In accordance with the Data Protection Act 1998 and Access to Health Records Act, patients may request to see their medical records.

Such requests should be made through the site manager and may be subject to an administration charge.

No information will be released without the patient consent unless we are legally obliged to do so.

What is a complaint?

Its’ recognised that this is not always easy to determine, however, it is usually when someone voices their dissatisfaction with the service provided and where a response is required.

Common causes of Complaint:

• Clinical care and treatment
• Failure to diagnose
• Attitude of health professional and/or staff
• Delay to visit/Unable to get an appointment/Not being seen on time
• Failure to refer
• Poor communication
• Breach of Confidentiality
• Practice Administration

What do Patients Want?

• To be listened to, to have their concerns taken seriously
• An apology
• An explanation of the events
• Reassurance that things will be put right

Who Can Complain?

• Anyone who is receiving or has received NHS treatment or services including minors i.e. under 16.

What to do if a patient makes a complaint:

Some complaints can be dealt with on the spot e.g. prescription not ready or sent to chemist in error, forms or letters not ready for collection etc.

Apologise to the patient and show empathy (let them know that you understand how they feel). Remember to stay calm and speak softly even if the patient is abusive.

Collect as much information as you can about the patient (name address telephone etc.) and their problem. Confirm the information with the patient.

Investigate the problem in an effort to try to identify possible solutions and if possible provide the patient with an explanation.

Agree with the patient a way forward.  This can sometimes be difficult if patients are very upset and are not happy with any of your suggestions in which case it may useful to ask the patient how they would like to see the matter resolved.

Ensure that you follow through any agreed action and check that the patient is happy with the solution.

If you are unable to satisfy the patient please make the patient aware of the PALS (Patient Advice and Liaison Service) who may be able to help, particularly useful for patients who do not wish to make a formal complaint.

Provide the patient with a copy of the NHS Complaints Procedure, which can be located in the red complaints/suggestions file in reception.

Record the incident in the red complaints/suggestions file.

We can learn from our mistakes.  The complaints will be reviewed and used as a tool to improve our services.

Complaints that are Not Easy to Resolve:

These include more serious complaints such as, complaints against a GP or member of staff, breach of confidentiality, clinical matters etc.  These patients should be given a copy of the NHS complaints procedure and referred to the Practice Manager. If the complaint is about the practice manager, please refer to the Senior Partner.

Complaints Procedure

The practice operates an internal complaints procedure known as local resolution.  The practice aims to give you a quick but thorough response to your complaint.

Anyone who is receiving or has received NHS treatment or services can make a complaint.

If you are unable to make your complaint yourself, then someone else such as a relative or a friend can complain for you.  If you are aged 16 or over your representative will need your written consent.

If you are complaining on behalf of a patient that has died you will need to provide a letter of administration or proof that you are the executor of the will.

It is important to make your complaint as soon as possible after the problem arises.

1. Complaints may be made verbally or in writing to the Practice Manager.

1. Your complaint will be recorded and acknowledged within 3 working days.

1. Your complaint will be investigated thoroughly and fairly.

1. As per the NHS England Complaints Resolution guidelines;

1. Inline with the NHS England’s complaints policy, we aim to respond within 40 working days. If no response is provided within six months, we will write to the complainant to explain the reasons for the delay and outline when they can expect to receive the response. At the same time, we will notify the complainant of their right to approach the PHSO without waiting for local resolution to be completed

If we are unable to satisfy the complainant through local resolution, or the complainant is unhappy with our response, they have the right to take their complaint to the Health Service Ombudsman. The Ombudsman is independent of the government and the NHS. You can contact their helpline on 03450154033, email phso.enquiries@ombudsman.org.uk, fax 03000614000 or via post Millbank Tower, Millbank, London, SW1P 4QP. Further information about the Ombudsman is available at www.ombudsman.org.uk 

 Changes to making complaints from 1^st July 2023

from 1 July 2023, the way members of the public make a complaint about primary care services to the commissioner is changing.

There are two ways members of the public can make a complaint:

• You can complain to the healthcare provider: for example, a GP surgery
• You can complain to the commissioner of the service

West London instead of NHS England.

They will need to do this by:

• Telephone: 020 3350 4567 (This is an automated service. Please leave a

message requesting a call back)

• E-mail: nhsnwl.complaints@nhs.net
• Writing to us at: Complaints Manager, NHS North West London, 15 Marylebone

Road, London NW1 5JD

The practice complies with data protection and access to medical records legislation. Identifiable information about you will be shared with others in the following circumstances:

• To provide further medical treatment for you e.g. from district nurses and hospital services.
• To help you get other services e.g. from the social services department. This requires your consent.
• When we have a duty to others e.g. in child protection cases. Anonymised patient information will also be used at local and national level to help the Health Policy makers and Government plan services e.g. for diabetic care.

If you do not wish that anonymous information about you be used in such a way, please let us know.

Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.

Information about the General Practioners and the practice, required for disclosure under this act, can be made available to the public. All requests for such information should be made to the site manager.

This practice is supporting vital coronavirus (COVID-19) planning and research by sharing your data with NHS Digital.

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.

NHS Digital will analyse the data they collect and securely and lawfully share data with other appropriate organisations, including health and care organisations, bodies engaged in disease surveillance and research organisations for coronavirus response purposes only.

These purposes include protecting public health, planning and providing health, social care and public services, identifying coronavirus trends and risks to public health, monitoring and managing the outbreak and carrying out of vital coronavirus research and clinical trials.

The British Medical Association, the Royal College of General Practitioners and the National Data Guardian are all supportive of this initiative.

NHS Digital has various legal powers to share data for purposes relating to the coronavirus response.

It is also required to share data in certain circumstances set out in the COVID-19 Direction and to share confidential patient information to support the response under a legal notice issued to it by the Secretary of State under the Health Service (Control of Patient Information) Regulations 2002 (COPI Regulations).

Legal notices under the COPI Regulations have also been issued to other health and social care organisations requiring those organisations to process and share confidential patient information to respond to the coronavirus outbreak.

Any information used or shared during the outbreak under these legal notices or the COPI Regulations will be limited to the period of the outbreak unless there is another legal basis for organisations to continue to use the information.

Data which is shared by NHS Digital will be subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the coronavirus purpose will be shared.

Organisations using your data will also need to have a clear legal basis to do so and will enter into a data sharing agreement with NHS Digital. Information about the data that NHS Digital shares, including who with and for what purpose will be published in the NHS Digital data release register.

For more information about how NHS Digital will use your data please see the NHS Digital Transparency Notice for GP Data for Pandemic Planning and Research (COVID-19).

