Data Subject, Primary Care, Secondary Care and Community Care
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(a) – Explicit Consent

Article 9 (2)(h) - Processing is 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 and social care or treatment or the management of health and social care systems

Common law duty of confidentiality – explicit consent

If you contact the GP Practice about a complaint, we require your explicit consent to process this complaint for you. You will be informed of how and with whom your data will be shared by us, including if you have or you are a representative you wish the GP practice to deal with on your behalf.

Purposes requiring consent

There are also other areas of processing undertaken where consent is required from you. Under GDPR, consent must be freely given, specific, you must be informed and a record must be made that you have given your consent, to confirm you have understood.

Patient and Public Involvement

Type of Data
Personal Data – demographics
Source of Data
GP Practice
Legal basis for processing personal data and Condition for processing special category of data
Article 6 (1)(a) – Explicit Consent

Article 9 (2)(a) – Explicit Consent

NHS App & Messages

We use the NHS Account Messaging Service provided by NHS England to send you messages relating to your health and care. You need to be an NHS App user to receive these messages. Further information about the service can be found at the privacy notice for the NHS App managed by NHS England.

How we protect your personal data

We will use the information in a manner that conforms to the General Data Protection Regulations (GDPR) and Data Protection Act 2018.   The information you provide will be subject to rigorous measures and procedures to make sure it can’t be seen, accessed or disclosed to any inappropriate persons.   We have an Information Governance Framework that explains the approach within the GP practice, our commitments and responsibilities to your privacy and cover a range of information and technology security areas.  

Access to your personal confidential data is password protected on secure systems and securely locked in filing cabinet when on paper.

Our IT Services provider, Greater Manchester Shared Service, regularly monitor our system for potential vulnerabilities and attacks and look to always ensure security is strengthened.

All our staff have received up to date data security and protection training.  They are obliged in their employment contracts to uphold confidentiality, and may face disciplinary procedures if they do not do so. We have incident reporting and management processes in place for reporting any data breaches or incidents.  We learn from such events to help prevent further issues and inform patients of breaches when required.

How long do we keep your personal data?

Whenever we collect or process your data, we will only keep it for as long as is necessary for the purpose it was collected. For a GP practice, we comply with the Records Management NHS Code of Practice which states that we keep records for 10 years after date of death. Following this time, the records are securely destroyed if stored on paper.

Destruction

This will only happen following a review of the information at the end of its retention period. Where data has been identified for disposal we have the following responsibilities:

  • to ensure that information held in manual form is destroyed using a cross cut shredder or contracted to a reputable confidential waste company Shred-It that complies with European Standard EN15713 and obtain certificates of destruction.
  • to ensure that electronic storage media used to hold or process information are destroyed or overwritten to national standards.

How long do we keep your personal data?

As stated above, where your data is being processed for direct care this will be shared with other care providers who are providing direct care to you such as:

  • NHS Trusts / Foundation Trusts
  • GP’s
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Social Care Services
  • Out of hours providers
  • Walk in centres
  • Clinics

We work with third parties and suppliers (data processors) to be able for us to provide a service to you. These include:

  • Emis Web – to provide our electronic clinical system
  • NHS Greater Manchester Shared service – to provide our IT services

There may be occasions whereby these organisations have potential access to your personal data, for example, if they are fixing an IT fault on the system. To protect your data, we have contracts and / or Information Sharing Agreements in place stipulating the data protection compliance they must have and re-enforce their responsibilities as a data processor to ensure you data is securely protected at all times.

We will not disclose your information to any 3rd party without your consent unless:

  • there are exceptional circumstances (life or death situations)
  • where the law requires information to be passed on as stated above
  • required for fraud management – we may share information about fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
  • It is required to be disclosed to the police or other enforcement, regulatory or government body for prevention and / or detection of crime

Where is your data processed?

Your data is processed with the GP surgery and by other third parties as stated above who are UK based. Your personal data is not sent outside of the UK for processing.

