PRIVACY POLICY

COVID-19 and your information – Updated on 8th April 2020

Supplementary privacy notice on Covid-19 for Patients

This notice describes how we may use your information to protect you and others during the Covid-19 outbreak.  It supplements our main Privacy Notice below.

The health and social care system is facing significant pressures due to the Covid-19 outbreak.  Health and care information is essential to deliver care to individuals, to support health and social care services and to protect public health.  Information will also be vital in researching, monitoring, tracking and managing the outbreak.  In the current emergency it has become even more important to share health and care information across relevant organisations.

Existing law which allows confidential patient information to be used and shared appropriately and lawfully in a public health emergency is being used during this outbreak. Using this law the Secretary of State has required NHS Digital; NHS England and Improvement; Arms Length Bodies (such as Public Health England); local authorities; health organisations and GPs to share confidential patient information to respond to the Covid-19 outbreak.  Any information used or shared during the Covid-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use the data.  Further information is available on the gov.uk website and there are also some FAQs on this law.

During this period of emergency, opt-outs will not generally apply to the data used to support the Covid-19 outbreak, due to the public interest in sharing information.  This includes National Data Opt-Outs. However in relation to the Summary Care Record, existing choices will be respected.  Where data is used and shared under these laws your right to have personal data erased will also not apply.  It may also take us longer to respond to Subject Access Requests (SARs), Freedom of Information requests (FOIs) and new opt out requests whilst we focus our efforts on responding to the outbreak.

In order to look after your health and care needs we may share your confidential patient information included health and care records with clinical and non-clinical staff in other health and care providers, for example neighbouring GP practices, hospitals and NHS 111. We may also use the details we have to send public health messages to you, either by phone, text message or email.

During this period of emergency we may offer you a consultation via telephone or video conferencing. By accepting the invitation and entering the consultation you are consenting to this.  Your personal/confidential patient information will be safeguarded in the same way it would with any other consultation.

We will also be required to share personal confidential patient information with health and care organisations and other bodies engaged in disease surveillance for the purposes of protecting public health, providing healthcare services to the public and monitoring and managing the outbreak.  Further information about how health and care data is being used and shared by other NHS and social care organisations in a variety of ways to support the Covid-19 response can be found on this NHSX page.

NHS England and Improvement and the NHSX have developed a single, secure store to gather data from across the health and care system to information the Covid-19 response.  This includes data already collected by NHS England, NHS Improvement, Public Health England and NHS Digital.  New data will include 999 call data, data about hospital occupancy and A&E capacity data as well as data provided by patient themselves. All the data held in the platform is subject to strict controls that meet the requirements of data protection legislation.

In such circumstances where you tell us you’re experiencing Covid-19 symptoms we may need to collect specific health data about you.  Where we need to do so, we will not collect more information than we require and we will ensure that any information collected is treated with the appropriate safeguards.

We may amend this Privacy Policy at any time so please review it frequently. The date at the top of this page will be amended each time this notice is updated.

 

Privacy Notice – Direct Care, (routine care and referrals)

The records we keep to enable us to look after you

This practice keeps data on you relating to who you are, where you live, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care.

When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS

GPs have always delegated tasks and responsibilities to others that work with them in their surgeries, on average an NHS GP has between 1,500 to 2,500 patients for whom he or she is accountable. It is not possible for the GP to provide hands on personal care for each and every one of those patients in those circumstances, for this reason GPs share your care with others, predominantly within the surgery but occasionally with outside organisations.

If your health needs require care from others elsewhere outside this practice we will exchange with them whatever information about you that is necessary for them to provide that care. When you make contact with healthcare providers outside the practice but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all of those reports. Normally we will receive equivalent reports of contacts you have with non NHS services but this is not always the case.

Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law.

People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments, the practice nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst the GP you see or speak to will normally have access to everything in your record.

You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests. Please see below.

We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.


1) Data Controller contact details

Vine Surgery Partnership
Hindhayes Lane
Street
Somerset
BA16 0ET
Tel: 01458 841122
Email: vinesurgery@nhs.net

2) Data Protection Officer contact details

Kevin Caldwell
GP Data Protection Officer
Somerset Clinical Commissioning Group
Wynford House
Lufton Way
Yeovil
Somerset
BA22 8HR
Tel: 01935 384000 
Email: somccg.GPDPO@nhs.net

3) Purpose of the  processing

Direct Care is care delivered to the individual alone, most of which is provided in the surgery. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.

