GDPR/Privacy

What is a Privacy Notice and why does it apply to me?

A Privacy Notice tells people how organisations use information that they hold about them. A new law called the General Data Protection Regulation 2016, also known as GDPR, says that we need to provide you with this Privacy Notice and let you know:

•  What information we hold about you
• How we keep this very important information safe and secure and where we keep it
• How we use your information
• Who we share your information with
• What your rights are
• When the law gives us permission to use your information

Why does the law give you permission to use my information?

The law gives us permission to use your information in situations where we need it to take care of you. Because information about your health is very personal, sensitive and private to you, the law is very strict about how we use it.

So, before we can use your information in the ways we have set out in this Privacy Notice, we have to have a good reason in law, which is called a ‘lawful basis’.  Not only do we have to do that, but we also have to show that your information falls into a special group or category, because it is very sensitive. By doing this the law makes sure we only use your information to look after you and that we do not use it for any other reason.

If you would like more information about this please ask to speak to our Data Protection Officer (DPO) mentioned in this Privacy Notice who will explain this in more detail.

About Us

We, at Grovehill Medical Centre, Kilbride Court, Hemel Hempstead, are responsible for collecting, storing and handling your information when you registered with us as a patient. Because we do this, the law says we are Data Controllers. Sometimes we may use your information for a particular purpose and when we do so, the law says we are Data Processors.

What information do you hold about me?

We hold information about you such as:

• Your name
• Address
• Mobile number
• Information about your parent(s) or person with parental responsibility
• All your health records
• Appointment records
• Visits to see your GP
• Treatments you have had
• Medicines prescribed for you and any other information to help us look after you

How do you keep it safe?

• The law says that we must do all we can to keep your information private, safe and secure.
• We use secure computer systems and we make sure that any written information held about you is under lock and key and kept in a safe place. This includes taking great care with any passwords we use which we change on a regular basis. We also train our staff to respect your privacy and deal with your information in a manner that makes sure it is always kept and dealt with in a safe way.

What do you do with my information?

• We only usually use your information to help us care for you. That means we might need to share your information with other people who are concerned and involved with looking after your health.
• We might need to share your information with the police, courts, social services, solicitors and other people who have a right to your information, but we always make sure that they have a legal right to see it (or have a copy of it) before we provide it to them.

Who else will see my information?

• Usually only doctors, nurses and other people who work with us are allowed to see your information.
• Sometimes though, if you need to go to the hospital or be seen by a special doctor, we will share your information with them but this only so that we can take care of you.
• Sometimes we might be asked to take part in medical research that might help you in the future. We will always ask you or your parent(s) or adult with parental responsibility if we can share your information if this happens.
• Possibly the police, social services, the courts and other organisations and people who may have a legal right to see your information.

What are my rights?

• If you want to see what information we hold about you then you have a right to see it and you can ask for it.
• To ask for your information you will usually need to put your request in writing and tell us what information you want us to give you.
• We usually need to answer you within one month. Your parent(s) or adult with parental responsibility can help you with is if you need help.
• Usually we will give this to you free of charge.
• If you think there are any errors in the information we hold about you then you can ask us to correct it but the law says we can’t remove any of the information we hold about you even if you ask us to. This is because we need this information to take care of you.
• You have a right to ask us not to share your information.
• If you would like to talk to us about not sharing your information, even if this means you don’t want us to share your information with your parent(s) or adult with parental responsibility, please let us know. We will be happy to help.

Can I access my information online?

• You may be able to access your information online.
• Please ask our receptionist who will put you in touch with your GP.
• Your GP will discuss this with you and explain how to register.

What if I have a question?

• A member of our staff/receptionist will be happy to talk to you about any questions you may have and we will do our best to help you.
• The Surgery has a person called a Data Protection Officer (DPO) who deals with all queries about patient information. Our receptionist may put you in touch with this person who will listen to your concerns and give you the advice you need.
• Our DPO is called X and she/he can be contacted at XXX.

What if I have a serious complaint about how you look after my information?