The application of the National Data Opt-Out to information shared by NHS Digital will be considered on a case by case basis and may or may not apply depending on the specific purposes for which the data is to be used.

This is because during this period of emergency, the National Data Opt-Out will not generally apply where data is used to support the coronavirus outbreak, due to the public interest and legal requirements to share information.

NHS Digital has been legally directed to collect and analyse patient data from all GP practices in England to support the coronavirus response for the duration of the outbreak.

NHS Digital will become the controller under the General Data Protection Regulation 2016 (GDPR) of the personal data collected and analysed jointly with the Secretary of State for Health and Social Care, who has directed NHS Digital to collect and analyse this data under the COVID-19 Public Health Directions 2020 (COVID-19 Direction).

All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the data provision notice issued by NHS Digital to GP practices.

Under GDPR our legal basis for sharing this personal data with NHS Digital is Article 6(1)(c) – legal obligation. Our legal basis for sharing personal data relating to health, is Article 9(2)(g) – substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the COVID-19 Direction.

The NHS prescription charge is a flat-rate amount which successive Governments have thought it reasonable to charge for those who can afford to pay for their medicines.

Extensive exemption and remission arrangements protect those likely to have difficulty in paying charges (NHS prescription and dental charges, optical and hospital travel costs).

If you think you may be exempt please ask for a medical exemption form from your pharmacist or doctor.

Prescription prepayment certificates (PPCs) offer real savings for people who need several items of  medication on a regular basis.

You can also speak to your pharmacist for further information.

Charges

• Prescription (per item): £9.15
• 12-month prepayment certificate (PPC): £105.90
• 3-month PPC: £29.65

If you will have to pay for four or more prescription items in three months, or more than 15 items in 12 months, you may find it cheaper to buy a PPC .

To order a pre-payment certificate:

Telephone advice and order line 0845 850 0030

General Public – Buy or Renew a PPC On-line

There is further information about prescription exemptions and fees on the NHS website

Useful leaflets and posters

Conditions that could be self-managed and items that should not be routinely prescribed in Primary Care

Medicines that can be purchased without a prescription

Ordering repeat prescriptions online

Be in the know about repeat prescription requests

Repeat prescriptions; requesting your repeat prescriptions

Data Protection Privacy Notice for Patients

 Introduction:

 This privacy notice lets you know what happens to any personal data that you give to us, or any information that we may collect from you or about you from other organisations.

This privacy notice applies to personal information processed by or on behalf of the practice.

This Notice explains

• Who we are and how we use your information
• Information about our Data Protection Officer
• What kinds of personal information about you we hold and use (process)
• The legal grounds for our processing of your personal information (including when we share it with others)
• What should you do if your personal information changes?
• For how long your personal information is retained / stored by us?
• What are your rights under Data Protection laws

The UK General Data Protection Regulation (UKGDPR) and the Data Protection Act 2018 (DPA 2018) became law on 25th May 2018, and 1^st January 2021 when the UK exited the EU.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (UK) 2016/679) (the “UKGDPR”), and the Data Protection Act 2018 the practice responsible for your personal data is Heathrow Medical Centre.

This Notice describes how we collect, use and process your personal data, and how in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

How we use your information and the law.

Heathrow Medical Centre will be what’s known as the ‘Controller’ of your personal data.

We collect basic personal data about you and location-based information.  This does include name, address and contact details such as email and mobile number etc.

We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare setting) ethnicity and sex life information that are linked to your healthcare, we may also receive this information about you from other health providers or third parties.

Why do we need your information?

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously.  These records help to provide you with the best possible healthcare and treatment.

NHS health records may be electronic, paper-based or a mixture of both.  We use a combination of working practices and technology to ensure that your information is kept confidential and secure.

Records about you may include the following information;

• Details about you, such as your address, your carer or legal representative and emergency contact details.
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments.
• 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.
• Contact details (including email address, mobile telephone number and home telephone number)

To ensure you receive the best possible care, your records are used to facilitate the care you receive, including contacting you. Information held about you may be used to help protect the health of the public and to help us manage the NHS and the services we provide. Limited information may be used within the GP practice for clinical audit to monitor the quality of the service we provided.

How do we lawfully use your data?

We need your personal, sensitive and confidential data in order to provide you with healthcare services as a General Practice, under the General Data Protection Regulation we will be lawfully using your information in accordance with: –

Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”

Article 9, (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

This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.

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.
• In a de-identified form to support planning of health services and to improve health outcomes for our population

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 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

GP Connect System and Data Sharing

Heathrow Medical Centre has signed the National Data Sharing Arrangement (NDSA) for GP connect. GP Connect helps clinicians gain access to GP patient records during interactions away from a patient’s registered practice and makes their medical information available to appropriate health and social care professionals when and where they need it, to support the patient’s direct care.

From a privacy, confidentiality and data protection perspective, GP Connect provides a method of secure information transfer and reduces the need to use less secure or less efficient methods of transferring information, such as email or telephone.

GP Connect – key points.

• GP Connect can only be used for direct care purposes.
• Individuals can opt out of their GP patient record being shared via GP Connect by contacting their GP practice.
• Access to GP Connect is governed by role-based access control (RBAC) and organisational controls; only people who need to see the GP patient record for a patient’s direct care should be able to see it
• All systems that allow the use of GP Connect must undergo a robust compliance process and the organisations involved must sign a connection agreement holding them to high standards of information security.

GP Connect products can help health and social care professionals share, view or act on information that could be required for a patient’s direct care, but they would otherwise have difficulty accessing easily (for example if they are using different IT systems).

Organisations can have access to relevant information in GP patient records to provide direct care to patients only.

Type of organisations that use GP Connect

Examples of organisations that may wish to use GP connect to view GP patient records include:

• GP surgeries that patients are not registered at – for example, if they need to see a doctor when they are away from home
• secondary care (hospitals) if they need to attend A&E or are having an operation
• GP hubs/primary care networks (PCNs)/integrated care systems (ICSs), partnerships between healthcare providers and local authorities
• local ‘shared care‘ record systems
• ambulance trusts, so paramedics can view GP patient records in an emergency
• healthcare professionals such as community services
• acute and emergency care service providers
• NHS 111
• pharmacies
• optometrists
• dentistry
• mental health trusts
• hospices
• adult and children’s social care
• care and nursing homes

All access to your GP patient record is stored within an audit trail at your GP practice and within the organisation that information has been shared with.

Confidentiality

Confidentiality and trust are essential to the relationship between GPs and their patients.

The information a patient provides to their GP is confidential, and they can expect that any information that is shared for their direct care will remain confidential.

GP Connect relies on ‘implied consent’.