4) Lawful basis for  processing

The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere  is supported under the following Article 6 and 9 conditions of the GDPR:

Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.

Article 9(2)(h) ‘necessary for the purposes of preventative 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 and services...”

Organisations and their employees will also respect and comply with their obligations under the common law duty of confidence.

5) Recipient or categories of recipients of the processed data

The data will be shared with Health and care professionals and support staff in this surgery and at hospitals, diagnostic and treatment centres who contribute to your personal care.

6) Rights to object and the national data opt-out

There are very limited rights to object when the law requires information to be shared but government policy allows some rights of objection as set out below.

NHS Digital

  • You have the right to object to information being shared with NHS Digital for reasons other than your own direct care.
  • This is called a ‘Type 1’ objection – you can ask your practice to apply this code to your record.
  • Please note: The ‘Type 1’ objection, however, will no longer be available after 2020.
  • This means you will not be able to object to your data being shared with NHS Digital when it is legally required under the Health and Social Care Act 2012.

The national data op-out model provides you with an easy way of opting-out of identifiable data being used for health service planning and research purposes, including when it is shared by NHS Digital for these reasons.

To opt-out or to find out more about your opt-out choices please go to NHS Digital’s website:

Public health

  • Legally information must be shared under public health legislation. This means that you are unable to object.

Care Quality Commission

  • Legally information must be shared when the Care Quality Commission needs it for their regulatory functions. This means that you are unable to object.

Court order

Your information must be shared if it ordered by a court. This means that you are unable to object.
7) Right to access and correct

You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.

8) Retention period

The data will be retained in line with the law and national guidance. See further information on the Retention Period or speak to the practice.

9) Right to Complain.

You have the right to complain to the Information Commissioner’s Office.

or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate).

There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website).

 


 

Website Privacy Policy

We are committed to protecting the privacy of all individuals using this website.

This policy explains how we use any personal information we collect from you through this website.

 

Collection of personal information

You can access most of the pages on our website without giving us your personal information. However, you may choose to provide us with your personal information on some pages of the website by completing an on-line form.

By submitting your personal information, you consent to our use of the information as set out in this privacy policy.

 

Use of personal information

We shall use any personal information you give to us, in accordance with this policy, and with any additional statements appearing on forms used for submitting your personal information. We shall not disclose your personal information to any third parties without obtaining your prior consent unless we are required by law to do so. In particular:

We shall use your personal information to administer, and may respond to, your request.

We shall securely store the information you supply together with any response we may provide.

If you contact us regarding the website we may use your details to reply to you. If you make a comment or complaint about other aspects of the service we may use your details to investigate your comments.

 

Website privacy

This website uses https to ensure data is encrypted in transmission. This encryption, known as TLS encryption protocol, allows us to protect your privacy. You can usually verify that the page is encrypted by seeing a small lock symbol in the upper left corner of your browser and the website address is prefixed with https://.

 

Data storage

All data obtained by us is held and used in compliance with the Data Protection Act 2018.

 

Cookie Policy

Please read our Cookie Policy.

 

Links

This website contains links to other sites. We are not responsible for the privacy practices of third parties that run any other websites. Please refer to their own privacy policies for more information.

 

Access to your personal information

You have a right under the Data Protection Act 2018 to ask us to provide you with the information we hold about you and to have any inaccuracies corrected. If you would like to access a copy of your information, please contact the Practice Manager using the following contact details in the heading above.

Website AccessibilitySurgery NewsFind Local ServicesConditions and Treatments

Self Help Advice and Tools

NHS 111

111 is the NHS non-emergency number. It’s fast, easy and free. Call 111 and speak to a highly trained adviser, supported by healthcare professionals.

Patient Access

Use Patient Access to book an appointment, order repeat prescriptions and view your medical record.

Patient Survey

How likely are you to recommend this Surgery to friends and family if they needed similar care or treatment? Please spend 2 minutes to take the Friends and Family Test.

View our results

NHS (nhs.uk)

The NHS website. Take control of your health and wellbeing. Get medical advice, information about healthcare services and support for a healthy life.

Patient UK

Patient is one of the most trusted medical resources online, supplying evidence based information on a wide range of medical and health topics to patients and health professionals.

Top of Page