• We will always do our best to look after your information and to answer your questions.
• If you are still not happy with something we have done with your information you can speak to our DPO.
• If our DPO has not been able to help you or if you prefer not to speak to our DPO then you have a right to pass your complaint to an organisation called the Information Commissioner’s Office (ICO) who will look into what has gone wrong. For more information visit ico.org.uk

Updates to this Privacy Notice

The law says we must keep all information we provide in this Privacy Notice up to date.
Updated on: 02.12.18 by Liz Keenan (Practice Manager) & Manu Wilhelm (Assistant PM & DPO)

General Practice Transparency Notice For GPES Data For Pandemic Planning And Research (COVID-19)

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.

The health and social care system is facing significant pressures due to the coronavirus (COVID-19) outbreak. Health and care information is essential to deliver care to individuals, to support health, social care and other public services and to protect public health. Information will also be vital in researching, monitoring, tracking and managing the coronavirus outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations. This practice is supporting vital coronavirus planning and research by sharing your data with NHS Digital, the national safe haven for health and social care data in England.

For more information, please visit www.digital.nhs.uk.

We understand how important it is to keep your personal information safe and secure and we take this very seriously. We have taken steps to make sure your personal information is looked after in the best possible way and we review this regularly.

Please read this privacy notice carefully, as it contains important information about how we use the personal and healthcare information we collect on your behalf.

Why we are providing this Privacy Notice

We are required to provide you with this Privacy Notice by Law. It explains how we use the personal and healthcare information we collect, store and hold about you. If you are unclear about how we process or use your personal and healthcare information, or you have any questions about this Privacy Notice or any other issue regarding your personal and healthcare information, then please do contact our Data Protection Officer (details below).

The Law says:

• We must let you know why we collect personal and healthcare information about you;
• We must let you know how we use any personal and/or healthcare information we hold on you;
• We need to inform you in respect of what we do with it;
• We need to tell you about who we share it with or pass it on to and why; and
• We need to let you know how long we can keep it for.

The Data Protection Officer

The Data Protection Officer at the Surgery is  Barry Moult. You can contact him at Grovehill Medical Centre, Kilbride Court, Hemel Hempstead, HP2 6AD on Tel No 01442 212 038

If:

• You have any questions about how your information is being held;
• If you require access to your information or if you wish to make a change to your information;
• If you wish to make a complaint about anything to do with the personal and healthcare information we hold about you;
• Or any other query relating to this Policy and your rights as a patient.

About Us

We, at Grovehill Medical Centre situated at Kilbride Court, Hemel Hempstead, Herts, HP2 6AD, are a Data Controller of your information. This means we are responsible for collecting, storing and handling your personal and healthcare information when you register with us as a patient.
There may be times where we also process your information. That means we use it for a particular purpose and, therefore, on those occasions we may also be Data Processors. The purposes for which we use your information are set out in this Privacy Notice.

Information we collect about you

The information we collect from you will include:

• Your contact details (such as your name and email address, including place of work and work contact details);
• Details and contact numbers of your next of kin;
• Your age range, gender, ethnicity;
• Details in relation to your medical history;
• The reason for your visit to the Surgery;
• Medical notes and details of diagnosis and consultations with our GPs and other health professionals within the Surgery involved in your direct healthcare.

Information about you from others

We also collect personal information about you when it is sent to us from the following:

• A hospital, a consultant or any other medical or healthcare professional, or any other person involved with your general healthcare.

Your Summary Care Record

Your summary care record is an electronic record of your healthcare history (and other relevant personal information) held on a national healthcare records database provided and facilitated by NHS England.

This record may be shared with other healthcare professionals and additions to this record may also be made by relevant healthcare professionals and organisations involved in your direct healthcare.

You may have the right to demand that this record is not shared with anyone who is not involved in the provision of your direct healthcare. If you wish to enquire further as to your rights in respect of not sharing information on this record then please contact our Data Protection Officer.

To find out more about the wider use of confidential personal information and to register your choice to opt out if you do not want your data to be used in this way, please visit www.nhs.uk/my-data-choice.