Explicit consent is not required when information is shared for a direct care purpose. If a patient does not want their information to be shared using GP Connect, they can opt out.

The NDSA and its terms and conditions stipulate that any information received or accessed about a patient for direct care purposes must remain confidential.

In addition to the NDSA, health and social care professionals are also subject to their own professional codes of confidentiality and are aware that any information received via GP Connect is provided in confidence, which must be respected.

Organisations using GP Connect are notified of their duty as ‘controllers’ to be fair and transparent about their processing of their patients’ information and to ensure that their transparency notices are fully updated with how they may be using GP Connect functionality.

NHS England helps support the mitigation of information sharing risks by ensuring that:

• NHS England audit data access is subject to two-factor authentication and role-based access controls – only certain assured users can have access to the full audit logs
• a completed Supplier Conformance Assessment List (SCAL) which covers service and capability specific compliance requirements and controls of the consumer system is in place

It is the responsibility of organisations using GP Connect to ensure that they comply with the NDSA, and their statutory and legal obligations regarding data protection and confidentiality.

Opting out of GP Connect

If patients do not wish their information to be shared using GP Connect, they can opt out by contacting their GP practice.

National Data Opt-Out

The National Data Opt-out is a service that allows patients to opt out of their confidential patient information being used for research and planning.

The National Data Opt-out only applies to any disclosure of data for purposes beyond direct care, so having National Data Opt-out will not prevent your GP patient record being shared via GP Connect.

Risk Stratification 

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from several sources including NHS Trusts and from this GP Practice. The identifying parts of your data are removed, analysis of your data is undertaken, and a risk score is then determined. This is then 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 in most circumstances, please contact the practice for further information about opt out.

Individual Risk Management at a GP practice level however is deemed to be part of your individual healthcare and is covered by our legal powers above.

Transferring the current paper medical records into patients’ electronic medical records.

The following provisions of the General Data Protection Regulation permit us to digitise existing paper medical records:

Article 6(1)(e) – ‘processing is necessary…in the exercise of official authority vested in the controller…’’

Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’

The paper patient records will be shared with [Scanning provider], who will scan and digitise the current paper medical records before destroying them.  The paper patient records will be shared with the scanning provider above, who will scan and digitise the current paper medical records before destroying them.

Anonymised information

Sometimes we may provide information about you in an anonymised form. Such information is used analyse population- level heath issues, and helps the NHS to plan better services. If we share information for these purposes, then none of the information will identify you as an individual and cannot be traced back to you.

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. The reviews are carried out by the ICBs Medicines Management Team under a Data Processing contract with the Practice.

Research – National Institute for Health & Social Care Research (NIHR) – Clinical Research Network 
All NHS Staff members who have been allocated to work within the Practice will be issued with a Letter of access or assurance to confirm individual study placements and pre-employment checks.

The legal bases for processing this information
NIHR processes data under the instruction of the individual research protocol, as delegated by the practice (data controller). You can opt out of being invited to participate in research at any time, please inform a member of the practice team and we will add the appropriate opt out code to your record.

Prior to informed consent:
The legal basis which allows us to process your personal data for research is GDPR article 6 (1)(f) …legitimate interests…except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject…’

Once informed consent has been given:
The legal basis which allows us to process your personal data is informed consent – Article 6 1(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes; and Article 9 (2) (a) the data subject has given explicit consent to the processing those personal data for one or more specified purposes.

Individual study consent forms will detail how to withdraw consent and who to contact, this will usually be via the study sponsor.

Categories of personal data
The data processed by NIHR delivery staff, in addition to demographic and contact details, is likely to be special category information (such as health information) to determine eligibility for individual research studies.

Recipients of data
The data processed by NIHR delivery staff will be used to invite potentially eligible patients into research studies. Once patients have consented to participate, data processed by the NIHR delivery staff will be used to answer the research questions as outlined in individual research protocols.

For further information, please refer to the Clinical Research Network West Midlands Privacy Notice: https://local.nihr.ac.uk/documents/crn-wm-privacy-notice-march-2021/27187

Summary Care Records

All patients registered with a GP have a Summary Care Record, unless they have chosen not to have one. The information held in your Summary Care Record gives registered and regulated healthcare professionals, away from your usual GP practice, access to information to provide you with safer care, reduce the risk of prescribing errors and improve your patient experience.

Your Summary Care Record contains basic (Core) information about allergies and medications and any reactions that you have had to medication in the past.

Some patients, including many with long term health conditions, previously have agreed to have Additional Information shared as part of their Summary Care Record. This Additional Information includes information about significant medical history (past and present), reasons for medications, care plan information and immunisations.

Change to information held in your Summary Care Record

In light of the current emergency, the Department of Health and Social Care has removed the requirement for a patient’s prior explicit consent to share Additional Information as part of the Summary Care Record.

This is because the Secretary of State for Health and Social Care has issued a legal notice to healthcare bodies requiring them to share confidential patient information with other healthcare bodies where this is required to diagnose, control and prevent the spread of the virus and manage the pandemic. This includes sharing Additional Information through Summary Care Records, unless a patient objects to this.

If you have already expressed a preference to only have Core information shared in your Summary Care Record, or to opt-out completely of having a Summary Care Record, these preferences will continue to be respected and this change will not apply to you. For everyone else, the Summary Care Record will be updated to include the Additional Information. This change of requirement will be reviewed after the current coronavirus (COVID-19) pandemic.

Why we have made this change

In order to look after your health and care needs, health and social care bodies may share your confidential patient information contained in your Summary Care Record with clinical and non-clinical staff in other health and care organisations, for example hospitals, NHS 111 and out of hours organisations. These changes will improve the healthcare that you receive away from your usual GP practice.

Your rights in relation to your Summary Care Record

Regardless of your past decisions about your Summary Care Record preferences, you will still have the same options that you currently have in place to opt out of having a Summary Care Record, including the opportunity to opt-back in to having a Summary Care Record or opt back in to allow sharing of Additional Information.

You can exercise these rights by doing the following:

1. Choose to have a Summary Care Record with all information shared. This means that any authorised, registered and regulated health and care professionals will be able to see a detailed Summary Care Record, including Core and Additional Information, if they need to provide you with direct care.
2. Choose to have a Summary Care Record with Core information only. This means that any authorised, registered and regulated health and care professionals will be able to see limited information about allergies and medications in your Summary Care Record if they need to provide you with direct care.
3. Choose to opt-out of having a Summary Care Record altogether. This means that you do not want any information shared with other authorised, registered and regulated health and care professionals involved in your direct care. You will not be able to change this preference at the time if you require direct care away from your GP practice. This means that no authorised, registered and regulated health and care professionals will be able to see information held in your GP records if they need to provide you with direct care, including in an emergency.

To make these changes, you should inform your GP practice or complete this form and return it to your GP practice.

Patient Communication

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 if 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 contacting you and not another person. As this is operated on an ‘opt out’ basis we will assume that you give us permission to contact you via SMS if you have provided us with your mobile telephone number. Please let us know if you wish to opt out of this SMS service. We may also contact you using the email address you have provided to us. Please ensure that we have your up-to-date details.

There may be occasions where authorised research facilities would like you to take part in research. Your contact details may be used to invite you to receive further information about such research opportunities.

The NHS App

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.

Safeguarding

The Practice is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently and conscientiously applied with the wellbeing of all, at the heart of what we do.

Our legal basis for processing For the General Data Protection Regulation (GDPR) purposes is: –

Article 6(1)(e) ‘…exercise of official authority…’.

For the processing of special categories data, the basis is: –

Article 9(2)(b) – ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law…’

Research

Clinical Practice Research Datalink (CPRD) collects de-identified patient data from a network of GP practices across the UK. Primary care data are linked to a range of other health related data to provide a longitudinal, representative UK population health dataset.  You can opt out of your information being used for research purposes at any time (see below), full details can be found here: –

https://cprd.com/transparency-information

The legal bases for processing this information

CPRD do not hold or process personal data on patients; however, NHS Digital (formally the Health and Social Care Centre) may process ‘personal data’ for us as an accredited ‘safe haven’ or ‘trusted third-party’ within the NHS when linking GP data with data from other sources. The legal bases for processing this data are:

• Medicines and medical device monitoring: Article 6(e) and Article 9(2)(i) – public interest in the area of public health
• Medical research and statistics: Article 6(e) and Article 9(2)(j) – public interest and scientific research purposes

Any data CPRD hold or pass on to bona fide researchers, except for clinical research studies, will have been anonymised in accordance with the Information Commissioner’s Office Anonymisation Code of Practice. We will hold data indefinitely for the benefit of future research, but studies will normally only hold the data we release to them for twelve months.

Categories of personal data

The data collected by Practice staff in the event of a safeguarding situation will be as much personal information as is possible that is necessary to obtain in order to handle the situation. In addition to some basic demographic and contact details, we will also process details of what the safeguarding concern is. This is likely to be special category information (such as health information).

Sources of the data

The Practice will either receive or collect information when someone contacts the organisation with safeguarding concerns, or we believe there may be safeguarding concerns and make enquiries to relevant providers.

Recipients of personal data

The information is used by the Practice when handling a safeguarding incident or concern. We may share information accordingly to ensure duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals (i.e. their GP or mental health team).

Third party processors

In order to deliver the best possible service, the practice will share data (where required) with other NHS bodies such as other GP practices and hospitals. In addition, the practice will use carefully selected third party service providers. When we use a third party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties include:

• Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
• Delivery services (for example if we were to arrange for delivery of any medicines to you).
• Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).

Further details regarding specific third-party processors can be supplied on request to the Data Protection Officer as below.

How do we maintain the confidentiality of your records? 

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• Data Protection Act 2018
• The General Data Protection Regulations 2016
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management
• Information: To Share or Not to Share Review

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.

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 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.

Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulation (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.

All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary.  If a sub-contractor acts as a data processor for Heathrow Medical Centre an appropriate contract (art 24-28) will be established for the processing of your information.

In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent.  If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.

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 in an identifiable format.   In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes.

With your consent we would also like to use your information

There are times that we may want to use your information to contact you or offer you services, not directly about your healthcare, in these instances we will always gain your consent to contact you.  We would however like to use your name, contact details and email address to inform you of other services that may benefit you.  We will only do this with your consent.  There may be occasions where authorised research facilities would like you to take part on innovations, research, improving services or identifying trends, you will be asked to opt into such programmes if you are happy to do so.

At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO as below.

National Opt-Out Facility

You can choose whether your confidential patient information is used for research and planning.

Who can use your confidential patient information for research and planning?

It is used by the NHS, local authorities, university and hospital researchers, medical colleges and pharmaceutical companies researching new treatments.

Making your data opt-out choice

You can choose to opt out of sharing your confidential patient information for research and planning. There may still be times when your confidential patient information is used: for example, during an epidemic where there might be a risk to you or to other people’s health. You can also still consent to take part in a specific research project.

Will choosing this opt-out affect your care and treatment?

No, your confidential patient information will still be used for your individual care. Choosing to opt out will not affect your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.

What should you do next?

You do not need to do anything if you are happy about how your confidential patient information is used.

If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service.

You can change your choice at any time. To find out more or to make your choice visit nhs.uk/your-nhs-data-matters or call 0300 303 5678

NHS Digital Data Collection from the Practice

The NHS needs data about the patients it treats to plan and deliver its services and to ensure that care and treatment provided is safe and effective. The General Practice Data for Planning and Research data collection will help the NHS to improve health and care services for everyone by collecting patient data that can be used to do this. For example patient data can help the NHS to:

• monitor the long-term safety and effectiveness of care
• plan how to deliver better health and care services
• prevent the spread of infectious diseases
• identify new treatments and medicines through health research

GP practices already share patient data for these purposes, but this new data collection will be more efficient and effective.

This means that GPs can get on with looking after their patients, and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it, to improve health and care for everyone.

Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality.

NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and GP practices.

NHS Digital purposes for processing patient data

Patient data from GP medical records kept by GP practices in England is used every day to improve health, care and services through planning and research, helping to find better treatments and improve patient care. The NHS is introducing an improved way to share this information – called the General Practice Data for Planning and Research data collection.

NHS Digital will collect, analyse, publish and share this patient data to improve health and care services for everyone. This includes:

• informing and developing health and social care policy
• planning and commissioning health and care services
• taking steps to protect public health (including managing and monitoring the coronavirus pandemic)
• in exceptional circumstances, providing you with individual care
• enabling healthcare and scientific research

Any data that NHS Digital collects will only be used for health and care purposes. It is never shared with marketing or insurance companies.

What patient data NHS Digital collect

Patient data will be collected from GP medical records about:

• any living patient registered at a GP practice in England when the collection started – this includes children and adults
• any patient who died after the data collection started, and was previously registered at a GP practice in England when the data collection started

While 1 September has been seen by some as a cut-off date for opt-out, after which data extraction would begin, Government has stated this will not be the case and data extraction will not commence until NHS Digital have met the tests.

