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Privacy Information

PRACTICE FAIR PROCESSING

& PRIVACY NOTICE

Your Information, Your Rights

 

Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR). 

The following notice reminds you of your rights in respect of the above legislation and how your GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.

This notice reflects how we use information for:

  • The management of patient records;
  • Communication concerning your clinical, social and supported care;
  • Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
  • Participation in health and social care research; and
  • The management and clinical planning of services to ensure that appropriate care is in place for our patients today and in the future.

 

Data Controller

 

As your registered GP practice, we are the data controller for any personal data that we hold about you.

 

What information do we collect and use?

 

All personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to the your care.

 

We will collect the following types of information from you or about you from a third party organisations engaged in the delivery of your care:

 

  • ‘Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data.  This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS number

 

And
 

  • ‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.

 

Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services).  These records may be electronic, a paper record or a mixture of both.  We use a combination of technologies and working practices to ensure that we keep your information secure and confidential. We work in partnership with NHS Wales who provide the IT infrastructure for secure medical record storage.

 

How long we keep your data

 

We retain clinical information on our patients until they transfer from the practice or until their death. We hold CCTV images for 4 weeks and telephone recording data is held for 12 months.

 

 

Why do we collect this information?

 

The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training.  To do this we will need to process your information in accordance with current data protection legislation to:

  • Protect your vital interests;
  • Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
  • Perform tasks in the public’s interest;
  • Deliver preventative medicine, medical diagnosis, medical research; and
  • Manage the health and social care system and services.

 

How are your records used to help you?

 

Your records are used to guide professionals in the care you receive to ensure that:

 

  • We have accurate and up to date information to assess your health and decide what care you need.

  • Information is available if you see another clinician within the practice or are referred to a specialist

  • There is a good basis for assessing the type of care you have received.

  • Your concerns can be properly investigated if you need to complain.

     

    How is the information collected?

     

    Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection.  In addition physical information will be sent to your practice.  This information will be retained within your GP’s electronic patient record or within your physical medical records.

     

    Who will we share your information with?

     

    In order to deliver and coordinate your health and social care, we may share information with the following organisations:

  • Local GP cluster Practices in order to deliver extended primary care services
  • NHS Wales
  • Cwm Taf University Health Board and other Health Boards commissioned by Cwm Taf
  • Cwm Taf GP Out of Hours service.
  • Merthyr Tydfil CBC Social Services and Community Care services
  • Attached clinical teams – for example Health Visitors, Midwifes, Pharmacists ,Community Mental Health staff , Physiotherapists, Dentists, Opticians, Pharmacists
  • Public Health Wales (Immunisation Services, Cervical Screening Wales, Breast Test Wales, Smoking cessation Wales)
  • Private consultants (usually at your request)
  • Voluntary Sector Providers (e.g. cancer aid)
  • Welsh Ambulance Service Ambulance Trusts
  • Social Services
  • South Wales Police
  • You may be receiving care from other NHS Wales organisations as well and we will only ever pass on information if we feel there is a genuine need and it is in your best interests (E.G. hospitals that might treat you)
  • We will use the Welsh Clinical Communications Gateway (an electronic secure gateway) to send referrals about you and we will include details such as past medical history and presenting conditions. 
  • All NHS Wales staff are bound by confidentiality agreements.

 

Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.

Your information will not be transferred outside of the European Union.

 

Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.

In addition, if you choose to use the e-consult system we will received data from them to assist us in providing electronic consultations.

 

How do we maintain the confidentiality of your records?

Your personal information is held in both paper and electronic forms for specified periods of time as set out in the Records Management Code of Practice for Health and Social Care 2022.

We are committed to protecting your privacy and will only use information that has been collected lawfully.  Every member of staff who works for the practice and any NHS organisation has a legal obligation to keep information about you confidential.  We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.

Information is not held for longer than is necessary.   We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.

 

Consent and Objections

 

Do I need to give my consent?

 

The GDPR sets a high standard for consent.  Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation.  However consent is only one potential lawful basis for processing information.  Therefore your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice.  Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice.  Your consent will be documented within your electronic patient record.

 

 

What will happen if I withhold my consent or raise an objection?

 

You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing.  Please contact the Practice Manager for further information and to raise your objection.

 

Health Risk Screening / Risk Stratification

 

Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health.  By using selected information such as age, gender, NHS number, diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.

 

To summarise Risk Stratification is used in the NHS to:

  • Help decide if a patient is at a greater risk of suffering from a particular condition;
  • Prevent an emergency admission;
  • Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
  • Review and amend provision of current health and social care services.

 

Your GP will routinely conduct the risk stratification process outside of your GP appointment.  This process is conducted electronically and without human intervention.  The resulting report is then reviewed by a multidisciplinary team of staff within the Practice.  This may result in contact being made with you if alterations to the provision of your care are identified.

As mentioned above, you have the right to object to your information being used in this way.  However you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care.  Please contact the Practice Manager to discuss how disclosure of your personal data can be limited

.

Sharing of Electronic Patient Records within the NHS

 

Electronic patient records are kept in most places where you receive healthcare.  Our Clinical system (Vision) enables your record to be shared with organisations involved in your direct care, such as:

  • Cluster GP practices
  • Community services such as district nurses, rehabilitation services and out of hospital services.
  • Child health services that undertake routine treatment or health screening
  • Urgent care organisations, minor injury units or out of hours services
  • Community hospitals & Hospital Pharmacies
  • Palliative care / Cancer Care

 

In addition, NHS Wales has implemented the Summary Care Record which contains information including medication you are taking and any allergic reactions to medication that you have had in the past.

In most cases, particularly for patients with complex conditions and care arrangements, the shared electronic health record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health.  Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so.  The shared record means patients do not have to repeat their medical history at every care setting.

Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to disable this function or restrict access to specific elements of your record.  This will mean that the information recorded by your GP will not be visible at any other care setting. 

You can also reinstate your consent at any time by giving your permission to override your previous dissent. 

Your Right of Access to Your Records

The Data Protection Act and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format.  This is known as the “right of subject access”.  If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information.  This can be your GP, or a provider that is or has delivered your treatment and care.  You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party. 

 

If you would like access to your GP record, please submit your request in writing to :

 

Data Controller C/O Mr Kevin Rogers, Practice Manager, Pontcae Medical Practice

 

Photo ID Verification will be required in all cases

 

Changes to our privacy policies

 

We keep our privacy notice and policy under review and we will place any updates on www.pontcaemedicalpractice.co.uk - The last update was 15 May 2018.

 

 

 

Complaints

 

In the event that your feel we have not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager (as above)

If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at

Information Commissioner’s Office – Wales

2nd Floor, Churchill House

Churchill Way

Cardiff

CF10 2HH

 

Enquiry Line: 029 2067 8400 online at www.ico.gov.uk