Where information sharing is required with a country outside of the EU you will be informed of this and we will have a relevant Information Sharing Agreement in place. We will not disclose any health information without an appropriate lawful principle, unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it, or to carry out a statutory functions i.e. reporting to external bodies to meet legal obligations.

What are your rights over your personal data?

You have the following rights over your data we hold:

  • Subject Access Rights – you can request access to and or copies of personal data we hold about you, free of charge (subject to exemptions) and provided to you within 1 calendar month. We request that you provide us with adequate information in writing to process your request such as full name, address, date of birth, NHS number and details of your request and documents to verify your identity so we can process the request efficiently. On processing a request, there may be occasions when information may be withheld if the organisation believes that releasing the information to you could cause serious harm to your physical or mental health. Information may also be withheld if another person (i.e. third party) is identified in the record, and they do not want their information disclosed to you. However, if the other person was acting in their professional capacity in caring for you, in normal circumstances they could not prevent you from having access to that information.
    To request a copy or request access to information we hold about you and / or to request information to be corrected if it is inaccurate, please contact:
    Mrs Lisa Nolan - lisanolan1@nhs.net
  • Right to rectification - The correction of personal data when incorrect, out of date or incomplete which must be acted upon within 1 calendar month of receipt of such request. Please ensure the GP practice has the correct contact details for you.
  • Right to withdraw consent - If we have your explicit consent for any processing we do, you have the right to withdraw that consent at any time
  • Right to Erasure (‘be forgotten’) - If we obtain consent for any processing we do, you have the right to have that data deleted / erased. Please note this does not apply to health records.
  • Right to Data Portability - If we obtain consent for any processing we do, you have the right to have data provided to you in a commonly used and machine readable format such as excel spreadsheet, csv file.
  • Right to object to processing – you have the right to object to processing however please note if we can demonstrate compelling legitimate grounds which outweighs the interest of you then processing can continue. If we didn’t process any information about you and your health care if would be very difficult for us to care and treat you.
  • Right to restriction of processing - This right enables individuals to suspend the processing of personal information, for example, if you want to establish its accuracy or the reason for processing it.

Complaints / Contacting the Regulator

If you feel that your data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, please contact our Data Protection Officer / Practice Manager at the following contact details:

Email us at: hollinwood@nhs.net

Or write to us at: 1 Clive Street, Hollinwood, Oldham, OL8 3TR .

If you are not happy with our responses and wish to take your complaint to an independent body, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1133

Or go online to www.ico.org.uk/concerns (opens in a new window, please note we can’t be responsible for the content of external websites)

Further Information / Contact Us

We hope that the Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. Should you have any questions / or would like further information, please visit the websites below and / or contact either our Caldicott Guardian / Data Protection Officer / Practice Manager at the following contact details:

Email us at: hollinwood@nhs.net
Or write to us at: 1 Clive Street, Hollinwood, Oldham, OL8 3TR .

Links

If you would like to find out more information on the wider health and care system approach to using personal information or other useful information, please click and / or search for the following on the internet:

Fair Processing Notice

IMPORTANT: CHANGES TO DATA PROCESSING & SHARING FOR A COVID-19 PURPOSE:

This practice is supporting vital coronavirus (COVID-19) planning and research by sharing your data with NHS digital.  This transparency notice supplements our main practice privacy notice.

Please be aware, as we all face the Coronavirus pandemic, there is a newly enforced requirement for the sharing and processing of confidential patient information, in order to manage and mitigate the spread and impact of the current Covid-19 pandemic. This requirement is outlined on this site:

https://digital.nhs.uk/coronavirus/gpes-data-for-pandemic-planning-and-research/general-practice-transparency-notice

As stated in that information, organisations are required to process confidential patient information where the information to be processed is required for a Covid-19 purpose and will be processed solely for that Covid-19 purpose.

Please also note that the attached notice expires on September 30th, 2020 and the regulation will be reviewed on or before that date.

