Privacy Notice

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.

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 and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form. The records will include basic details about you, such as your name and address. They will also contain more sensitive information about your health and also 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 (e.g. from Hospitals, GP Surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

Records which this GP Practice will hold about you will include the following:

• Details about you, such as your address 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

How we keep your information confidential and safe

Everyone working for our organisation is subject to the Common Law Duty of Confidence.  Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law.  The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.  All our staff are expected to make sure information is kept confidential and receive regular training on how to do this.

The health records we use will 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.  Your records are backed up securely in line with NHS standard procedures.  We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.

We also make sure external data processors that support us, for example, companies who provide mailing services, text messaging services and shredding services, 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 are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• Data Protection Legislation
• General Data Protection Regulation
• Human Rights Act
• Common Law Duty of Confidentiality
• NHS Codes of Confidentiality and Information Security
• Health and Social Care Act 2015
• And all applicable legislation

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care.

For example it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed.  This is explained further in the Local Information Sharing section below.

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.

You can choose to withdraw your consent to your personal data being shared for these purposes. When we are about to participate in a new data-sharing project we will display prominent notices in the Practice and on our website at least four weeks before the scheme is due to start. Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.

You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.

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.

Assessing Treatment Outcomes

Information is used by Berkshire Healthcare Foundation Trust (BHFT) to assess the effectiveness of providing psychotherapy treatment to patients with long term conditions.  NHS numbers and a summary of the number of visits to the practice before and after treatment is shared with BHFT.  If you do not wish your information to be shared for this purpose please let your GP know.

Child Health Information

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS Berkshire Health Foundation Trust health visitors and school nurses, and with SCW CHIS (South Central & West Childhood Immunisation Service), who provide the Child Health Information Service in Berkshire on behalf of NHS England.

Clinical audit

Information will be used by Buckinghamshire, Oxfordshire and Berkshire West (BOB) Integrated Care System for clinical audits to monitor the quality of the service provided to patients with long terms conditions. When required, information will be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

Clinical Research

We get requests from organisations to use our information for research purposes – we will always ask your permission before releasing any information for this purpose.

Improving Diabetes Care

Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led local diabetes review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.

ACR project for patients with diabetes (and/or other conditions)

The data is being processed for the purpose of delivery of a programme, sponsored by NHS Digital, to monitor urine for indications of chronic kidney disease (CKD) which is recommended to be undertaken annually for patients at risk of chronic kidney disease e.g., patients living with diabetes. The programme enables patients to test their kidney function from home.

We will share your contact details with Healthy.io to enable them to contact you and send you a test kit. This will help identify patients at risk of kidney disease and help us agree any early interventions that can be put in place for the benefit of your care. Healthy.io will only use your data for the purposes of delivering their service to you.

If you do not wish to receive a home test kit from Healthy.io we will continue to manage your care within the Practice. Healthy.io are required to hold data we send them in line with retention periods outlined in the Records Management code of Practice for Health and Social Care.

Further information about this is available on the Healthy.io website

Individual Funding Request

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for funding of specialised healthcare which falls outside the range of services and treatments that BOB Integrate Care System has agreed to commission for the local population.

An Individual Funding Request is taken under consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment.

A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to identify which CCG or Integrated Care System is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes.

We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

Local Information Sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a health professional such as an Emergency Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if relevant information from your GP record is available to them.

Where available, this information can be shared electronically with other local health and care providers via a secure system designed for this purpose. Depending on the service you are using and your health and care needs, this may involve the professional accessing a secure system that enables them to view relevant parts of your GP electronic patient record (e.g. Connected Care or your Summary Care Record).

In all cases, your information is only accessed and used by authorised health and social care professionals in Berkshire based organisations who are involved in providing or supporting your direct care. Your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).

National Fraud Initiative – Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under Data Protection legislation. Data matching by the Cabinet Office is subject to a Code of Practice.

For further information see Code of data matching practice for national fraud initiative

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

Risk Stratification

‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.

Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information.  This can help us identify and offer you additional services to improve your health.

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the Berkshire West NHS Clinical Commissioning Group. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes.