The NHS is introducing three changes to the opt-out system which mean that patients will be able to change their opt-out status at any time:

• Patients do not need to register a Type 1 opt-out by 1 September to ensure their GP data will not be uploaded
• NHS Digital will create the technical means to allow GP data that has previously been uploaded to the system via the GPDPR collection to be deleted when someone registers a Type 1 opt-out
• The plan to retire Type 1 opt-outs will be deferred for at least 12 months while we get the new arrangements up and running, and will not be implemented without consultation with the RCGP, the BMA and the National Data Guardian

We will not collect your name or where you live. Any other data that could directly identify you, for example NHS number, General Practice Local Patient Number, full postcode and date of birth, is replaced with unique codes which are produced by de-identification software before the data is shared with NHS Digital.

This process is called pseudonymisation and means that no one will be able to directly identify you in the data. The diagram below helps to explain what this means. Using the terms in the diagram, the data we collect would be described as de-personalised.

Image provided by Understanding Patient Data under licence.

NHS Digital will be able to use the same software to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason. Only NHS Digital has the ability to do this. This would mean that the data became personally identifiable data in the diagram above. An example would be where you consent to your identifiable data being shared with a research project or clinical trial in which you are participating, as they need to know the data is about you.

More information about when we may be able to re-identify the data is in the who we share your patient data with section below.

The NHS Digital programme will be providing further information as the programme progresses. In the meantime, if you have any questions, you can contact the programme at enquiries@nhsdigital.nhs.uk.

The NHS Digital web pages also provide further information at https://digital.nhs.uk/data-and-information/data-collections-and-data-sets/data-collections/general-practice-data-for-planning-and-research#additional-information-for-gp-practices.

The Data NHD Digital collect

We will only collect structured and coded data from patient medical records that is needed for specific health and social care purposes explained above.

Data that directly identifies you as an individual patient, including your NHS number, General Practice Local Patient Number, full postcode, date of birth and if relevant date of death, is replaced with unique codes produced by de-identification software before it is sent to NHS Digital. This means that no one will be able to directly identify you in the data.

NHS Digital will be able to use the software to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason. This would mean that the data became personally identifiable in the diagram above. It will still be held securely and protected, including when it is shared by NHS Digital.

NHS Digital will collect

• data on your sex, ethnicity and sexual orientation
• clinical codes and data about diagnoses, symptoms, observations, test results, medications, allergies, immunisations, referrals and recalls, and appointments, including information about your physical, mental and sexual health
• data about staff who have treated you

More detailed information about the patient data we collect is contained in the Data Provision Notice issued to GP practices.

NHS Digital Does not collect.

• your name and address (except for your postcode in unique coded form)
• written notes (free text), such as the details of conversations with doctors and nurses
• images, letters and documents
• coded data that is not needed due to its age – for example medication, referral and appointment data that is over 10 years old
• coded data that GPs are not permitted to share by law – for example certain codes about IVF treatment, and certain information about gender re-assignment

Opting out of NHS Digital collecting your data (Type 1 Opt-out)

If you do not want your identifiable patient data (personally identifiable data in the diagram above) to be shared outside of your GP practice for purposes except for your own care, you can register an opt-out with your GP practice. This is known as a Type 1 Opt-out.

Type 1 Opt-outs were introduced in 2013 for data sharing from GP practices, but may be discontinued in the future as a new opt-out has since been introduced to cover the broader health and care system, called the National Data Opt-out. If this happens people who have registered a Type 1 Opt-out will be informed. More about National Data Opt-outs is in the section Who we share patient data with.

NHS Digital will not collect any patient data for patients who have already registered a Type 1 Opt-out in line with current policy. If this changes patients who have registered a Type 1 Opt-out will be informed.

If you do not want your patient data shared with NHS Digital, you can register a Type 1 Opt-out with your GP practice. You can register a Type 1 Opt-out at any time. You can also change your mind at any time and withdraw a Type 1 Opt-out.

Data sharing with NHS Digital will start on 1 September 2021.

If you have already registered a Type 1 Opt-out with your GP practice your data will not be shared with NHS Digital.

If you wish to register a Type 1 Opt-out with your GP practice before data sharing starts with NHS Digital, this should be done by returning this form to your GP practice. If you have previously registered a Type 1 Opt-out and you would like to withdraw this, you can also use the form to do this. You can send the form by post or email to your GP practice or call 0300 3035678 for a form to be sent out to you.

If you register a Type 1 Opt-out after your patient data has already been shared with NHS Digital, no more of your data will be shared with NHS Digital. NHS Digital will however still hold the patient data which was shared with us before you registered the Type 1 Opt-out.

If you do not want NHS Digital to share your identifiable patient data (personally identifiable data in the diagram above) with anyone else for purposes beyond your own care, then you can also register a National Data Opt-out. There is more about National Data Opt-outs and when they apply in the National Data Opt-out section below.

NHS Digital legal basis for collecting, analysing and sharing patient data.

When we collect, analyse, publish and share patient data, there are strict laws in place that we must follow. Under the UK General Data Protection Regulation (GDPR), this includes explaining to you what legal provisions apply under GDPR that allows us to process patient data. The GDPR protects everyone’s data.

NHS Digital has been directed by the Secretary of State for Health and Social Care under the General Practice Data for Planning and Research Directions 2021 to collect and analyse data from GP practices for health and social care purposes including policy, planning, commissioning, public health and research purposes.

NHS Digital is the controller of the patient data collected and analysed under the GDPR jointly with the Secretary of State for Health and Social Care.

All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the Data Provision Notice issued by NHS Digital to GP practices.

NHS Digital has various powers to publish anonymous statistical data and to share patient data under sections 260 and 261 of the 2012 Act. It also has powers to share data under other Acts, for example the Statistics and Registration Service Act 2007.

Regulation 3 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) also allow confidential patient information to be used and shared appropriately and lawfully in a public health emergency. The Secretary of State has issued legal notices under COPI (COPI Notices) requiring NHS Digital, NHS England and Improvement, arm’s-length bodies (such as Public Health England), local authorities, NHS trusts, Integrated Care Boards and GP practices to share confidential patient information to respond to the COVID-19 outbreak. Any information used or shared during the COVID-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use confidential patient information.

The legal basis under UKGDPR for General Practice Data for Planning and Research

How NHS Digital use patient data

NHS Digital will analyse and link the patient data we collect with other patient data we hold to create national data sets and for data quality purposes.

NHS Digital will be able to use the de-identification software to convert the unique codes back to data that could directly identify you in certain circumstances for these purposes, where this is necessary and where there is a valid legal reason. There are strict internal approvals which need to be in place before we can do this and this will be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD).