The rest of this Fair Processing Notice describes how your health care data is used under normal circumstances:

How we use your personal information

This fair processing notice explains why the practice collects information about you and how that information may be used.

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. Hospital, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

NHS health 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. Records which this GP Practice hold about you may include the following information:

  • Details about you, such as your address, legal representative, 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 will be retained in accordance with the NHS Code of Practice for Records Management

The Records Management Code of Practice for Health and Social Care 2016 sets out what people working with or in NHS organisations in England need to do to manage records correctly. It's based on current legal requirements and professional best practice and was published on 20 July 2016 by the Information Governance Alliance (IGA).

Appendix 3 of the Code contains the detailed retention schedules. It sets out how long records should be retained, either due to their ongoing administrative value or as a result of statutory requirement. 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 GP practice 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.

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:

  • GDPR 2018
  • Data Protection Act 2018
  • Human Rights Act 2015
  • Common Law Duty of Confidentiality
  • Health and Social Care Act 2012
  • NHS Codes of Confidentiality and Information Security
  • Information: To Share or Not to Share Review (click here to read further information about this)

Every member of staff who works for the Practice or another 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 3rd party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on for example Child/Adult Protection and Serious Criminal Activity.

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 or receive information from the following organisations:

  • NHS Trusts / Foundation Trusts
  • GPs
  • NHS Commissioning Support Units
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Clinical Commissioning Groups
  • Social Care Services
  • NHS Digital
  • Local Authorities
  • Education Services
  • Fire and Rescue Services
  • Police & Judicial Services
  • 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) GDPR 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
  • We are required to respond to you within 30 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

Greater Manchester (GM) Care Record

Each health and care organisation in Greater Manchester collects information about you and keeps records about the care and services they provide. The GM Record pulls together this key information about you from these different health and social care records and displays it in one combined record. This enables health and social care staff to find key information about your care in one place which helps them to make the most informed decisions and provide the best care to you as a patient or service user. It is also essential that health and social care staff have access to the most up to date information including alerts that may be helpful for staff involved in your care.

They also remove or scramble the information that identifies you such as your name, address, and date of birth that that they can use this information to better plan services, make sure that they are providing the best care, and for research into different conditions.

Health Innovation Manchester works across Greater Manchester’s Health and Social Care system and is rolling out the GM Care Record on behalf of its partners.

You can find out more about the GM Care Record here:

https://www.healthinnovationmanchester.com/thegmcarerecord

Objections / Complaints

Should you have any concerns about how your information is managed at the GP Practice, please contact the Practice Manager.  If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) via their website - www.ico.org.uk.

Data Protection Officer

As dictated by the GDPR (General Data Protection Regulations), every public organisation must have a Data Protection Officer. Our DPO is Lisa Nolan and she can be contacted at lisanolan1@nhs.net

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.

Notification

The GDPR/ Data Protection Act 2018 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).

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential is Allana Critchlow.

Who is the Data Protection Officer?

The DPO is Lisa Nolan. She can be contacted via lisanolan1@nhs.net

GP Data for Planning And Research Direction 2021

NHS Digital has been directed to collect, process, analyse and disseminate general practice data to support the purposes set out here:

GP Data for Planning and Research Direction 2021

This is a national initiative and from 1st September 2021, patient data will be extracted from GP systems on a daily basis. Data will be encrypted in transit and pseudonymised.

As this is a statutory obligation, practices are legally obliged to share this data, unless patients have opted out of having their data shared.

If you as patient want to opt out of your data being shared, apart from information used for your direct care, you have the option of registering a Type 1 Opt-out or a National Data Opt-out, or both.

If you wish to register your opt out choice, please use the following link:

Make your choice about sharing data from your health records - NHS

You can also download and complete this form and give it to your GP practice staff.

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Hollinwood MP_White
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1 Clive Street
Hollinwood
Oldham
OL8 3TR

Tel: 0161 357 2070
Email: hollinwood@nhs.net

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