EMIS, the clinical system we use as a practice for our appointments and patient information, has moved it’s online storage to a facility run by Amazon. They informed us of this on 31st May 2019, please see the attached document detailing the actions taken to ensure it is secure. This document is called a Data Protection Impact Assessment (DPIA) and it is part of the Data Protection 2018 regulations.
Please be assured that this move was subject to the terms of the GP Systems of choice Framework (GPSOC) which is managed by NHS Digital on behalf of the the Secretary of State for Health.
There is no change to how you access your information or the security of your information.
If you have any questions please contact the surgery and ask for a message to be sent to Julie Ball, Practice Manager.
Clifton Road Surgery
Fair Processing Notice
This fair processing notice explains why our Practice collects information about you and how that information may be used and shared.
The employees and partners of the Practice use electronic and paper records to create and maintain an in-depth history of your NHS medical care at the Practice and elsewhere, to help ensure you receive the best possible healthcare. Anyone who accesses your data within the practice can only do so using a ‘smartcard’ that identifies him/her and what he/she accessed.
We comply with Data Protection Act in ensuring your personal information is as confidential and secure as possible.
Information Governance - The GP Information Governance for our Practice is provided by Arden and GEM CSU. Our named Data Protection Officer (from Arden and GEM CSU) is Judith Jordan email: firstname.lastname@example.org
WHAT INFORMATION DO YOU HOLD?
Records which this GP Practice hold about you may include the following information:
- Details about you, such as your address, legal representative, emergency contact detail
- Any contact the surgery has had with you, such as appointments, telephone conversations and letters
- Notes and reports about your physical (including sexual) and mental health
- Details about your treatment and medications
- Results of investigations such as laboratory tests, x-rays etc.
- Relevant information from other health professionals, relatives or those who care for you
- Reports from social services such as child protection reports or police reports if relevant to the care of you or your family
- Private reports sent, at your request, to other organisations.
We are committed to protecting your privacy and will only use information collected lawfully in accordance with the Data Protection Act 1998 (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 and contractors 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.
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 new information sharing principle i.e. “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. They should be supported by the policies of their employers, regulators and professional bodies.
Your information may be used within the GP Practice for clinical audit to monitor the quality of the service provided or ensure we are providing appropriate care.
SHARING YOUR DATA OUTSIDE THE PRACTICE
Information held about you may be used to help protect the health of the public and to help the Department of Health manage the NHS. Some of this information will be extracted and held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified.
We currently only share information from your records on an individual basis either by fax, letter or courier but with improvements in information technology and strict information governance standards, it is becoming possible to share your GP records across Coventry & Warwickshire Health & Social Care. We will only allow this to happen with your consent, so that you are able to allow doctors, nurses and other health and social care services to see all the information held on your GP records.
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
- Clinical Commissioning Groups and NHS England
- Social Care Services and Local Authorities
- Police, Fire and Rescue Services.
Any patient can choose to withdraw their consent to their data 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. These schemes are only for direct care so you (or your carer) will be present when the information is accessed and will be asked for consent again, before your records are opened.
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.
Third party processors
In order to deliver the best possible service, the practice will share data (where required) with other NHS bodies such as other GP practices and hospitals. In addition the practice will use carefully selected third party service providers. When we use a third party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties includes:
- Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
- Delivery services (for example if we were to arrange for delivery of any medicines to you).
- Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).
Further details regarding specific third party processors can be supplied on request.
Risk stratification is a process for identifying and managing patients who are at a higher risk of emergency hospital admission. This may be because patients have a long term condition such as COPD, cancer or are more frail. NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and help reduce the patients’ risk of hospital admissions.
Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. Your risk is then ‘scored’ after 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.
The Health and Social Care Act 2012 allows NHS Digital to collate personal confidential data from GP practices without seeking your specific consent. This is extracted in order to make increased use of information from medical records and either used just by the NHS with the intention of improving healthcare and the quality of care delivered to patients or may be sold to external companies such as universities or commercial organisations. Please see below if you do not want your data used in this way.
WHAT IF I WANT TO SEE MY RECORDS?
You have a right under the Data Protection Act 1998 to access/view information the Practice holds about you, and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject access’. We are very keen for you to have access to help you manage your own health and maintain the quality of the records about your health. With some provisos, we are now able to give most adults access to their records on-line if they wish. If you would like access on-line, please ask our receptionists.
You can request a copy of your records in paper form. If you wish to do this, you will need to do the following:
Your request must be made in writing to the GP. Under GDPR this is free for the first copy set; thereafter there maybe a charge.
You can also view all your records on-line. This gives you instant and up-to-date access. For further details on how to do this visit the 'Clinics & Services' then 'Accessing Medical Records' sections on our website.
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
WHAT IF I WANT TO SEE WHO HAS ACCESSED MY RECORDS?
You can look at your GP Shared Record History on EMIS web to find out when your GP record has been accessed. All you need is the username and password you use to order prescriptions or make appointments via our website. (If you have chosen to have sharing functionality disabled this will not be available.) This only covers instances where your record has been accessed outside your GP practice for direct care purposes, i.e. it does not cover accesses by your own GP, and it does not cover the data that gets copied for research and to NHS Digital.
The Data Protection Act 1998 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.
This information is publicly available on the Information Commissioners Office website www.ico.org.uk
The practice is registered with the Information Commissioners Office (ICO) as a data controller under the Data Protection Act 1998. The registration number is Z5146666 and can be viewed online in the public register at http://ico.org.uk/what_we_cover/register_of_data_controllers
Should you have any concerns about how your information is managed at the practice, please contact the GP Practice Manager. If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) via their website (www.ico.gov.uk).
If you are happy for your data to be extracted and used for the purposes described in this fair processing notice then you do not need to do anything.
If you do not want your personal data being extracted and leaving the GP practice for any of the purposes described, you need to let us know as soon as possible so please speak to the receptionist.
There are 3 levels of opt-out to prevent your data being shared. Each opt-out requires the practice to add a different code to your medical notes. (Please be aware that certain regulation such as child protection and court orders may over-rule your choices.)
- You do not want your data to leave the practice even for direct patient care. (9Ndo Express dissent for Summary Care Record dataset upload)
- You are happy to share your data for your care but do not want NHS Digital extracting your data. (9Nu0 Dissent from secondary use of GP patient identifiable data)
- You are happy to share your data for your care and improving public health but do not want NHS Digital selling or sharing your data to third parties. (9Nu4 Dissent from disclosure of personal confidential data by Health and Social Care Information Centre)
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.
Please also see our section on "Your Medical Record and GDPR" and "Privacy Notice". These can be found in the 'Clinics & Services' section on our website.