Data Protection Privacy Notice for Patients
This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect
from or about you.
This privacy notice applies to personal information processed by or on behalf of the practice. This Notice explains:
- Who we are, how we use your information and our Data Protection Officer.
- What kinds of personal information about you do we process?
- What are 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 by us?
- What are your rights under data protection laws?
The General Data Protection Regulation (GDPR) became law on 24th May 2016.
This is a single EU‐wide regulation on the protection of confidential
and sensitive information. It enters into force in the UK on the 25th
May 2018, repealing the Data Protection Act (1998).
For the purpose of applicable data protection legislation (including
but not limited to the General Data Protection Regulation (Regulation
(EU) 2016/679) (the "GDPR"), and the Data Protection Act 2018 (currently
in Bill format before Parliament) the practice responsible for your
personal data is Khan Medical Practice.
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.
Khan Medical Practice (the Practice) will be what's known as the 'Controller' of the personal data you provide to
us.
We collect basic personal data about you which does not include any
special types of information or location‐based information. This does
however include name, address, 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 during the services we provide to you and or linked to your
healthcare through 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 (e.g. NHS Trust, GP Surgery, Walk‐in clinic, etc.). These
records help to provide you with the best possible healthcare.
NHS health records may be electronic, on paper or a mixture of both,
and we use a combination of working practices and technology to ensure
that your information is kept confidential and secure. Records which the
Practice hold about you may include the following information;
- Details about you, such as your address, carer, legal representative, emergency contact details
- 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
To ensure you receive the best possible care, your records are used
to facilitate the care you receive. Information held about you may be
used to help protect the health of the public and to help us manage the
NHS. Information may be used within the GP practice for clinical audit
to monitor the quality of the service provided.
How do we lawfully use your data?
We need to know 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.
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 a number of
sources including NHS Trusts and from this GP Practice. A risk score is
then arrived at through an analysis of your de‐ identified information
is only 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.
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.
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 Regulations (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 Khan
Medical Practice (the Practice) 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 to
inform you of services that may benefit you. We would like to use your
name, contact details and email address to inform you of services that
may benefit you, with your consent only. There may be occasions were
authorised research facilities would like you to take part on
innovations, research, improving services or identifying trends.
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.
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. 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
- NHS Commissioning Support Units
- Independent Contractors such as dentists, opticians, pharmacists
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services
- NHS England (NHSE) and NHS Digital (NHSD)
- 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 happen when this is required.
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 Khan Medical Practice (the Practice) an appropriate
contract (art 24‐ 28) will be established for the processing of your
information.
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 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 because
we deem it necessary for our legitimate interests to do so, and you do
not agree, you have the right to object. We will respond to your request
within 30 days (although we may be allowed to extend this period in
certain cases). Generally, we will only disagree with you if certain
limited conditions apply.
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 market to you, 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 30 days (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 generally assume that you would prefer us to keep a
note of your name on our register of individuals who would prefer not to
be contacted. That way, we will minimise the chances of you being
contacted 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.
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 the hospital you should write direct to them
- There is no charge to have a copy of the information held about you
- We are required to respond to you 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.
Objections / Complaints
Information Commissioner:
Wycliffe house
Water Lane
Wilmslow
Cheshire
SK9 5AF
☎ Tel: 01625 545745
Website:Click here to visit ICO website
If you are happy for your data to be extracted and 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:
The Practice Data Protection Officer is
Hayley Gidman, Head of Information Governance MLCSU
.
Any queries in regard to Data Protection issues should be addressed to:
Address: Heron House, 120 Grove Road, Fenton, Stoke-on-Trent, ST4 4LX
Email: mlcsu.dpo@nhs.net
☎ Tel: 01782 872648
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.
What is the Social Prescribing Service?
The Social Prescribing Service is a new service being offered through your GP Practice to Patients 18+
Social Prescribing Service is part of the NHS Long-Term Plan to make personalised care business as usual across the Health and Care System.
When you access your local Social Prescribing Service you will be allocated a Link Worker who will be able to support you to explore new services, activities and therapies enabling you to have more control over your own health and well-being.
What to expect from your Social Prescribing Service…
Contact your GP to access a Social Prescriber
The purpose of the service is to support you with your non-clinical needs (Physical, Mental, Financial, Educational and Social) and work with you to find the right services and support to help meet your needs.
Do you need support with any of the following?
How can the Social Prescribing Service help you?
Your Link Worker will work with you to develop a personalised support plan focusing on “what matters to you” and will provide ongoing support that meets your individual needs and enables you to achieve your goals.
Your Link Worker can support you to gain information, advice, guidance, support, as well as assisting you to access a range of services that meet your needs.
This may include: