GDPR and Privacy

Woodway Medical Centre

Privacy Notice

This privacy 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.

Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 1998 and the EU General Data Protection Regulations (GDPR).

GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.

This notice reflects how we use information for:

The management of patient records;
Communication concerning your clinical, social and supported care;
Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
Participation in health and social care research; and
The management and clinical planning of services to ensure that appropriate care

This information is publicly available on the Information Commissioners Office website www.ico.org.uk

Data Controller: Woodway Medical Centre

DPO: Judith Jordan

Email:

Tele: 0121 611 0730

As your registered GP practice, we are the data controller for any personal data that we hold about you.

What information do we collect and use?

All personal data must be processed fairly and lawfully, NHS records maybe 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 secure and confidential.

We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:

Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data. This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS Number; and

Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.

Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services). These records maybe electronic, a paper record or a mixture of both. We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.

What Details we collect about you?

The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training. To do this we will need to process your information in accordance with current data protection legislation to:

Protect your vital interests;
Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
Perform tasks in the public’s interest;
Deliver preventative medicine, medical diagnosis, medical research; and
Manage the health and social care system and services.

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 do we use this information? Risk Stratification

To ensure that you receive the best possible care, your records will be used to facilitate the care you receive. Information held about you may be used to protect the health of the public and to help us manage the NHS. Information may also be used for clinical audit to monitor the quality of the service provided. In addition, your information will be used to identify whether you are at risk of a future unplanned hospital admission and/or require support to effectively manage a long-term condition. 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.

How is the information collected?

Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection. In addition, physical information will be sent to your practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.

Who will we share your information with?

In order to deliver and coordinate your health and social care, we may share information with the following organisations:

Other GP Practices
NHS Trusts/Foundation Trusts
NHS Commissioning Support Units
Private sector providers
Clinical Commissioning Groups
Social Care Services
Health and Social Care Information Centre (HSCIC)
Local Authorities
Education Services
Fire and Rescue Services
Community Health and Care Trust
111 and Out of Hours Service
West Midlands Ambulance Service
Coventry City Council (Adult Social Services and Community Care)
Voluntary Support Organisations
Age UK, MIND
Children’s Local Safeguarding Board
Police and Judicial Serves
Coventry GP Connect Sharing agreement EMIS Enterprise
CWPT
UHCW
GP Alliance
Healthy Lifestyle
Other data processors which you will be informed of

Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations. You will be informed who your data will be shared with and in some cases asked for explicit consent when required.

We may also use external companies to process information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.

Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.

In addition, we received data from NHS Digital (as directed by the Department of Health) such as the uptake of flu vaccinations and disease prevalence in order to assist us to improve “out of hospital care”.

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information that has been collected lawfully. Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.

Information is not held for longer than is necessary. We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.

Primary Care Networks: This Practice is part of the Coventry GP Connect Primary Care Network

Other Member Practices of Coventry GP Connect are:

Network Member Practices

Windmill Surgery

Longford Primary Care Centre

George Eliot Medical Centre

Phoenix Family Care

Park House Surgery

Stoke Aldermoor Medical Centre

Woodway Medical Centre

GPAllinace Teaching Practices: Foleshill Surgery,

Stoke Aldermoor Surgery,

City of Coventry Healthcare Centre and Broad Lane Surgery

For the purpose of continued provision of healthcare, access to your health records could be disclosed to other healthcare professionals or specialising healthcare personnel working for Coventry GP Connect under implied consent. Particularly if patients require a review of their treatment and recording of outcomes of the review.

Consent and Objections

Do I need to give my consent?

The GDPR sets a high standard for consent. However, consent is only one potential lawful basis for processing information. Therefore, your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice. Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice. Your consent will be documented within your electronic patient record.

What will happen if I withhold my consent or raise an objection?

You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing. Please contact your GP Practice for further information and to raise your objection.

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 fair processing 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.

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.

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’. For further information about Type 2 Opt-Outs, please contact NHS Digital contact centre at referencing ‘Type 2 Opt-Outs – Data Requests’ in the subject line; or call NHS Digital on (0300) 303 5678; or visit the website http://content.digital.nhs.uk/article/7092/Information-on-type-2-opt-outs .

Health Risk Screening / Risk Stratification

Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health. By using selected information such as age, gender, NHS number, diagnosis, existing long-term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.

To summarise Risk Stratification is used in the NHS to:

Help decide if a patient is at a greater risk of suffering from a particular condition.
Prevent an emergency admission.
Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
Review and amend provision of current health and social care services.

Your GP will use computer-based algorithms or calculations to identify their registered patients who are at most risk, with support from the local Commissioning Support Unit and/or a third-party accredited Risk Stratification provider. The risk stratification contracts are arranged by NHS Coventry and Rugby Clinical Commissioning Group in accordance with the current Section 251 Agreement. Coventry CCG will not at any time have access to your personal or confidential data. They will only act on behalf of your GP to organise the risk stratification service with appropriate contractual technical and security measures in place.

Your GP will routinely conduct the risk stratification process outside of your GP appointment. This process is conducted electronically and without human intervention. The resulting report is then reviewed by a multidisciplinary team of staff within the Practice. This may result in contact being made with you if alterations to the provision of your care are identified.

A Section 251 Agreement is where the Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers.

As mentioned above, you have the right to object to your information being used in this way. However, you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.

