Privacy Statement

The information we hold on you

Our organisation keeps various patient data in relation to the services we provide and commission. This may include, your contact details, and your family contact details, the reasons you seek help, your appointments, if you have a carer, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out by our services, and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this healthcare provider who are appropriately involved in your health care. We may also have information in regards to complaints, significant events and comments and suggestions, also recorded phone calls to our organisation.

When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS data.  Our services and contracted services would access your data through your registered practice.

The majority of the information we hold in our organisation is anonymised data.

Who we share information with

As an organisation that provides services and contracts services, we do not handle all your information ourselves, so we need to delegate this responsibility to others within the organisation and also with our contracted services.

Once you have seen the care provider through one of our services, they will normally send details of the care they have provided you with to your GP practice, and also some information may be passed to us as the contractor, or service provider, which is mostly anonymised.

Your consent to this sharing of data, lays with your registered practice and with those others outside the practice is assumed and is allowed by the Law; however we will gladly discuss this with you in more detail if you would like to know more.

The organisation and service provider staff (clinicians, administration staff) only access the information they need to allow them to perform their function and fulfil their roles.

You have the right to object to our sharing your data in these circumstances but your practice whom you are registered with have an overriding responsibility to do what is in your best interests.

We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.

 

Data Controller

 

 

Jim Fenwick – Jeremy.fenwick@nhs.net

 

Data Protection Officer

 

Mark Steed – mark.steed@nhs.net
Purpose of Processing your personal information

 

Direct Care is care delivered to the individual alone, most of which is provided in your surgery or hospital, but can be provided by our service providers such as our walk-in centres.

After a patient agrees to a referral for direct care elsewhere through their practice, such as a referral to one of our services or service provider’s, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, clinicians, therapists, technicians, etc.

The information that is shared is to enable our healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and/or care.

Lawful Basis for Processing your personal information The processing of personal data in the delivery of direct care and for providers’ administrative purposes within our services, and in support of direct care by our contracted services, is supported under the following Article 6 and 9 conditions of the GDPR:

Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.

Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”

 

 

Recipient or categories of recipients of your personal data The data will be shared with health and care professionals and support staff in your surgery and at other providers (e.g. hospitals) or diagnostic and treatment centres who contribute to your personal care.

In addition, personal data may be shared which is sent to or may be received from providers such as our 8to8 hubs (who provide some evening and weekend appointments on behalf of your practice), 111, walk-in centres, local social services and care services, or other services that we commission or contract with.

In all cases, we ensure the data is supplied is appropriate and within the law.

Your right to object You have the right to object to some or all the information being processed, which is detailed under Article 21.

Please contact the Data Controller at your registered practice to put this into place.

You should be aware that there is a right to raise an objection that is not the same as having an absolute right to have your wishes granted in every circumstance.

You may also note that your treatment at walk-in centres and some of our other services maybe restricted if we cannot access your medical record.

Your right to access and correction You have the right to access the data that is being shared and have any inaccuracies corrected.

There is no right to have accurate medical records deleted except when ordered by a court of Law.

How long do we hold your personal data for? We retain your personal data in line with both national guidance and law, which can be found here:

https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016

Your right to complain Use of personal data is overseen by the Information Commissioners Office, often known as the ICO.

You have to complain or raise concerns with the ICO and they can be contacted via their website:

https://ico.org.uk/global/contact-us/

Or you can also call their helpline:

Tel: 030 3123 1113 (local rate)

Tel: 01625 545 745 (national rate)

 

DOWNLOAD: Privacy Notice BHCIC v1 2018