On 25 May 2018, the General Data Protection Regulation (GDPR)  will be enforced across Europe, including the UK. The law aims to give citizens more control over their data and to create a uniformity of rules to enforce across the continent. Click here to download the GDPR leaflet.

This privacy notice explains why the GP Practice collects information about you, and how that information may be used.

As data controllers, GPs have responsibilities which are regulated by law under the General Data Protection Regulations. This means ensuring that your personal confidential data (PCD) is handled in ways that are safe, transparent and what you would reasonably expect.

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come in to such possession. The processing of personal data is governed by the General Data Protection Regulation (the ‘GDPR’).

Health care professionals maintain records about your health and any treatment or care you have received within the NHS (e.g. NHS Hospital Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide the best possible healthcare.

NHS health records may be processed electronically, on paper or a mixture of both, and a combination of working practices and technology are used to ensure that your information is kept confidential and secure. Records held by this GP Practice may include the following information:

•   Details about you, such as address, telephone numbers, DOB and next of kin
•   Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
•   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.

This GP Practice collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that information is kept confidential. We can disclose personal information if:

• It is required by law
• You consent – either implicitly for the sake of your own care or explicitly for other purposes
• It is justified in the public interest

Some of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict measures to ensure that individual patients cannot be identified.

Sharing your personal data

Sometimes information about you may be requested to be used for research purposes. The Practice will always endeavour to gain your consent before releasing the information.

Under the powers of the Health and Social Care Act 2012 (HSCA) the Health and Social Care Information Centre (HSCIC) can request Personal Confidential Data (PCD) from GP Practices without seeking the patient’s consent. Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.

Any patient can choose to exercise their right of objection specified under the GDPR regarding their PCD being used in this way. When the Practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-in’ of each new scheme.

Though a patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

Risk Stratification

Risk stratification is a process for identifying and managing patients who are at a higher risk of emergency hospital admission. Typically, this is because patients have a long-term condition such as COPD or cancer. NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help prevent avoidable admissions.

Information about you is collected from several sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your anonymous information using computer programmes. Your information is only provided back to your GP or member of your care team in an identifiable form. Risk stratification enables your GP to focus on the prevention of ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services.

Under the GDPR we require your explicit consent to be able to perform this process. Please note the purpose of risk stratification is to prevent and detect health issues therefore we will ask our Patients for their consent to be included in this.

Invoice Validation

If you have received treatment within the NHS, access to your personal information may be required to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.

This information would most likely include information such as your name, address, date of treatment and may be passed on to enable the billing process. These details are held in a secure environment and kept confidential. This information will only be used to validate invoices and will not be shared for any further purposes.

NHS Health Checks

All of our patients aged 40-74 not previously diagnosed with cardiovascular disease are eligible to be invited for an NHS Health Check. Nobody outside the healthcare team in the practice will see confidential information about you during the invitation process and only contact details would be securely transferred to a data processor (if that method was employed). You may be ‘given the chance to attend your health check either within the practice or at a community venue. If your health check is at a community venue all data collected will be securely transferred back into the practice system and nobody outside the healthcare team in the practice will see confidential information about you during this process.

CCTV (Closed Circuit Television)
Images will be retained for 31 days and then deleted.

All images will be held securely, and all access requests and access to images will be documented.

Images may record individuals and / or record incidents. Not all recordings are designed to identify persons.

The lawful basis of recording CCTV images is for legitimate interests. Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime, and images may be provided to police or other bodies.

Other than in accordance with statutory rights, the release or availability of images will be at the discretion of the Partners of the Practice, who are Data Controllers for the purposes of the Data Protection Act.

Where access is granted in response to an application received, the image may be edited to exclude images of third parties who may be also included within the requested image. This may be necessary to protect the identity of the third parties. In these circumstances the image released as part of the application may record / identify the “data subject” only.

Images will be located by the Data Controller or authorised person.

When assessing the content of the image to be released the decision will be taken by the Data Controllers having due regard to the requirements of the Data Protection Act and Code of Conduct.

Your Care Connected
Your Care Connected (YCC) is an electronic record sharing system that allows authorised health and care staff to securely view key aspects of the GP record, to provide patients with better and safer care.
Please see the following website for further information: https://midlandsyourcareconnected.nhs.uk
‘The lawful basis for processing this data is for the purposes of provision of health care or treatment’ [Article 9(2) of the GDPR].

We are committed to protecting your privacy and will only use information collected lawfully in accordance with the GDPR (which is overseen by the Information Commissioner’s Office), Human Rights Act, the Common Law Duty of Confidentiality, and the NHS Codes of Confidentiality and Security.

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

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.

