This is the privacy notice of Gove Medical Centre. In this document, “we”, “our”, or “us” refer to Grove Medical Centre.
Our registered surgery address is at Windlass Place, Deptford , London, SE8 3QH.
This website collects some personal data from users, as stated in our website provider’s Privacy Policy.
Introduction
- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
- Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Information we process because we have a contractual obligation with you
When you join our practice, receive medical services from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- verify your identity for security purposes
- provide you with our services
- provide you with suggestions and advice and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us [at email address or webpage]. However, if you do so, you may not be able to use our website or our services further.
Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business or profession
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage business or professional risk
- protecting your interests where we believe we have a duty to do so
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Information we process may be categorised as special category data
Special category data is personal data which the GDPR says is more sensitive, and so needs more protection. For example information about an individuals:
- race;
- ethnic origin;
- health;
- sex life; or
- sexual orientation.
We may process this information for the purposes of medical diagnosis, provision of health treatment and management of health of our patients and the community we serve.
Specific uses of information you provide to us
Health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records are used to help to provide you with the best possible healthcare.
NHS health care records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records this we hold about you may include the following information;
- Details about you, such as your name, address, carers, legal representatives and emergency contact details
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
- Notes and reports about your health
- Details about your treatment and care
- Results of investigations such as laboratory tests, x-rays, etc.
- Relevant information from other health professionals, relatives or those who care for you
To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the 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.
Risk Stratification
Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information using software and is only provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary your GP may be able to offer you additional services.
Please note that you have the right to opt out of your data being used in this way.
Medicines Management
The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost effective treatments. This service is provided to practices within North Yorkshire through Harrogate and Rural District Clinical Commissioning Group.
Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for [six years] before destroying or deleting it.
Sending a message to our practice team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our practice.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
Complaining
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Use of information we collect through automated systems when you visit our website
Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires on our site while you complete them
[We provide more information about the cookies we use in our cookie policy].
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
Information we obtain from third parties
We sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.
Information provided on the understanding that it will be shared with a third party
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the new information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;
- 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
- Health and Social Care Information Centre (HSCIC)
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Voluntary Sector Providers
- Private Sector Providers
- MediData/EMR+ to process medical reports
- 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.
Data may be processed outside the European Union
Our website is hosted in the United Kingdom.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example online patient forms on our website are encrypted and delivered securely to the NHS system by an email service provider based in the United States of America. Their systems comply with provisions certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, a mechanism for cross border transfer of personal data.
Access to your own information
Access to your personal information
- At any time you may request to review or update personally identifiable information that we hold about you,
- To obtain a copy of any information you may send us a request by email.
- After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at [email address].
This may limit the service we can provide to you.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
Use of our website by children
- If you are under 18, you may use our website only with consent from a parent or guardian
- We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
- Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site information they find, wherever they visit.
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
How you can complain
If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you have any concerns about how your data is shared then please contact the practice.
- If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is [email address].
- [You can find further information about our complaint handling procedure at webpage URL]
- If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
- If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
In accordance with the NHS Codes of Practice for Records Management, your healthcare records will be retained for 10 years after death, or if a patient emigrates, for 10 years after the date of emigration.
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.
Opt-outs
You have a right to object to your information being shared.
If you do not wish your health information shared you have two options:
Type 1 Opt-out: medical records held at your GP practice
You can tell your GP practice if you do not want your confidential patient information held in your GP medical record to be used for purposes other than your individual care. This is commonly called a type 1 opt-out. This opt-out request can only be recorded by your GP.
If you choose a Type 1 opt-out, please inform us in writing.
Type 2 Opt-out: information held by NHS Digital
A Type 2 opt-out is an objection that prevents an individuals personal confidential information from being shared outside of NHS Digital, that is used for research and planning.
Previously you could tell your GP surgery if you did not want NHS Digital to share confidential patient information that is collected from across the health and care service for purposes other than your individual care. This was called a type 2 opt-out.
From 25 May 2018 the type 2 opt-out has been replaced by the national data opt-out. Type 2 opt-outs that have been recorded previously have been automatically converted to national data opt-outs.
To find out more or to make your choice visit: nhs.uk/your-nhs-data-matters
or call 0300 303 5678
and/or view the NHS Digital patient Leaflet
Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
Sending Photos/Images to your GP
With the increased use of online and remote consultations, there may be some occasions where we ask you to send us an image of your area of concern. To protect both our patients and our team, we adhere to strict guidelines about the request, receipt, storage and deletion of any images we ask you to send us.
By law, we cannot receive any images of sensitive areas of any patients under the age of 18. For patients over the age of 18, the law is different and images can be sent but only with the full consent of the patient. However, we would usually agree a different method of consultation if this was your area of concern.
You are not permitted to send any images to us without the express request of the clinician and this request will be documented in the medical record, including the type and location of the authorised image. Any images sent without express permission or that exceed the permission given will be deleted and may be subject to further action.
By sending photos to us you are consenting to them being stored as part of your secure electronic record using the EMIS Web clinical system, which is used by GP Practices all over the UK to securely store patient’s medical records.
To minimise risk to the patient we advise images be sent via AccuRX text messaging technology in preference to being emailed to the practice. Where images are emailed to us we transfer them to patient’s secure EMIS Web record and delete them from our practice email account.
Where and how are photos stored?
Where images are emailed to us we transfer them to patient’s secure EMIS Web record and delete them from our practice email account.
AccuRx data (including photos) is hosted on Microsoft Azure servers in their London Data Centre. All data sent is encrypted when in transit (when it is sent) and at rest (when it is stored). AccuRx follows the Microsoft Azure NHS Blueprint for Platform-as-a-Service web applications, specifically designed for NHS services. Patient images – along with other patient data – are kept in line with the Records Management Code of Practice for Health and Social Care 2016. These require AccuRX to hold records on behalf of GP practices until 10 years after a patient has died. However, we would delete the data earlier than suggested by this code if we are informed that the condition of Article 9(3) GDPR and s. 11(1) Data Protection Act 2018 no longer applies: “that the circumstances in which the processing of personal data is carried out… by or under the responsibility of a health professional or a social work professional”.
Can AccuRx access patient photos?
This is not routinely possible. However, as with other record systems, AccuRX are required to be able to access patient data in exceptional circumstances to fulfil our legal obligations as a data processor, such as assisting the data controller in providing subject access and allowing data subjects to exercise all their other rights under the GDPR. If such access is required, only designated AccuRx staff can access the data we store on the London Microsoft Azure Data Centre servers. Extensive controls are in place, a full audit trail is kept, and no staff member would view any photos as part
of this process.
Is accuRx NHS approved?
AccuRx are an NHS Digital approved supplier.
What security credentials does AccuRx have?
AccuRx has successfully completed NHS Data Security and Protection Toolkit assurance (under NHS ODS code 8JT17), and both the Cyber Essentials and the Cyber Essentials Plus* certification.
AccuRx are fully compliant with DCB0129, which is for manufacturers of health IT software such as accuRx, and we have been assured by NHS Digital against this standard.
Is AccuRx GDPR compliant?
Yes.
The Grove Medical Centre Data Protection Impact Assessment of AccuRX for photo use is available on request.
COVID Privacy notice
Medical Reports/Letters/Subject Access Requests
Our practice has decided to outsource our medical reporting work to an NHS Digital accredited company called MediData.
MediData will be processing your medical report via eMR and providing online access via their secure encrypted portal. By requesting and consenting to a medical report/letter from Grove Medical Centre, we would like you to understand this work is only possible via MediData who would have access to your information and are bound by the same standards of confidentiality and data security as Grove Medical Centre.
If you wish to contact MediData directly, please email mdmc@medi2data.com or call on 03333 055774.
Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.
Please see the South East London CCG Privacy Notice for information on how we share information with them to provide better care.
https://selondonccg.nhs.uk/privacy-policy/https://selondonccg.nhs.uk/privacy-policy/
List of Data Processors & activities:
- South East London ICB
Purpose – Anonymous data is used by the Integrated Care Board (ICB) for planning, performance and commissioning purposes, as directed in the practices contract, to provide services as a public authority.
Legal Basis –
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’
Patients may opt out of having their personal confidential data used for Planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/ to apply a National Data Opt Out
- NHS England
Summary Care Record (including additional information)
Purpose –The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.
Legal Basis –
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’
Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that by opting out of having your information shared with the Summary Care Record could result in a delay care that may be required in an emergency.
- South East London ICB
Individual Funding Requests
Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our standard NHS contract.
The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time but this may affect the decision to provide individual funding.
Legal Basis –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’
Data processor – South East London ICB
- Lewisham & southwark Council Safeguarding Adults Teams
Safeguarding Adults
Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of individuals.
Consent is not required to share information for this purpose.
Legal Basis – Direct Care under UK 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
- Lewisham & Southwark Council Safeguarding Children Teams, Named professionals for Safeguarding Lewisham & Southwark
Safeguarding Children
Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children.
