Practice privacy notice

How long do we keep your personal information?

 

We are required under UK law to keep your information and data for the full retention periods as specified by the NHSE – Records Management Code of Practice 2023 

 

Where do we store your information electronically?

 

All the personal data we process is processed by our staff in the UK via cloud based secure system.

 

No third 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 data protection processes in place to oversee the effective and secure processing of your personal and/or special category data.

 

This organisation uses a clinical system provided by a data processor called Meddbase. 

 

Data does remain in the UK and will be fully encrypted both in transit and at rest. In doing this, there will be no change to the control of access to your data and the hosted service provider will not have any access to the decryption keys. 

 

Maintaining your confidentiality and accessing your records

 

We are committed to protecting your privacy and will only use information collected lawfully in accordance with the UK General Data Protection Regulations (which is overseen by the Information Commissioner’s Office), Human Rights Act and the Common Law Duty of Confidentiality. Every staff member who works at My Specialist GP has a legal obligation to maintain the confidentiality of patient information.

 

All of our staff, contractors and locums receive appropriate and regular training to ensure they are aware of their personal responsibilities and have legal and contractual obligations to uphold confidentiality, enforceable through disciplinary procedures. Only a limited number of authorised staff have access to personal information where it is appropriate to their role and this is strictly on a need-to-know basis. 

 

We maintain our duty of confidentiality to you at all times. 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 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 organisational policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the UK General Data Protection Regulation (UK GDPR) and all UK specific data protection requirements. Our policy is to ensure all personal data related to our patients will be protected. 

 

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

 

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.

 

Third party processors

 

To enable us to deliver the best possible services, 

 

Third parties mentioned on your medical record

 

Sometimes we record information about third parties mentioned by you to us during any consultation. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them that may breach their rights to confidentiality are removed before we send any information to any other party including yourself. Third parties can include spouses, partners and other family members.

 

Anonymised information

 

Sometimes we may provide information about you in an anonymised form. If we do so, then none of the information we provide to any other party will identify you as an individual and cannot be traced back to you.

 

Audit

 

Auditing of clinical notes is done by this organisation as part of its commitment to the effective management of healthcare whilst acting as a data processor.

 

Article 9.2.h is applicable to the management of healthcare services and “permits processing necessary for the purposes of medical diagnosis, provision of healthcare and treatment, provision of social care and the management of healthcare systems or services or social care systems or services.’” No consent is required to audit clinical notes for this purpose. 

 

Furthermore, compliance with Article 9(2)(h) requires that certain safeguards are met. The processing must be undertaken by or under the responsibility of a professional subject to the obligation of professional secrecy or by another person who is subject to an obligation of secrecy.

 

Auditing clinical management is no different to a multi-disciplinary team meeting discussion whereby management is reviewed and agreed. It would be realistically impossible to require consent for every patient reviewed that is unnecessary. It is also prudent to audit under Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 17: Good Governance.

 

Computer System

 

This organisation operates a clinical computer system on which 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.

 

Patient communication

 

As we are obliged to protect any confidential information we hold about you, it is imperative that you let us know immediately if you change any of your contact details. 

 

We may contact you using email should we need to notify you about appointments and other services that we provide to you involving your direct care 

 

Safeguarding

 

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

 

Our legal basis for processing for UK General Data Protection Regulation (UK 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…’

 

Safeguarding information such as referrals to safeguarding teams is retained by this organisation when handling a safeguarding concern or incident. We may share information accordingly to ensure a duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals (i.e., the mental health team).

 

Shared care

 

To support your care and improve the sharing of relevant information to our partner organisations when they are involved in looking after you, we will share information to Your NHS GP upon your explicit request. 

 

Organisation website

 

Our website does use cookies to optimise your experience. Using this feature means that you have agreed to the use of cookies as required by the EU Data Protection Directive 95/46/EC. You have the option to decline the use of cookies on your first visit to the website. The only website this privacy notice applies to is this organisation’s website. 

 

If you use a link to any other website from the organisation’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.

 

What to do if you have any questions

 

Should you have any questions about our privacy policy or the information we hold about you, you can:

 

1. Contact the organisation via email at info@myspecislitgp.co.uk. GP practices are data controllers for the data they hold about their patients (for more information, refer to the BMA guidance on this subject) 

   

1. Write to the Data Protection Officer (DPO) Cathy Stewart 

 

1. Ask to speak to the Practice Manager Cathy Stewart or their deputy [Marieke Richardson]

 

Objections or complaints

 

If you are unhappy with any element of our data processing methods, contact the Practice Manager in the first instance. If you feel that we have not addressed your concern appropriately, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). 

 

The ICO can be contacted on https://ico.org.uk and select “Raising a concern” or telephone: 0303 123 1113.

 

The ICO is the regulator for data protection and offers independent advice and guidance on the law and personal data including your rights and how to access your personal information.

 

Changes to our privacy policy

 

We regularly review our privacy policy and any updates will be published on our website, in our newsletter and on posters to reflect the changes.