Privacy Notice: Banbury Cross Health Centre
Your information, what you need to know
This privacy notice explains why we collect information about you, how that information may 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 may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form. The records may include basic details about you, such as your name and address. They may 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 may hold about you may 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 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. 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 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 Act 2018
- General Data Protection Regulation 2018
- 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.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.
What are your rights?
Since GDPR you have important rights to protect your personal data. You can access any of these rights by contacting us. The following is a summary of those rights:
- Right to be informed – individuals have the right to be informed about the collection and use of their personal data.
- Right of Access – you have rights to request access to the personal data we hold about you
- Right of rectification – you have the right to request the correction of inaccurate or incomplete information recorded in the record, subject to certain safeguards.
- Right to erasure – you have the right to refuse/withdraw consent to the storing of personal information and for it to be erased from our records if it is beyond the purpose for which it is collected and held.
- Right to restrict processing – where certain conditions apply, you have a right to restrict the processing.
- Right of portability – you have the right to request personal information to be transferred to others on certain occasions.
- Right to object – individuals have the right to object to the processing of their personal data in certain circumstances e.g. being used for direct marketing. Objections can be made verbally or in writing.
We will not be able to erase or cease processing personal information that is required to maintain our business purpose, we have a legal reason to keep it, or required to facilitate your contract with us. 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. Should you decide in the future that you want to opt out of receiving communications, or cease to be the point of contact for your organisation, please contact us, at which point all of the personal data we hold for you would be deleted with the exception of information we may still be legally required to hold.
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 may choose to withdraw your consent to 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.
ou 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.
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 Oxford Health Foundation Trust health visitors and schoolnurses, and with NHS South Central and West Commissioning Support Unit, who provide the Child Health Information Service in Oxfordshire on behalf of NHS England.
Information may be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may 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.
Sometimes your information may be requested to be used for research purposes – we will always ask your permission before releasing your 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.
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 CCG 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 is an important process. It involves using your NHS number to check which CCG 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 local health or care professional outside of your usual practice services, such as in an Evening and Weekend GP Access Clinic, GP Federation Service, Emergency Department, Minor Injury Unit, Urgent Care Centre or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them.
Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view parts of your GP electronic patient record (e.g. Oxfordshire Care Summary or your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. EMIS remote consulting system).
In all cases, your information is only accessed and used by authorised staff 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 the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice.
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 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 Oxfordshire NHS Clinical Commissioning Group (OCCG). Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes.
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.
To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s 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 optout of having an SCR please return a completed and signed opt-out form to the practice.
Supporting Medicines Management
Oxfordshire CCG and some Oxfordshire GP Federations operate 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 CCG medicines management team may order medications on behalf of your GP Practice to support your care.
Supporting Locally Commissioned Services
CCGs support 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.
Suspected Cancer Data
may be analysed in cases of suspected cancer by Nuffield Department of Primary Care Health Sciences, Oxford University to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual 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.
eMR+ by medi2data
Our practice has decided to outsource our medical reporting work to an NHS Digital accredited company called MediData.
MediData will be processing your medical report via eMR and providing online access via their secure encrypted portal.
If you wish to contact MediData directly, please email firstname.lastname@example.org or call on 03333 055774.
Digitisation of paper medical records
The NHS Long Term plan published in 2019 requires the digitisation of all primary care paper medical records, commonly known as ‘Lloyd George’ records or ‘A4 medical records’
Having paper based medical records restricts the use of technology to provide ‘joined up’ services and therefore the current paper records will be transferred to a digital format and then destroyed.
This will involve the current patient paper medical records being scanned and then entered directly into a patient’s electronic medical record. This work will be completed by a third-party supplier, Iron Mountain UK plc, whose security standards have been reviewed by Oxfordshire Clinical Commissioning Group.
We are required by Data Protection law to provide you with the following information about how we handle your information.
Data Controller contact details
Banbury Cross Health Centre South Bar House Banbury OX16 9AD
Data Protection Officer contact details
Carolyn Abbisogni 01295 256261
Purpose of the processing
Transferring the current paper medical records into patients’ electronic medical records.
Lawful basis for processing
The following provisions of the General Data Protection Regulation permit us to digitise existing paper medical records:
- Article 6(1)(e) – ‘processing is necessary…in the exercise of official authority vested in the controller...’’
- Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services...’
Recipient or categories of recipients of the processed data
The paper patient records will be shared with Iron Mountain UK plc, who will scan and digitise the current paper medical records before destroying them.
Right to access and correct
You have the right to access your medical record and have any errors or mistakes corrected. Please speak to a member of staff or look at our ‘subject access request’ policy on the practice website
GP medical records will be kept in line with the law and national guidance. Information on how long records can be kept can be found on the NHS Website or speak to the practice. The paper medical records will be destroyed three months after they are transferred to an electronic format.
The practice holds medical records to provide medical treatment and advice and patients have a relationship with a GP in order for them to be provide health and care service to you. We therefore do not require your consent to transfer these papers records to an electronic format.
Details of Supplier: Iron Mountain UK Plc Ground Floor, 4 More London Riverside, London SE1 2AU United Kingdom.
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 Group
- Social Care Services
- Local Authorities
- Education Services
- Fire and Rescue Services
- EMR+ by Medi2data
- Other ‘data processors’
- Approved Courier Services
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 to 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 wishyour information to be used for any purpose other than your care but in some circumstances wemay still be legally required to disclose your data.
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 personal confidential 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 Data Opt-Out (formerly 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 for the National Opt-Out.
Access to your information
Under the Data Protection Act 2018 and General Data Protection Regulation 2018 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 Banbury Cross Health Centre.
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
If you provide us with your mobile phone number we may use this to send you reminders about your appointments or other health information. Please let us know if you do not wish to receivereminders on your mobile.
The Data Protection Act 2018 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.
Any changes to this notice will be published on our website and in a prominent area at the Practice.
For independent advice about data protection, privacy and data-sharing issues, you can contact:
The Information Commissioner
- Phone: 0303 123 1113
- Online: visit the ICO website
Further information about the way in which the NHS uses personal information and your rights in that respect can be found here:
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 programmes available to you, confidentiality, information and your right to complain if things go wrong.
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 April 2022
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