Legal Basis – 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’
Consent may not be required to share this information.
- Public Health England/NHS England
Public Health, Screening programmes (identifiable), Notifiable disease information (identifiable)
Smoking cessation (anonymous), Sexual health (anonymous), Vaccination programmes.
Personal identifiable and anonymous data is shared.
Purpose –The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service to name a few. The law allows us to share your contact information, and certain aspects of information relating to the screening with Public Health England so that you can be appropriately invited to the relevant screening programme.
More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes or speak to the practice.
Patients may not opt out of having their personal information shared for Public Health reasons.
Patients may opt out of being screened at the time of receiving an invitation.
Legal Basis –
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’
- Care providers including but not limited to Lewisham & Greenwich NHS trust, Guys & St Thomas NHS Trust, North Lewisham Primary Care Network, One Health Lewisham GP Federation
Direct Care/NHS Trusts/Other Care Providers
Purpose – Personal information is shared with other secondary care trusts and providers in order to provide you with direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.
Legal Basis – The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following:
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
- Care Quality Commission
Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.
More detail on how they ensure compliance with data protection law (including GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy-statement
Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.”
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
- Cerner
Population Health Management
Purpose – Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data in order to:
Understand the health and care needs of the care system’s population, including health inequalities
Provide support to where it will have the most impact
Identify early actions to keep people well, not only focusing on people in direct contact with services, but looking to join up care across different partners.
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data. NB only organisations that provide your care will see your identifiable data.
Legal Basis –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
- NHS England, South East London ICB, Public Health
Payments, Invoice validation
Purpose – Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QUOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.
Legal Basis – 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
- EMIS Web, NHS England
Patient record data base
Purpose –Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date. Your record will follow you as you change surgeries throughout your life.
Closed records will be archived by NHS England.
Legal Basis –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’
- EMR+ (Medidata), solicitors, insurance companies, other organisations
Medical reports
Subject Access Requests
Purpose –Your medical record or information from it may be shared in order that:
Solicitors/persons acting on your behalf can conduct certain actions as instructed by you.
Insurance companies seeking a medical reports where you have applied for services offered by then can have a copy to your medical history for a specific purpose.
Your current or potential employers can undertake occupational health checks.
Councils can verify if you meet the criteria for certain services such as tax reduction or disabled bus passes.
Legal Basis –Articles 6(1)(a) and 9(1)(h) – explicit consent
- South East London ICB Medicines Management Team
Purpose – your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes can be implemented.
Legal Basis – 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’
- North Lewisham Primary Care Network (PCN)
Purpose – Your medical record will be shared with the North Lewisham PCN in order that they can provide direct care services to the patient population.
Legal Basis – 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’
- One Health Lewisham GP Federation
Purpose – Your medical record will be shared with the North Lewisham PCN in order that they can provide direct care services to the patient population.
Legal Basis – 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’
- Lewisham & Greenwich NHS Trust
Smoking Cessation
Purpose – personal information is shared in order for the smoking cessation service to be provided.
Only those patients who wish to be party to this service will have their data shared .
Legal Basis – 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’
- Social Prescribing Provider as contracted by North Lewisham PCN (at time of writing Joy)
Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their health social care needs.
Only those patients who wish to be party to this service will have their data shared
Legal Basis – 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’
- Police
Purpose – Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared consent will not always be required.
The Police will require the correct documentation in order to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime. Or where the information is necessary to protect a person or community.
Legal Basis –Article 6(1)(c) – to comply with a legal obligation; and
Article 9(2)(j) – ‘for reasons of substantial public interest’
- The Coroners Office
Purpose – Personal health records or information relating to a deceased patient may be shared with the coroner.
Legal Basis – UK GDPR Article 6(1)(c) – to comply with a legal obligation and article 9(2)(h) health data
- Medical Examiners service, Lewisham & Greenwich NHS Trust
Medical Examiners
Purpose: Purpose: Medical records associated with deceased patients are outside scope of the UK GDPR. However, next of kin details are within the scope of the UK GDPR. We will share specified deceased patient records and next of kin details with the Medical Examiners within Surrey & Sussex Healthcare Trust.
Legal Basis: Article 6(1)(c) – necessary under a legal obligation to which the controller is subject”; and
Article 9(2)(h)– “processing is necessary for the purposes of preventive 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”
- Private healthcare providers- As requested by the patient
Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with private providers.
Legal Basis – Articles 6(1)(a) and 9(2)(a) Consented and under contract between the patient and the provider
- AccuRX, NHS App, Patient Access
Messaging Service
Purpose – Personal identifiable information shared with the messaging service in order that messages including; appointment reminders; results; campaign messages related to specific patients health needs; and direct messages to patients, can be transferred to the patient in a safe way.
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.
Legal Basis –
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’
- AccuRX
Remote consultation
Including – Video Consultation
Clinical photography
Purpose – Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice.
Legal Basis –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’
Patients may be videoed or asked to provide photographs with consent. There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children.
- Microsoft Teams
MDT meetings and information sharing
Purpose – For some long term conditions, 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. Personal data will be shared with other agencies in order that mutual care packages can be decided. Microsoft Teams is also used for information sharing by the practice team
Legal Basis –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’
- NHS England
General Practice Extraction Service (GPES)
At risk patients data collection Version 3
Covid-19 Planning and Research data
CVDPREVENT Audit
Physical Health Checks for people with Severe Mental Illness
Purpose – GP practices are required by law to provide data extraction of their patients personal confidential information for various purposes by NHS Digital. The objective of this data collection is on an ongoing basis to identify patients registered at General Practices who fit within a certain criteria, in order to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction, by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work:
At risk patients including severely clinically vulnerable
Covid-19 Planning and Research data, to control and prevent the risk of Covid-19
NHS England has directed NHS Digital to collect and analyse data in connection with Cardiovascular Disease Prevention Audit
GPES Physical Health Checks for people with Severe Mental Illness (PHSMI) data collection.
Legal Basis – All GP Practices in England are legally required to share data with NHS Digital for this purpose under section 259(1)(a) and (5) of the Health and Social Care Act 2012.
Further detailed legal basis can be found in each link.
Any objections to this data collection should be made directly to NHS Digital. enquiries@nhsdigital.nhs.uk
- Community Pharmacy of choice
Medication/Prescribing
Purpose : Prescriptions containing personal identifiable and health data will be shared with chemists/pharmacies, in order to provide patients with essential medication or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Where patients have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver medication.
Legal Basis –
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’
- RCGP, HEE, iConnect, Fourteen Fish
Professional Training
Purpose – We are a training surgery. Our clinical team are required to be exposed to on the job, clinical experience, as well as continual professional development. On occasion you may be asked if you are happy to be seen by one of our GP registrars, pharmacists or other clinical team to assist with their training as a clinical professional. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE.
Legal Basis –Article 6(1)(a) consent, patients will be asked if they wish to take part in training sessions.
Article 9(2)(a) – explicit consent will be required when making recordings of consultations
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’
Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.
- Surgery Connect (Xon)
Telephony
Purpose – The practice use an internet based telephony system that has the capacity to record telephone calls. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients.
Legal Basis – While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way.
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’
- LeDeR, South East London ICB, NHS England
LeDer
Purpose: The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with this criteria will be shared with NHS England.
Legal Basis: It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information without the patient’s consent.
- NHS England
Shared Care Record
Purpose: In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP Connect, which is managed by NHS Digital, to enable a shared care record, which will assist in patient information to be used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population.
Where data is used for secondary uses, no personal identifiable data will be used.
Where personal confidential data is used for research, explicit consent will be required.
Legal Basis – 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’
- London Shared Care
Purpose: 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 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.
Legal Basis –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’
- Pinnacle, community pharmacies
Community Pharmacy Consultation Service/Pharmacy First
Purpose: Where a referral is made to a community pharmacist, limited information about the patient and their presenting condition will be shared with the pharmacy to whom they will be referred. This is required to enable the community pharmacist to provide a consultation and provide a summary record (known as a post-even message) back to their GP.
Legal Basis –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’
- Iron Mountain
Off Site Storage of medical records
Purpose: The practice has commissioned the services of an offsite storage facility to provide secure offsite storage for all Lloyd George medical records. The facility has met the NHS standard as a supplier of this service. The practice can assure patients that their medical records will remain in control of the practice and robust mechanisms are in place to protect the security of the patients personal confidential data.
Legal Basis: The movement and storage of patient records will be undertaken by contractual obligation between the practice and the companies undertaking the work.
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’
- Klinik
Purpose: The practice has contracted the use of an interactive online consultation system, which is provided by an independent provider, to allow patients to provide various information to the surgery. All data is protected during transit and remains under control of the practice.
Legal Basis: the practice is obliged to provide alternative methods of communication to the surgery as a requirement within their contract.
Article 6(1)(a) consent
Article 9(2)(a) – explicit consent
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’