We may also have to share your information, subject to strict agreements on how it will be used. The following are examples of the types of organisations that we are likely to share information with:
• NHS and specialist hospitals, Trusts
• Independent Contractors such as dentists, opticians, pharmacists
• Private and Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups and NHS England
• Social Care Services and Local Authorities
• Education Services
• Police, Fire and Rescue Services
• Other ‘data processors’ during specific project work e.g. Diabetes UK

Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
• The right to request a copy of your personal data which this practice holds about you;
• The right to request that this practice corrects any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for the practice to retain such data. Although please note for Patients at this practice, your records will be retained until death;
• The right to withdraw consent to the processing at any time;
• The right to data portability;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to lodge a complaint with the Information Commissioners Office.

Contact Details
Should you have any concerns about how your information is managed or wish to object to any of the data collection at the Practice, please contact the Practice Manager or your healthcare professional to discuss how the disclosure of your personal information can be restricted. All patients have the right to change their minds and reverse a previous decision. Please contact the practice if you change your mind regarding any previous choice.
If you would like to make a ‘data subject access request’ please contact the practice in writing. We will endeavour to respond to your request within one calendar month or two months if the request is complex.
Any changes to this notice will be published on our website and on the Practice notice board.
Suspected breaches in data protection can be reported to the independent OHP Data Protection Officer Leanne Hoye on 0121 422 1366. Breaches in data protection will result in an incident investigation. Serious breaches will be reported to the ICO.
It is the responsibility of all employees of the practice to report suspected breaches of information security to the Practice lead and Data Protection Officer without delay.
The Practice is registered as a data controller with the ICO. The registration number is Z7394759 and can be viewed online in the public register at: ico.org.uk. You can contact the ICO on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

Sometimes information about you may be requested to be used for research purposes. The Practice will always endeavour to gain your consent before releasing the information.

Under the powers of the Health and Social Care Act 2012 (HSCA) the Health and Social Care Information Centre (HSCIC) can request Personal Confidential Data (PCD) from GP Practices without seeking the patient’s consent. Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.

Any patient can choose to exercise their right of objection specified under the GDPR regarding their PCD being used in this way. When the Practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-in’ of each new scheme.

Though a patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

Risk stratification is a process for identifying and managing patients who are at a higher risk of emergency hospital admission. Typically, this is because patients have a long-term condition such as COPD or cancer. NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help prevent avoidable admissions.

Information about you is collected from several sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your anonymous information using computer programmes. Your information is only provided back to your GP or member of your care team in an identifiable form. Risk stratification enables your GP to focus on the prevention of ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services.

Under the GDPR we require your explicit consent to be able to perform this process. Please note the purpose of risk stratification is to prevent and detect health issues therefore we will ask our Patients for their consent to be included in this.

If you have received treatment within the NHS, access to your personal information may be required to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.

This information would most likely include information such as your name, address, date of treatment and may be passed on to enable the billing process. These details are held in a secure environment and kept confidential. This information will only be used to validate invoices and will not be shared for any further purposes.

All of our patients aged 40-74 not previously diagnosed with cardiovascular disease are eligible to be invited for an NHS Health Check. Nobody outside the healthcare team in the practice will see confidential information about you during the invitation process and only contact details would be securely transferred to a data processor (if that method was employed). You may be ‘given the chance to attend your health check either within the practice or at a community venue. If your health check is at a community venue all data collected will be securely transferred back into the practice system and nobody outside the healthcare team in the practice will see confidential information about you during this process

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –

• The right to request a copy of your personal data which this practice holds about you;
• The right to request that this practice corrects any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for the practice to retain such data. Although please note for Patients at this practice, your records will be retained until death;
• The right to withdraw consent to the processing at any time;
• The right to data portability;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed o further processing;

The right to lodge a complaint with the Information Commissioners Office

Should you have any concerns about how your information is managed or wish to object to any of the data collection at the Practice, please contact the Practice Manager or your healthcare professional to discuss how the disclosure of your personal information can be restricted. All patients have the right to change their minds and reverse a previous decision. Please contact the practice if you change your mind regarding any previous choice.

If you would like to make a ‘data subject access request’ please contact the practice in writing. We will endeavour to respond to your request within one calendar month or two months if the request is complex.

Any changes to this notice will be published on our website and on the Practice notice board.

Suspected breaches in data protection can be reported to the independent OHP Data Protection Officer Naomi Frazer or Leanne Hoye on 0121 422 1366. Breaches in data protection will result in an incident investigation. Serious breaches will be reported to the ICO.

It is the responsibility of all employees of the practice to report suspected breaches of information security to the Practice lead and Data Protection Officer without delay.

The Practice is registered as a data controller with the ICO. The registration number is ZA188128 and can be viewed online in the public register at: ico.org.uk. You can contact the ICO on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

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Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• improving the quality and standards of care provided
• research into the development of new treatments
• preventing illness and diseases
• monitoring safety
• planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law. Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed. You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care.

To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.  On this web page you will:

• See what is meant by confidential patient information
• Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
• Find out more about the benefits of sharing data
• Understand more about who uses the data
• Find out how your data is protected
• Be able to access the system to view, set or change your opt-out setting
• Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
• See the situations where the opt-out will not apply