Note if you do choose to opt out, you can still consent to your data being used for specific purposes. However, if you are happy with this use of information you do not need to do anything. You may however change your choice at any time.

Who we may provide your personal information to and why

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care Services, important information about you is collected to help ensure you get the best possible care and treatment. This information may be passed to other approved organisations where there is a legal basis, to help with planning services, improving care, research into developing new treatments and preventing illness. All of this helps in proving better care to you and your family and future generations. However, as explained in this privacy notice, confidential information about your health and care is only used in this way where allowed by law and would never be used for any other purpose without your clear and explicit consent.

We may pass your personal information on to the following people or organisations, because these organisations may require your information to assist them in the provision of your direct healthcare needs. It, therefore, may be important for them to be able to access your information in order to ensure they may properly deliver their services to you:

• Hospital professionals (such as doctors, consultants, nurses, etc);
• Other GPs/Doctors;
• Pharmacists;
• Nurses and other healthcare professionals;
• Dentists;
• Any other person that is involved in providing services related to your general healthcare, including mental health professionals.

Other people who we provide your information to

• Commissioners;
• Clinical Commissioning Groups;
• Local authorities;
• Community health services;
• For the purposes of complying with the law e.g. Police, Solicitors, Insurance Companies;
• Anyone you have given your consent to, to view or receive your record, or part of your record. Please note, if you give another person or organisation consent to access your record we will need to contact you to verify your consent before we release that record. It is important that you are clear and understand how much and what aspects of your record you give consent to be disclosed.  
• Extended Access – we provide extended access services to our patients which means you can access medical services outside of our normal working hours. In order to provide you with this service, we have formal arrangements in place with the Clinical Commissioning Group and with other practices whereby certain key “hub” practices offer this service on our behalf for you as a patient to access outside of our opening hours. This means, those key “hub” practices will have to have access to your medical record to be able to offer you the service. Please note to ensure that those practices comply with the law and to protect the use of your information, we have very robust data sharing agreements and other clear arrangements in place to ensure your data is always protected and used for those purposes only.
• Data Extraction by the Clinical Commissioning Group – the Clinical Commissioning Group at times extracts medical information about you, but the information we pass to them via our computer systems cannot identify you to them. This information only refers to you by way of a code that only your practice can identify (it is pseudo-anonymised). This therefore protects you from anyone who may have access to this information at the Clinical Commissioning Group from ever identify you as a result of seeing the medical information and we will never give them the information that would enable them to do this. There are good reasons why the Clinical commissioning Group may require this pseudo-anonymised information in order to fulfil their duty to commission safe and effective healthcare for the Locality Commissioning Group from ever identifying you as a result of seeing the medical information and we will never give them the information that would enable them to do this.

Anonymised Information

Sometimes we may provide information about you in an anonymised form. If we do so, then none of the information we provide to any other party will identify you as an individual and cannot be traced back to you.

Your rights as a patient

The Law gives you certain rights to your personal and healthcare information that we hold, as set out below:

Access and Subject Access Requests

You have the right to see what information we hold about you and to request a copy of this information.
If you would like a copy of the information we hold about you please email our Data Protection Officer. We will provide this information free of charge however, we may in some limited and exceptional circumstances have to make an administrative charge for any extra copies if the information requested is excessive, complex or repetitive.
We have one month to reply to you and give you the information that you require. We would ask, therefore, that any requests you make are in writing and it is made clear to us what and how much information you require.

Online Access

You may ask us if you wish to have online access to your medical record. However, there will be certain protocols that we have to follow in order to give you online access, including written consent and production of documents that prove your identity.
Please note that when we give you online access, the responsibility is yours to make sure that you keep your information safe and secure if you do not wish any third party to gain access.

Correction

We want to make sure that your personal information is accurate and up to date. You may ask us to correct any information you think is inaccurate. It is very important that you make sure you tell us if your contact details including your mobile phone number has changed.

Removal

You have the right to ask for your information to be removed however, if we require this information to assist us in providing you with appropriate medical services and diagnosis for your healthcare, then removal may not be possible.

Objection

We cannot share your information with anyone else for a purpose that is not directly related to your health, e.g. medical research, educational purposes, etc. We would ask you for your consent in order to do this however, you have the right to request that your personal and healthcare information is not shared by the Surgery in this way. Please note the Anonymised Information section in this Privacy Notice.

Transfer

You have the right to request that your personal and/or healthcare information is transferred, in an electronic form (or other form), to another organisation, but we will require your clear consent to be able to do this.

Third Parties mentioned on your Medical Record

Sometimes we record information about third parties mentioned by you to us during any consultation. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them which may breach their rights to confidentiality are removed before we send any information to any other party including yourself. Third parties can include: spouses, partners, and other family members.

How we use the Information about you

We use your personal and healthcare information in the following ways:

• when we need to speak to, or contact other doctors, consultants, nurses or any other medical/healthcare professional or organisation during the course of your diagnosis or treatment or on going healthcare;
• when we are required by Law to hand over your information to any other organisation, such as the police, by court order, solicitors, or immigration enforcement.

We will never pass on your personal information to anyone else who does not need it, or has no right to it, unless you give us clear consent to do so.

Legal Justification for collecting and using your information

The Law says we need a legal basis to handle your personal and healthcare information.

• Contract: We have a contract with NHS England to deliver healthcare services to you. This contract provides that we are under a legal obligation to ensure that we deliver medical and healthcare services to the public.
• Consent: Sometimes we also rely on the fact that you give us consent to use your personal and healthcare information so that we can take care of your healthcare needs.

Please note that you have the right to withdraw consent at any time if you no longer wish to receive services from us.

• Necessary Care: Providing you with the appropriate healthcare, where necessary. The Law refers to this as ‘protecting your vital interests’ where you may be in a position not to be able to consent.
• Law: Sometimes the Law obliges us to provide your information to an organisation (see above).

Special Categories

The Law states that personal information about your health falls into a special category of information because it is very sensitive. Reasons that may entitle us to use and process your information may be as follows:

• Public Interest: Where we may need to handle your personal information when it is considered to be in the public interest. For example, when there is an outbreak of a specific disease and we need to contact you for treatment, or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment;
• Consent: When you have given us consent;
• Vital Interest: If you are incapable of giving consent, and we have to use your information to protect your vital interests (e.g. if you have had an accident and you need emergency treatment);
• Defending a Claim: If we need your information to defend a legal claim against us by you, or by another party;
• Providing you with medical care: Where we need your information to provide you with medical and healthcare services

How long we keep your Personal Information

We carefully consider any personal information that we store about you, and we will not keep your information for longer than is necessary for the purposes as set out in this Privacy Notice.

If English is not your first language

If English is not your first language you can request a translation of this Privacy Notice. Please contact our Data Protection Officer.

Complaints

If you have a concern about the way we handle your personal data or you have a complaint about what we are doing, or how we have used or handled your personal and/or healthcare information, then please contact our Data Protection Officer.

However, you have a right to raise any concern or complaint with the UK information regulator, at the Information Commissioner’s Office: https://ico.org.uk/.

Our Website

The only website this Privacy Notice applies to is the Surgery’s website. If you use a link to any other website from the Surgery’s website then you will need to read their respective privacy notice. We take no responsibility (legal or otherwise) for the content of other websites.

Cookies

The Surgery’s website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy.

Security

We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secure. We regularly update our processes and systems and we also ensure that our staff are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that if we provide any other services, we carry out proper assessments and security reviews.

Text Messaging and Contacting you

Because we are obliged to protect any confidential information we hold about you and we take this very seriously, it is imperative that you let us know immediately if you change any of your contact details.

We may contact you using SMS texting to your mobile phone in the event that we need to notify you about appointments and other services that we provide to you involving your direct care, therefore you must ensure that we have your up to date details. This is to ensure we are actually contacting you and not another person.

Where to find our Privacy Notice

You may find a copy of this Privacy Notice in the Surgery’s reception, on our website, or a copy may be provided on request.

Changes to our Privacy Notice

We regularly review and update our Privacy Notice.