Further information about risk stratification is available from NHS England

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.

Safeguarding

To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in circumstances where it is legally required for the safety of the individuals concerned.

Summary Care Record (SCR)

The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.

Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, fax or phone.

If you wish to opt-out of having an SCR please make an appointment with your GP to discuss the implications of this.

Supporting Medicines Management

Buckinghamshire, Oxfordshire and Berkshire West (BOB) Integrated Care System operates pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared.

These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective.

Where specialist prescribing support is required, the Buckinghamshire, Oxfordshire and Berkshire West (BOB) Integrated Care System medicines optimisation team may order medications on behalf of your GP Practice to support your care.

Supporting Locally Commissioned Services

Buckinghamshire, Oxfordshire and Berkshire West (BOB) Integrated Care System supports GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality.  The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

Data Retention

We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.

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
• Specialist Trusts
• GP Federations
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police
• Other ‘data processors’

We will never share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function.

Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy for your information to be shared unless you choose to opt-out (see below).

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional.

There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued.  Our guiding principle is that we are holding your records in strictest confidence.

Your right to withdraw consent for us to share your personal information (Opt-Out)

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 do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately.

We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.

We are required by law to share some data from patients’ clinical records with NHS Digital under the General Practice Data for Planning and Research Directions 2021. For more information, including how to opt-out of sharing of your records, please see more info at NHS Digital: GP Privacy Notice.

There are two main types of opt-out:

Type 1 Opt-Out

If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’.  

This prevents your confidential personal information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease.

National Opt-Out (Also known as Type 2 Opt-Out)

NHS Digital collects information from a range of places where people receive care, such as hospitals and community services. If you do not want your personal confidential information to be shared outside of NHS Digital, for purposes other than for your direct care, you can register a ‘Type 2 Opt-Out’.

Find further information about Type 2 Opt-Outs

If you wish to discuss or change your opt-out preferences at any time please contact the surgery.

Access to your information

Under Data Protection Legislation everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions.

You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.

We may charge a reasonable fee for the administration of the request. If you wish to have a copy of the information we hold about you, please contact the surgery.

Record scanning

All paper patient records are being scanned directly onto the patient records and paper copies destroyed.  This means that we will no longer keep paper records.  The provider of the service ensures that the records are safe and confidential and security standards have been reviewed by Berkshire West CCG.

Telephone Calls

All telephone calls to and from and within the surgery are encrypted for security using our new telephony provider.  The calls are recorded for training and monitoring purposes. All recordings are encrypted, and password protected and retained securely. If you do not wish for your telephone consultation to be recorded, please inform the staff member at the start of the consultation.

Video Consultations

Occasionally our Clinicians may feel that a video consultation is the most appropriate way of consulting with you.  In such circumstances we use a system approved by the NHS that is secure and encrypted. The calls are not recorded and all other data recording and note taking is the same as in a face-to-face consultation.

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.

Mobile telephone number and text messaging

If you provide us with your mobile phone number, we may use this to send you reminders about your appointments, confirmation of referrals, chronic conditions recalls or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.  We use an encrypted system to ensure sensitive and personal information sent via text messaging is kept secure.

Email Address

Where you have provided us with your email address, we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communication by email, please let us know.

NHS App

We use the NHS Account Messaging Service provided by NHS England to send you messages relating to your health and care. You need to be an NHS App user to receive these messages.

Further information about the service can be found at the privacy notice for the NHS App, managed by NHS England

Notification

Data Protection Legislation 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 on the ICO website.

Data Protection Officer (DPO)

Should you have any data protection questions or concerns please contact our Data Protection Officer.

Complaints

If you have concerns or are unhappy about any of our services, please contact the Practice Manager.

For independent advice about data protection, privacy and data-sharing issues, you can contact the Information Commissioner

Further Information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found at NHS Digital: The NHS Constitution.

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under Data Protection Legislation.

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to.

These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong.

NHS Digital

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

Reviews of and Changes to our Privacy Notice

We will keep our Privacy Notice under regular review. This notice was last reviewed in March 2023.

Any changes to this notice will be published on our website and in a prominent area at the practice.