Sharing of Electronic Patient Records within the NHS

Electronic patient records are kept in most places where you receive healthcare. Our local electronic systems EMIS enables your record to be shared with organisations involved in your direct care, such as:

GP practices
Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
Child health services that undertake routine treatment or health screening
Urgent care organisations, minor injury units or out of hours services
Community hospitals
Palliative care hospitals
Care Homes
Mental Health Trust
Hospitals
Social Care organisations
Pharmacies

In addition, NHS England have implemented the Summary Care Record which contains information about medication you are taking, allergies you suffer from and any bad reactions to medication that you have had in the past.

Your electronic health record contains lots of information about you. In most cases, particularly for patients with complex conditions and care arrangements, the shared record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health. Many patients are understandably not able to provide a full account of their care or may not be in a position to do so. The shared record means patients do not have to repeat their medical history at every care setting.

Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to disable this function or restrict access to specific elements of your record. This will mean that the information recorded by your GP will not be visible at any other care setting.

You can also reinstate your consent at any time by giving your permission to override your previous dissent.

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
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

Safeguarding
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.

Supporting Medicines Management
CCGs support local GP practices with prescribing queries which generally don’t require identifiable information. CCG pharmacists work with your practice to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is safe and cost-effective. Where specialist support is required e.g., to order a drug that comes in solid form, in gas or liquid, the CCG medicines management team will order this on behalf of the practice to support your care.

Invoice Validation

If you have received treatment within the NHS, the local Commissioning Support Unit may require access to your personal information to determine which Clinical Commissioning Group is responsible for payment for the treatment or procedures you have received. Information such as your name, address, date of treatment and associated treatment code may be passed onto the CSU to enable them to process the bill. These details are held in a secure environment and kept confidential. This information is only used to validate invoices in accordance with the current Section 251 Agreement and will not be shared for any further commissioning purposes.

Your Right of Access to Your Records

Under the new General Data Protection Regulation (GDPR) 2018, The Data Protection Act 1998 and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format. This is known as the “right of subject access”. If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information. This can be your GP, or a provider that is or has delivered your treatment and care. You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party. If you would like access to your GP record, please submit your request in writing to:

Woodway Medical Centre, 201 Wigston Road, Coventry CV2 2RH or alternatively request an access to records application form from reception.

We are required to respond to you within 40 days

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 Numbers & Email Addresses
If you provide us with your mobile phone number, we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.

We do use email to contact patients if they have consented to this.

Notification
Woodway Medical Centre is registered with the Information Commissioners Office (ICO) to describe the purposes for which they process personal and sensitive information. Our Registration Number is Z6470233.

We are a registered Data Controller and our registration can be viewed online in the public register at: http://ico.org.uk/what_we_cover/register_of_data_controllers

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 the Data Protection Act 1998. http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf

Data Retention
We will approach the management of 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.

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 not to have your information shared with the other NHS organisations; otherwise they 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 hold your records in strictest confidence.

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.
https://www.gov.uk/government/publications/the-nhs-constitution-for-england

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.
http://content.digital.nhs.uk/article/4963/What-we-collect

How Patient Data is collected and stored by the Practice and Clinical System provider

A data processor acting on our behalf, EMIS Health, is changing certain technical aspects of the way in which it delivers services to us (see https://www.emisnug.org.uk/blog/next-generation-emis-x-announced) , and as part of this transition it will be moving the data which it hosts on our behalf from its own data centre to a third party data centre, which is owned and operated by Amazon Web Services (AWS).

This will be from 10^th June 2019 when EMIS will start storing practice data in a highly secure, third party cloud hosted environment.

As detailed above, the data (which includes special category data (i.e. health data) which is collected via the processor’s clinical IT system and which forms the patient’s medical record) will be stored in a third party data centre (which will act on the instructions of EMIS Health, who in turn will act in accordance with instructions received from (or on behalf of) ourselves as the relevant controller pursuant to our call off contract under the GPSOC framework or as otherwise documented).

Data Protection Impact Assessments are carried out by the practice and the clinical system provider by regulation for any changes on how patient data is collected and stored.

Coventry and Warwickshire Integrated Care Record

Woodway Medical Centre works with other health and social care organisations to share information that will form part of your Integrated Care Record. The Integrated Care Record allows health and care professionals involved in your care to view your records to help them understand your needs and make the best decisions with you, and for you. Information we hold about you will be available, to read only, to other Health and care professionals in Coventry and Warwickshire, Birmingham and Solihull, and Herefordshire and Worcestershire when they are involved in your health or social care.

For more information on how your data is used on the Integrated Care Record and how to exercise your rights please see the full Privacy Notice or copy and paste this link https://www.happyhealthylives.uk/our-priorities/digital-transformation/integrated-care-record/privacy-notice/

Population Health Management

Health and Social Care Professionals across Coventry and Warwickshire are introducing two new electronic information systems to support with patient care. They will be able to see your information and analyse it to make quicker and safer decisions about healthcare.

You will automatically be opted into sharing your information onto these systems, but you have the right to object at any time.

Patient information will only be accessed by health and social care staff supporting their care. People can choose whether they want their confidential information to be used to support with their care.

Complaints

In the event that you feel your GP Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager at:

Woodway Medical Centre, 201 Wigston Road, Coventry CV2 2RH

If you are still unhappy following a review by the GP practice, you can then complain to:-

The Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or via their website www.ico.gov.uk. Tele: 0303 123 1113

If you are happy for your data to be extracted and used for the purposes described in this privacy notice, then you need not do anything.

Further Information
Further information about the way in which the NHS uses personal information and your rights in that respect can be found here: https://www.england.nhs.uk/contact-us/privacy/privacy-notice/your-information/

Reviews of and Changes to our Privacy Notice
We will keep our Privacy Notice under regular review.

This notice updated: Oct 2021 / Mar 2023