These national data  sets are analysed and used by NHS Digital to produce national statistics and management information, including public dashboards about health and social care which are published. We never publish any patient data that could identify you. All data we publish is anonymous statistical data.

For more information about data we publish see Data and Information and Data Dashboards.

We may also carry out analysis on national data sets for data quality purposes and to support the work of others for the purposes set out in Our purposes for processing patient data section above.

Who NHS Digital share patient data with

All data which is shared by NHS Digital is subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the relevant health and social care purpose will be shared.

All requests to access patient data from this collection, other than anonymous aggregate statistical data, will be assessed by NHS Digital’s Data Access Request Service, to make sure that organisations have a legal basis to use the data and that it will be used safely, securely and appropriately.

These requests for access to patient data will also be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD). Organisations approved to use this data will be required to enter into a data sharing agreement with NHS Digital regulating the use of the data.

There are a number of organisations who are likely to need access to different elements of patient data from the General Practice Data for Planning and Research collection. These include but may not be limited to:

• the Department of Health and Social Care and its executive agencies, including Public Health England and other government departments
• NHS England and NHS Improvement
• primary care networks (PCNs), Integrated Care Boards (ICBs) and integrated care organisations (ICOs)
• local authorities
• research organisations, including universities, charities, clinical research organisations that run clinical trials and pharmaceutical companies

If the request is approved, the data will either be made available within a secure data access environment within NHS Digital infrastructure, or where the needs of the recipient cannot be met this way, as a direct dissemination of data. We plan to reduce the amount of data being processed outside central, secure data environments and increase the data we make available to be accessed via our secure data access environment. For more information read about improved data access in improving our data processing services.

Data will always be shared in the uniquely coded form (de-personalised data in the diagram above) unless in the circumstances of any specific request it is necessary for it to be provided in an identifiable form (personally identifiable data in the diagram above). For example, when express patient consent has been given to a researcher to link patient data from the General Practice for Planning and Research collection to data the researcher has already obtained from the patient.

It is therefore possible for NHS Digital to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason which permits this without breaching the common law duty of confidentiality. This would include:

• where the data was needed by a health professional for your own care and treatment
• where you have expressly consented to this, for example to participate in a clinical trial
• where there is a legal obligation, for example where the COPI Notices apply – see Our legal basis for collecting, analysing and sharing patient data above for more information on this
• where approval has been provided by the Health Research Authority or the Secretary of State with support from the Confidentiality Advisory Group (CAG) under Regulation 5 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) – this is sometimes known as a ‘section 251 approval’

This would mean that the data was personally identifiable in the diagram above. Re-identification of the data would only take place following approval of the specific request through the Data Access Request Service, and subject to independent assurance by IGARD and consultation with the Professional Advisory Group, which is made up of representatives from the BMA and the RCGP. If you have registered a National Data Opt-out, this would be applied in accordance with the National Data Opt-out policy before any identifiable patient data (personally identifiable data in the diagram above) about you was shared. More about the National Data Opt-out is in the section below.

Details of who we have shared data with, in what form and for what purposes are published on our data release register.

Where NHS digital stores patient data

NHS Digital only stores and processes patient data for this data collection within the United Kingdom (UK).

Fully anonymous data (that does not allow you to be directly or indirectly identified), for example statistical data that is published, may be stored and processed outside of the UK. Some of our processors may process patient data outside of the UK. If they do, we will always ensure that the transfer outside of the UK complies with data protection laws.

Where do we store your information electronically?

All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.

No 3rd parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place such as a Data Processor as above).  We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.

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
• GP’s
• Primary Care Network
• NHS Commissioning Support Units
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Integrated Care Boards
• Social Care Services
• NHS England (NHSE) and NHS Digital (NHSD)
• Multi Agency Safeguarding Hub (MASH)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Voluntary Sector Providers
• Private Sector Providers
• 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 consent for this to happen when this is required.

Computer System

This practice operates a Clinical Computer System on which NHS Staff record information securely.  This information can then be shared with other clinicians so that everyone caring for you is fully informed about your medical history, including allergies and medication.

To provide around the clock safe care, unless you have asked us not to, we will make information available to our Partner Organisation (above).  Wherever possible, their staff will ask your consent before your information is viewed.

Shared Care Records

To support your care and improve the sharing of relevant information to our partner organisations (as above) when they are involved in looking after you, we will share information to other systems.  You can opt out of this sharing of your records with our partners at any time if this sharing is based on your consent.

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.  All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for Heathrow Medical Centre an appropriate contract (art 24-28) will be established for the processing of your information.

Sharing your information without consent

We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:

• where there is a serious risk of harm or abuse to you or other people;
• Safeguarding matters and investigations
• where a serious crime, such as assault, is being investigated or where it could be prevented;
• notification of new births;
• where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS);
• where a formal court order has been issued;
• where there is a legal requirement, for example if you had committed a Road Traffic Offence.

How long will we store your information?

We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.

More information on records retention can be found online at (https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016).

How can you access, amend move the personal data that you have given to us?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data and you do not agree, you have the right to object. We will respond to your request within one month (although we may be allowed to extend this period in certain cases). This is NOT an absolute right sometimes we will need to process your data even if you object.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project, or consent to send you information about us or matters you may be interested in), you may withdraw your consent at any time.

Right to erasure: In certain situations, (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within one month (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will need to keep a note of your name/ other basic details on our register of individuals who would prefer not to be contacted. This enables us to avoid contacting you in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.

Primary Care Network

The objective of primary care networks (PCNs) is for group practices together to create more collaborative workforces which ease the pressure of GP’s, leaving them better able to focus on patient care.

This practice is a member of [PCN name].  Other members of the network are:

[Name PCN members]

Primary Care Networks form a key building block of the NHS long-term plan. Bringing general practices together to work at scale has been a policy priority for some years for a range of reasons, including improving the ability of practices to recruit and retain staff; to manage financial and estates pressures; to provide a wider range of services to patients and to more easily integrate with the wider health and care system.

This means the practice may share your information with other practices within the PCN to provide you with your care and treatment.

Service Evaluation

The PCN carries out service evaluations in order to improve the quality and accessibility of primary care services. This may be carried out in a number of ways including telephone surveys, online surveys and interviews.

The legal basis for contacting you to take part –

Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”

Article 9, (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

To process the survey information, we collect from you we will only do so with your consent.

Article 6(1)(a)  – Consent of the data subject (you)

Article 9(2)(a) – Explicit consent of the data subject. (you)’

Population Health Management

Population Health Management (or PHM for short) is aimed at improving the health of an entire population.  The PHM approach requires health care organisations to work together with communities and partner agencies, for example, GP practices, community service providers, hospitals and other health and social care providers.   These organisations will share and combine information with each other in order to get a view of health and services for the population in a particular area. This information sharing is subject to robust security arrangements.

