How we use your information
Our Privacy Notice explains why we collect your information and how that information may be used.
Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR).
As your registered GP practice, we are the data controller for any personal data that we hold about you.
What information do we collect and use?
We obtain and hold data for the sole purpose of providing healthcare services to our patients and we will ensure that the information is kept confidential.
We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:
- ‘Personal data’ – this includes, but is not limited to name, date of birth, address, NHS number and next of kin;
- ‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.
Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services). These records may be electronic, a paper record or a mixture of both. We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.
The practice will send text reminders for appointments and for health campaigns such as flu jabs. We will send information to you about the practice in the form of newsletters and other communications, such as patient surveys.
How is the information collected?
Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection. In addition physical information will be sent to the practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.
Who will we share your information with?
In order to deliver and coordinate your health and social care, we may share information with the following organisations:
- Local GP practices in order to deliver extended primary care services
- NHS England, Merton CCG, Merton Federation
- East Merton Primary Care Home
- 111 and out of hours service
- Local social Services and community care services
- Voluntary support organisations commissioned to provide services by Merton CCG
- NHS Digital
Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information that has been collected lawfully. Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.
We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.
Consent and Objections
Do I need to give my consent?
The GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation. However consent is only one potential lawful basis for processing information. Therefore your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice. Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice. Your consent will be documented within your electronic patient record.
What will happen if I withhold my consent or raise an objection?
You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing. Please contact the Practice Manager for further information and to raise your objection.
Health Risk Screening / Risk Stratification
Risk stratification is a process that helps your GP to help you manage your health. By using selected information from your health records, a secure NHS computer system will look at any recent treatments you have had in hospital or in the surgery and any existing health conditions that you have. This will alert your doctor to the likelihood of a possible deterioration in your health
Your GP will use computer based algorithms or calculations to identify their registered patients who are at most risk, with support from the local commissioning Support Unit and/or a third party accredited Risk Stratification provider. The risk stratification contracts are arranged by Merton CCG in accordance with the current Section 251 Agreement. Neither the CSU nor Merton CCG will at any time have access to your personal or confidential data. They will only act on behalf of your GP to organise the risk stratification service with appropriate contractual technical and security measures in place.
You have the right to object to your information being used in this way. However you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.
Sharing of Electronic Patient Records within the NHS
Electronic patient records are kept in most places where you receive healthcare. Our local electronic systems – EMIS enables your record to be shared with organisations involved in your direct care, such as:
- GP practices
- Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
- Child health services that undertake routine treatment or health screening
- Urgent care organisations, minor injury units or out of hours services
- Community hospitals
- Palliative care hospitals
- Care homes
- Mental health trusts
- Social care organisations
The NHS in England uses a national shared record to support safer patient care through providing authorised professionals with fast secure access to essential information about you in an urgent situation where they don’t have access to your detailed record. The core summary care record covers information about your current medications, allergies you suffer from and any bad reactions to medicines that you have previously experienced. Additional details can be added but only with your consent. You may opt-out of this sharing by talking to the practice
To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.
Information may be used for clinical audit to monitor the quality of the service provided. Some of this information may be held centrally and used for statistical purposes e.g. the National Diabetes Audit. Where we do this we take strict measures to ensure that individual patients cannot be identified and the information is anonymised.
National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.
The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 1998.
If you have received treatment within the NHS, the local commissioning Support Unit (CSU) may require access to your personal information to determine which Clinical Commissioning Group is responsible for payment for the treatment or procedures you have received. Information such as your name, address, date of treatment and associated treatment code may be passed onto the CSU to enable them to process the bill. These details are held in a secure environment and kept confidential.
Your Right of Access to Your Records
You are entitled to have access to your medical records. We now do this free of charge by providing patients with on-line access via our IT system’s “Patient Access” utility.
Requests for access can be made online.
You will be able to print your records if they are required by a third party, such as an insurance company or solicitor. Requests for access can be made online.
You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party.
In the event that your feel the Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager.
If you remain dissatisfied with our response you can contact the Information Commissioner’s Office online at www.ico.org.uk
This practice may supply personal health data to comply with its legal obligations from time to time, as directed by the Secretary of State for Health, or other recognised Statutory Authority.
Anonymised data on the use of fit notes is being provided to the HSCIC on behalf of Department of Health, and the Department for Work and Pensions. This will enable the Department for Work and Pensions to undertake research analysis to inform policy relating to employment and sickness absence, including evaluation of Fit for Work.
For more information, please go to the following sites: