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 (‘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 Practice Manager Vanessa Allen on 01274 567991
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 is Rachael.Nicholson@bradford.nhs.uk You can contact Vanessa Allen (Practice Manager) on 01274 567991 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.
We, Springfield Surgery (‘the Surgery’) situated at Canalside Health Care Centre, 2 Kingsway, Bingley BD16 4RP, 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 FROM 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 and mobile);
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);
Nurses and other healthcare professionals;
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
Clinical Commissioning Groups;
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.
The key Hub practices are as follows: Shipley Medical Centre BD18 3EG, Picton Medical Practice, Westbourne Green Health Care Centre, Bradford BD8 8RE & The Ridge Medical Practice, Bradford BD7 3JX
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 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.
Primary Care Network
We are a member of The Bingley Bubble Primary Care Network (PCN). This means we will be working closely with a number of other Practices and health and care organisations to provide healthcare services to you.
During the course of our work we may share your information with these Practices and health care organisations/professionals. We will only share this information where it relates to your direct healthcare needs.
When we do this, we will always ensure that appropriate agreements are in place to protect your information and keep it safe and secure. This is also what the Law requires us to do.
If you would like to see the information the PCN holds about you please contact the Data Protection Officer Rachael Nicholson at Bradford CCG, Scorex House, 1 Bolton Road, Bradford. BD1 4AS. See also your rights as a patient listed below.
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 general data Protection Regulation (GDPR)2018 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 contact The Access to Records Department, Springfield Surgery Canalside Health Care Centre, 2 Kingsway, Bingley. BD16 4RP. 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.
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.
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.
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.
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.
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 General data Protection Regulation (GDPR) 2018 says we need a legal basis to handle your personal and healthcare information.
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.
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.
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.
Sometimes the Law obliges us to provide your information to an organisation (see above).
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.
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/.
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.
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 sure 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. This Privacy Notice was last updated on 2nd July 2019
Why we need your information and how it will be used by health staff for your healthcare
The health professionals who work with you to provide your care will keep records about the treatment and support you receive. Having this information available will help these professionals to work together and share vital information about your health and wellbeing needs.
Health and social care professionals will be able to use the information to assess your needs and work in partnership with you to decide the most suitable treatment or support. We also use your information to inform you of services, for example reminding you of an appointment. We do not use your information for marketing purposes.
Who will be controlling your information?
The Practice (we) will be controlling your data and healthcare information.
All of our partners are required to maintain the same standard as the Trust when processing your information.
Each of our partners has a legal duty to protect your personal information and act as data controller. We take your confidentiality very seriously. We are committed to make sure all personal and identifiable information is managed in accordance with the relevant legalisation to ensure your information is safe, secure and confidential.
The data we are sharing
It is important that the Trust has up to date and accurate information about you to make sure you receive the best quality care possible.
Your care record with the Practice contains key information such as:
Personal details – for example your name, address, date of birth and next of kin (such as your parents or guardian(s))
Names of the health and care professionals looking after you
Any medications you are taking
Any allergies you have
Any health concerns about you
Your previous referrals to various services
Dates and reasons for any occasions where you have been admitted to hospital
Appointments and emergency department attendances
Care plans and care packages
Emergency contact details
Personal data from other sources associated with your care
Please be aware that our records may contain information about your parent(s) or guardian(s), if they are named as your next of kin.
What is the lawful basis for sharing your information?
In order for the Practice to process your information, we need what we call a 'lawful basis' to do so. There are a number of lawful bases that the Practice uses to process your data, depending on the information we need to collect.
In the majority of cases, the lawful basis will be for your care. Other bases may be a legal requirement, public task, or a mandatory obligation on the Trust for the protection of individuals. We may also use consent.
How will your information be used and accessed?
Personal information contained in your health records will only be used with a lawful basis.
Only authorised individuals are allowed to access personal information.
The information within your health record is used to provide you with the most suitable care and support that you need. The information in your health record helps professionals make better decisions about your care in conjunction with you and ensure it is safe and effective.
How long do we keep your information?
Records are retained according to NHS guidance and any statutory or legal requirements for prescribed time spans.
Who will see and share your information?
The Practice releases your information to other authorised parties that it has a legal duty to share it with, those who you may have given consent to, those who need to know to continue your care and those who have a lawful basis.
Your information will only be shared with authorised parties who are providing you with direct care, or third parties authorised by the Practice (who do not have a lawful basis), only if you have first given your consent.
? Where disclosure is necessary to safeguard you, or others, or is in the public interest
? Where there is a legal duty to do so, for example a court order or prevention of crime.
Your data might be shared in exceptional circumstances with countries other than the UK, where it is required for continuation of care.
Your rights as a 'Data Subject'
Under the General Data Protection Regulation, you have certain rights:
1. Right to be informed – the Trust will inform you about the information we hold
2. Access to the information the Trust holds about you
3. Access to have the information corrected if it is incorrect (rectification)
4. Right to be forgotten (erasure) – to have all your information removed
5. Right to restrict processing
6. Data portability
7. Right to object to processing or remove consent
8. Rights in relation to automated processing
Some of these rights are dependent on the circumstances around which the information is held.
If at any point you believe the information we hold or process is incorrect, please contact the Data Protection Officer by emailing the details below.
If you wish to raise a concern or a complaint you can do so by contacting the Practice Manager at Springfield Surgery.
If you are not satisfied with the response you receive or believe we are processing your personal data not in accordance with the law, you can make a complaint with the Information Commissioner's Office (ICO): https://ico.org.uk/
If you have a question regarding you or your child's data, please contact:
Rachael Nicholson – Data Protection Officer at Rachael.Nicholson@bradford.nhs.uk or 07395796639