As part of this programme, personal data about your health care will have all identifiers removed (like your name or NHS Number) and replaced with a code which will be linked to information about care received in different health care settings.  If we see that an individual might benefit from some additional care or support, we will send the information back to your GP or hospital provider and they will use the code to identify you and offer you relevant services.

As part of this programme your GP and other care providers will send the information they hold on their systems to the North Of England Commissioning Support Unit (NECS).  NECS are part of NHS England. More information can be found here https://www.necsu.nhs.uk

NECS will link all the information together. Your GP and other care providers will then review this information and make decisions about the whole population or particular patients that might need additional support.  NECS work in partnership with a company called Optum to help them with this work.  Both NECS and Optum are legally obliged to protect your information and maintain confidentiality in the same way that your GP or hospital provider is. More information about Optum can be found here www.optum.co.uk.

Health and Social Care Providers are permitted by data protection law to use personal information where it is ‘necessary for medical purposes’. This includes caring for you directly as well as management of health services more generally.

The PHM project is time-limited to 22 weeks.  Once the project has completed all de-identified , information processed by NECS / Optum will be securely destroyed.  This will not affect any personal information held by your GP or other health or social care providers.

Access to your personal information 

Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:

• Your request should be made to the Practice. (For information from a hospital or other Trust/ NHS organisation you should write direct to them.
• There is no charge to have a copy of the information held about you
• We are required to provide you with information within one month
• You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.

What should you do if your personal information changes?

You should tell us so that we can update our records please contact the Practice Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.

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 to give you online access, including written consent and the 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

Third parties mentioned on your medical record

Sometimes we record information about third parties mentioned by you to us during any consultation, or contained in letters we receive from other organisations. 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.

The NHS wants to give people better ways to see their personal health information online. We know that people want to be able to access their health records. It can help you see test results faster. It also lets you read and review notes from your appointments in your own time.

From 01/112022 we’re now letting you see all the information within your health record automatically. If you are over 16 and have an online account, such as through the NHS App, NHS website, or another online primary care service, you will now be able to see all future notes and health records from your doctor (GP). Some people can already access this feature, this won’t change for you.

This means that you will be able to see notes from your appointments, as well as test results and any letters that are saved on your records. This only applies to records from your doctor (GP), not from hospitals or other specialists. You will only be able to see information from [insert date that your practice will make the change]. For most people, access will be automatic, and you won’t need to do anything.

Your doctor (GP) may talk to you to discuss test results before you are able to see some of your information on the app. Your doctor (GP) may also talk to you before your full records access is given to make sure that having access is of benefit to you. There might be some sensitive information on your record, so you should talk to your doctor if you have any concerns.

These changes only apply to people with online accounts. If you do not want an online account, you can still access your health records by requesting this information through reception. The changes also only apply to personal information about you. If you are a carer and would like to see information about someone you care for, speak to reception staff.

The NHS App, website and other online services are all very secure, so no one is able to access your information except you. You’ll need to make sure you protect your login details. Don’t share your password with anyone as they will then have access to your personal information.

If you do not want to see your health record, or if you would like more information about these changes, please speak to your GP or reception staff.

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.

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

CCTV recording

CCTV is installed on our practice premises covering both the external area of the building and the internal area excluding consulting rooms. Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime. The images are recorded onto an integral hard drive of the equipment and are overwritten on a rolling basis. Viewing of these digital images is only authorised if requested only with a police reference recorded against the incident being investigated.

Telephone system

Our telephone system records all telephone calls.  Recordings are retained for up to three years, and are used periodically for the purposes of seeking clarification where there is a dispute as to what was said and for staff training Access to these recordings is restricted to named senior staff.

Medical Examiner Service

Following the death of any patients of Heathrow Medical Centre we are now obliged to inform [Provider Trust] NHS Trust, Medical Examiner Service.

Medical examiner offices at acute trusts now provide independent scrutiny of non-coronial deaths occurring in acute hospitals.  The role of these offices is now being extended to also cover deaths occurring in the community.

Medical examiner offices are led by medical examiners, senior doctors from a range of specialties including general practice, who provide independent scrutiny of deaths not taken at the outset for coroner investigation. They put the bereaved at the centre of processes after the death of a patient, by giving families and next of kin an opportunity to ask questions and raise concerns. Medical examiners carry out a proportionate review of medical records, and liaise with doctors completing the Medical Certificate of Cause of Death (MCCD).

The Practice will share any patient with the service upon request.

Objections / Complaints

Should you have any concerns about how your information is managed at the GP, please contact the GP Practice Manager or the Data Protection Officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.

Information Commissioner:

Wycliffe house

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel:  01625 545745

https://ico.org.uk/

If you are happy for your data to be 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 Data Protection Officer.

If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.

Data Protection Officer:

Any queries or concerns regarding Data Protection can be sent either directly to the practice or to the Data Protection Officer (DPO) North West London (NWL) ICB (Integrated Care Board)

The Practice Manager acts as the DPO for the Practice.  You can write to him at  heathrow.mc@nhs.net

Our Practice operates within the NWL ICB. You can also contact the DPO of ICB via the contact details below

Dr. E.Norman-Williams 

  Data Protection Officer

Email: e.norman-williams@nhs.net 

 Changes:

It is important to point out that we may amend this Privacy Notice from time to time.  If you are dissatisfied with any aspect of our Privacy Notice, please contact the Practice Data Protection Officer.

The data being shared with NHS Digital will include information about patients who are currently registered with a GP practice or who have a date of death on or after 1 November 2019 whose record contains coded information relevant to coronavirus planning and research.

The data contains NHS Number, postcode, address, surname, forename, sex, ethnicity, date of birth and date of death for those patients.

It will also include coded health data which is held in your GP record such as details of:

• diagnoses and findings
• medications and other prescribed items
• investigations, tests and results
• treatments and outcomes
• vaccinations and immunisations

To read more about the health and care information NHS Digital collects, its legal basis for collecting this information and what choices and rights you have in relation to the processing by NHS Digital of your personal data, see:

• the NHS Digital GPES Data for Pandemic Planning and Research (COVID-19) Transparency Notice
• the NHS Digital Coronavirus (COVID-19) Response Transparency Notice
• the NHS Digital General Transparency Notice
• how NHS Digital looks after your health and care information

Introduction

The NHS Zero Tolerance Zone is a nation-wide campaign to tackle violence and abuse, both physical and verbal, against all members of staff working in the NHS. Its two principal aims are: · To inform the public that violence against staff working in the NHS is unacceptable and the Government is determined to stamp it out · To inform all staff that violence and intimidation is unacceptable and is being tackled. The practice fully supports this campaign and its legal requirements to provide, as far as is reasonably practicable, conditions of working that are conducive to the prevention of and safe management of violence.

