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PRIVACY POLICY

This privacy notice explains why St Pauls Surgery collects information about you, how we keep it safe and confidential and how that information may be used.
 

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received within any NHS organisation. These records help to provide you with the best possible healthcare.

We collect and hold data for the sole purpose of providing healthcare services to our patients. In carrying out this role we may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form. The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and information such as outcomes of needs assessments.

Details we collect about you

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously or elsewhere (e.g. NHS Hospital Trust, other GP Surgery, Out of Hours GP Centre, A&E, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
 

Records which we may hold about you may include the following:

Details about you, such as your address and next of kin, emergency contacts

Your home telephone number, mobile phone number, email address

Any contact the surgery has had with you, such as appointments, clinic visits, immunisations, emergency appointments, etc.

Notes and reports about your health, 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, or information provided to the surgery by you (including that provided via our surgery website)



How we keep your information confidential and safe

All your GP NHS health records are kept electronically. Our GP records database is hosted by EMIS Health Ltd, who is acting as a data processor, and all information is stored on their secure servers in Leeds, is protected by appropriate security, and access is restricted to authorised personnel.


We also make sure that data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.


We only email you, or use your mobile number to text you, regarding matters of medical care, such as appointment reminders and (if appropriate) test results.
Unless you have separately given us your explicit consent, we will not email you for non-medical matters (such as surgery newsletters and other information).We maintain our duty of confidentiality to you always. 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), or where the law requires information to be passed on.


How we use information about you

Confidential patient data will be shared within the healthcare team at the practice, including nursing staff, admin staff, secretaries and receptionists, and with other healthcare professionals to whom a patient is referred. Those individuals have a professional and contractual duty of confidentiality.

Details of who is authorised to access your GP record can be found on our website.


Data Processors

St Paul’s Surgery uses data processors to perform certain administrative tasks for us, particularly where these involve large numbers of patients. Details of these data processors can be found on our website.


Referrals for specific health care purposes

We sometimes provide your information to other organisations for them to provide you with medical services. We will always inform you of such a referral and you always have the right not to be referred in this way. These include:

Referrals for home oxygen services (“HOOF”)

Referrals for Diabetes Eye Screening (DRS)

Referrals for Prediabetes advice (“Healthier You”)


Data Sharing Schemes

A number of data sharing schemes are active locally, enabling healthcare professionals outside of the surgery to view information from your GP record, with your explicit consent, should that need arise. These schemes are as follows:

The National Summary Care Record (SCR)

The Hampshire Health Record (HHR, or CHIE)

EMIS Web data streaming (MHH GP Acess hubs)

Adastra Web Access (GP out of hours)

IBIS (Ambulance service)

Details of these schemes, and of your right to opt-out of any or all of them, can be found on our website.

 

Mandatory disclosures of information

We are sometimes legally obliged to disclose information about patients to relevant authorities. In these circumstances the minimum identifiable information that is essential to serve that legal purpose will be disclosed.

That organisation will also have a professional and contractual duty of confidentiality. Data will be anonymised if at all possible before disclosure if this would serve the purpose for which the data is required.

Organisations that we are sometimes obliged to release information to include:

NHS Digital (e.g. the National Diabetes Audit)

CQC

DVLA

GMC

HMRC

NHS Counter Fraud

Police

The Courts

Public Health England

Local Authorities (Social Services)

The Health Service Ombudsman

In the event of actual or possible legal proceedings, we may need to disclose information from an individual’s GP record to a medical defence organisation.


Permissive disclosures of information

Only with your explicit consent, St Paul’s Surgery can release information about you, from your GP record, to relevant organisations. These may include:

Your employer

Insurance companies

Solicitors

Local Authorities

Police


Accessing your information on other databases

St Paul’s Surgery can access certain medical information about you, when relevant or necessary, that is held on other databases (i.e. under the control of another data controller). These include Hampshire Hospitals Foundation Trust (HHFT) databases and NHS Digital’s Open Exeter database. Accessing such information would only be for your direct medical care.


Research

St Paul’s Surgery sometimes undertakes accredited research projects. Where this involves accessing or disclosing identifiable patient information, we will only do so with the explicit consent of the individual and Research Ethics Committee approval. St Paul’s Surgery is not currently involved with other research projects such as the Clinical Practice Research Database (CPRD) or QResearch, and we do not permit secondary processing (e.g. for research, “analytics”, commissioning, commercial or political purposes) of our patients’ information uploaded to the Hampshire Health Record.


Your Data Rights


Your right to object to sharing of your information

You have the right to object to (or opt-out of) ways by which your information is shared, both for direct medical care purposes (such as the national NHS data sharing schemes), i.e. primary uses of your information, or for purposes other than your direct medical care – so-called secondary uses. You cannot object to some of the ways by which your information is disclosed.


Details of these purposes, and how you can object, can be found on our website.


Your right to rectification

You have the right to have any factual inaccuracies about you in your GP record corrected.


Accessing your own medical information

You have the right to access your own GP record. Details of how to do this can be found on our website.

You can also sign up to have secure online access to your electronic GP record. Again, details of how to do this can be found on our website.

Your right to be informed

St Paul’s Surgery provide fair processing information about all data processing activities concerning your medical records, by means of posters, booklets (such as this one), and detailed privacy notices.

 


Lawful bases for processing and the EU GDPR

Detailed information (individual privacy notices) about all our data processing activities, including lawful bases, can be found on our website, upon request from the surgery, or from the Data Protection Officer (Philip Heiden – Practice Manager)


We rely upon Article 6(1)(e) Official Authority and Article 9(2)(h) Provision of Health for much of our processing, in particular:

Maintaining your electronic GP record

Sharing information from, or allowing access to, your GP record, for healthcare professionals involved in providing you with medical care

Referrals for specific health care purposes

The NHS data sharing schemes

Our data processors

Organising your prescriptions, including sending both paper and electronic prescriptions to your chosen pharmacy

Some permissive disclosures of information

Accessing your information on other NHS organisation databases

We rely upon Article 6(1)(d) Vital Interests and Article 9(2)(h) Provision of Health to share information about you with another healthcare professional in a medical emergency.


We rely upon Article 6(1)(c) Legal Obligation and Article 9(2)(h) Provision of Health for mandatory disclosures of information (such as to NHS Digital, CQC).


We rely upon Article 6(1)(a) Consent and Article 9(2)(h) Provision of Health for certain permissive disclosures of information (such as to insurance companies).


We rely upon Article 6(1)(e) Official Authority and Article 9(2)(j) Research for accredited research undertaken in the surgery, with your explicit consent.



Notification

The Data Protection Act 1998 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a data controller and our registration can be viewed online in the public register at:

https://ico.org.uk/ESDWebPages/Entry/Z5331042

Complaints

If you have concerns or are unhappy about any of our services, please contact our Practice Manager. Details of how to complain are on our website, or available in surgery.

For independent advice about data protection, privacy, and data sharing issues, you can contact:
 

The Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

Phone: 08456 30 60 60
Website: www.ico.gov.uk

 

Further Information

If you would like any further information about primary or secondary uses of your GP record, opting out, the NHS Databases, access to your medical record, confidentiality, GDPR, or about any other aspect of NHS data sharing or your medical records, then please do contact the surgery’s Caldicott Guardian / Information Governance lead / Data Protection Officer:

In writing to:

Practice Manager
St Paul's Surgery
Alison Way
Winchester
SO22 5DD

or via email to:

whccg.stpaulssurgery-admin@nhs.net

 


 

Website Privacy Policy

We are committed to protecting the privacy of all individuals using this website.

This policy explains how we use any personal information we collect from you through this website.

 

Collection of personal information

You can access most of the pages on our website without giving us your personal information. However, you may choose to provide us with your personal information on some pages of the website by completing an on-line form.

By submitting your personal information, you consent to our use of the information as set out in this privacy policy.

 

Use of personal information

We shall use any personal information you give to us, in accordance with this policy, and with any additional statements appearing on forms used for submitting your personal information. We shall not disclose your personal information to any third parties without obtaining your prior consent unless we are required by law to do so. In particular:

We shall use your personal information to administer, and may respond to, your request.

We shall securely store the information you supply together with any response we may provide.

If you contact us regarding the website we may use your details to reply to you. If you make a comment or complaint about other aspects of the service we may use your details to investigate your comments.

 

Website privacy

This website uses https to ensure data is encrypted in transmission. This encryption, known as TLS encryption protocol, allows us to protect your privacy. You can usually verify that the page is encrypted by seeing a small lock symbol in the upper left corner of your browser and the website address is prefixed with https://.

 

Data storage

All data obtained by us is held and used in compliance with the Data Protection Act 2018.

 

Cookie Policy

Please click here to read our Cookie Policy.

 

Links

This website contains links to other sites. We are not responsible for the privacy practices of third parties that run any other websites. Please refer to their own privacy policies for more information.

 

Access to your personal information

You have a right under the Data Protection Act 2018 to ask us to provide you with the information we hold about you and to have any inaccuracies corrected. If you would like to access a copy of your information, please contact the Practice Manager using the following contact details in the heading above.

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