Background

In January 2000 the Department of Health (DOH) issued guidelines to Health Authorities to introduce local initiatives as part of a Zero Tolerance Campaign which addresses any incident where a General Practitioner (GP), or his/her staff are exposed to violent or abusive behaviour. As well as having a right to protect themselves, GPs have a duty, as employers, to protect their staff and as providers of a public service, those with reason to be on their premises. The DOH established the following definition for violence/abuse – “Any incident where a GP, or his or her staff, are abused, threatened or assaulted in circumstances related to their work, involving an explicit or implicit challenge to their safety, wellbeing or health”. The definition does not define violence just as physical assault but also includes threats that challenge the “Safety, wellbeing or health of staff”.

Here are some examples of the breaches of the Zero Tolerance Policy;

• Behaviours that target a person based on their protected characteristic or belonging to a marginalised group. These can be intentional and unintentional and are based on biases either conscious and unconscious
• Any physical violence towards any member of the Primary Health Care Team or other patients, such as pushing or shoving
• Racial abuse and sexual harassment
• Causing damage/stealing from the Practice’s premises, staff or patients
• Obtaining drugs and/or medical services fraudulently
• Refusing appointments with an appropriate clinician for the presenting care need i.e. insisting on a GP appointment when seeing a pharmacist or nurse prescriber is most appropriate or refusing to see an available GP for your presenting care need when your preferred GP is unavailable
• Refusing to access the service in the appropriate manner i.e. sending emails/texts instead of using the NHS Digital approved digital consultation service
• Demanding a same day appointment for a routine clinical need – this deprives access to urgent care services for those who genuinely need it
• Contacting individuals directly via social media or personal email instead of through the practice contact channels
• Using bad language threatening or swearing at practice staff or other service users;
• Unnecessarily persistent or unrealistic service demands that cause disruption;
• Verbal, non-verbal and environmental slights, snubs and insults which communicate hostile, derogatory or negative messages;

Process

The practice operates a Zero Tolerance Policy towards any member of our staff or patients. Patients are expected to be considerate and act reasonably. Management cites but does not restrict, the following unacceptable behaviour within its Zero Tolerance Policy: · any display of a violent temper · shouting, raised voices, sarcasm, pointing fingers. · repeated or insistent points being made; not engaging with staff in a positive way; being pushy or trying to intimidate staff · hostile or aggressive behaviour · threats, swearing, spitting · any mention or display of any object that could be used as a weapon. Should a member of staff (or patient) feel that they have encountered behaviour that could be classed as unacceptable within the Practice Zero Tolerance Policy, a complaint should be made to the Practice Manager. Once the matter has been reviewed by the Practice Manager the person in question will be sent a formal warning letter, depending on the severity of the incident they may then be either sent a warning letter with behavioural agreement to be signed within 30 days of the warning letter been issued or be removed from the practice list. We will have no hesitation in having the patient removed from the building by the Police should his/her behaviour warrant it.

Police involvement

If an incident is taking place and staff feel that a Police presence is required, regardless of the circumstances, the Police will be called to deal with the incident. It is our responsibility to protect our staff and patients and therefore no hesitation will be made if a Police presence is required. If the patient has left the premises and there is no immediate danger, the Police will still be notified of the incident so it can be recorded for future reference. The GP will also keep a record of the incident.

Warning system

Following an incident where a complaint has been made about a patient’s behaviour a formal warning letter will be sent with a behavioural agreement to be signed within 30 days of the date of the warning letter. The letter will notify the person that their behaviour was unacceptable and will not be tolerated, if the person is a patient at the surgery they will be warned that they run the risk of being removed from our practice list if they do not sign the behavioural agreement within the specified time period. The letter will clearly state that if there is any reoccurrence of their behaviour in any way that they will be removed from the Practice list. A permanent record of the warning, including the date and reason for the warning, will be made and retained. Although this procedure will be generally applied, there may be occasions where the Management Team feel that an episode of behaviour is so serious that a patient will removed from the Practice list with immediate effect. Where this is the case, the police will usually have been called to attend the Practice and one or more members of staff or patients will have been threatened or attacked or narrowly avoided being attacked. It is important to remember that it is not the intention of the perpetrator that is relevant, rather than the perception that is generated by the actions and behaviour of the perpetrator that will generate the Practice response.

Removal from the Practice List

Removal of patients from this Practice list is an exceptional and rare event and is a last resort. The practice must respect the safety and wellbeing of their staff and patients, and if a patient at the surgery is unable to respect the staff and treat them with courtesy then it is in the best interest of the patient in question and, more importantly, our staff that they register elsewhere. If the decision to remove a patient from the practice list is made, NHS England will be notified either immediately (in case of serious breaches where a deregistration is to be processed within 24hours with or without a police reference as necessary) or on 8 days’ notice for the protection of other NHS staff members. If a patient is removed from the Practice list, they will also be banned from entering the Practice premises or contacting Practice staff in any way.

Notifying the Patient

The Practice will take steps to contact the patient to inform them of the action being taken. After having a formal consultation with our integrated care board, we advise patients that following a breach of zero tolerance threshold, where the breach is not warranting a removal, practice is more than happy to carry on providing the service as normal provided a behavioural agreement is signed. This means that the practice will be monitoring patients behavioural after they have signed the agreement for a period of 12 months and should there be a reoccurrence of the same, a deduction will be processed as appropriate. Practice warning letter clearly specifies about the 30 days’ time period for signing the behavioural agreement and the patient will be informed in writing to their home address or through a verified email. Failing to sign the behavioural agreement within the given time period will result in the de-registration of the patient and no further notifications will be sent. Once this decision has been made the deduction will not be revoked under any circumstances, and the subject will not be entertained by any staff member and will be only considered as harassment. Practice is not obliged to send removal notifications in cases of serious breaches where it is necessary to remove patients within 24 hours’ time period, however all necessary measures will be taken by the practice to inform the NHS health authority of the event so that they can contact the patient directly to

Removing other members of the household

Because of the possible need to visit patients at home it may be necessary to terminate responsibility for other members of the family or the entire household. The prospect of visiting patients where a relative, who is no longer a patient of the practice by virtue of their unacceptable behaviour resides, or being regularly confronted by the removed patient, may make it too difficult for the practice to continue to look after the whole family. This is particularly likely where the patient has been removed because of violence or threatening behaviour and keeping the other family members could put Doctors or their staff at risk.