Privacy Policy
Fair Processing Notice (Privacy Notice)
Your Personal Information – what you need to know
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. 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
Our Commitment to Data Privacy and Confidentiality Issues
As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation. This includes the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.
Data we collect about you
Records which this GP Practice will hold or share about you will include the following:
· Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
· Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
· Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.
· Pseudonymised - The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
- Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place
· Aggregated - Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.
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 at Appendix A.
Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
• improving the quality and standards of care provided
• research into the development of new treatments
• preventing illness and diseases
• monitoring safety
• planning services
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.
How long do we hold information for?
All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for Health and Social Care 2016.
Your right to opt out of data sharing and processing
The NHS Constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’.
Type 1 Opt Out
This is an objection that prevents an individual's personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If patients wish to apply a Type 1 Opt Out to their record they should make their wishes know to the practice manager.
National data opt-out
The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.
By 2020 all health and care organisations are required to apply national data opt-outs where confidential patient information is used for research and planning purposes. NHS Digital has been applying national data opt-outs since 25 May 2018. Public Health England has been applying national data opt-outs since September 2018.
The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to National data opt out programme
To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.
On this web page you will:
• See what is meant by confidential patient information
• Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
• Find out more about the benefits of sharing data
• Understand more about who uses the data
• Find out how your data is protected
• Be able to access the system to view, set or change your opt-out setting
• Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
• See the situations where the opt-out will not apply
Right of Access to your information (Subject Access Request)
Under Data Protection Legislation everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access and you may find information has been redacted or removed for the following reasons;
· Does not cause harm to the patient
· That legal confidentiality obligations for the non-disclosure of third-party information are adhered to
You do not need to give a reason to see your data. And requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require.
Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the extra copies.
You will need to provide proof of identity to receive this information.
If you would like to access your GP record online click here https://www.thehousepartnershipsurrey.nhs.uk/
Change of Details
It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.
Mobile telephone number
If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile.
Email address
Where you have provided us with your email address, with your consent we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email please let us know.
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 at: http://ico.org.uk/what_we_cover/register_of_data_controllers
Any changes to this notice will be published on our website and in a prominent area at the Practice.
Data Protection Officer
Should you have any data protection questions or concerns, please contact our Data Protection Officer
What is the right to know?
The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However you can request this under a right of access request – see section above ‘Access to your information’.
Right to Complaint
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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 0303 123 1113 Website: https://ico.org.uk/global/contact-us
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.
http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf
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.
https://www.gov.uk/government/publications/the-nhs-constitution-for-england
Appendix A – The Practice will share your information with these organisations where there is a legal basis to do so.
Activity
Rationale
CCG
Purpose – Anonymous data is used by the CCG for planning and performance as directed in the practices contract.
We share information with our local Clinical Commissioning Group (CCG) about the care we provide and the health of our patients. This helps them to understand the needs of the local population and to support the design and development of local healthcare services. We also share information with the CCG to enable them to provide funding for the work we carry out. CCGs are not permitted to access identifiable information about patients for these purposes therefore we will only ever share anonymised, aggregate or de-identified data with them within this context.
Legal Basis – Contractual
Processor – Surrey Hearltands CCG
Summary Care Record
Purpose - 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.
Legal Basis – Direct Care
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, phone. If you wish to opt-out of having an SCR please return a completed opt-out form to the practice.
Processor – NHS England and NHS Digital
Research
Purpose – We may share personal confidential or anonymous information with research companies. Where you have opted out of having your identifiable information shared for this purpose your information will be removed.
Legal Basis – consent is required to share confidential patient information for research, unless there is have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales
For participation in specific research project, consent will be required eg Perspectum Ltd, of Gemini One, 5520 John Smith Drive, Oxford, OX4 2LL
Processor – Clinical Practice Research Data and NICE, Perspectum Ltd, UKIDS, Dare2Think/CPRD
Individual Funding Requests
Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our contracts.
Legal Basis - The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time
Data processor – GP
Safeguarding Adults
Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns.
Legal Basis - Because of public Interest issues, e.g. to protect the safety and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.
Data Processor – Safeguarding Team, MASH, Adult Social Care, Social Services as appropriate
Safeguarding Children
Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns.
Legal Basis - Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.
Data Processor – Safeguarding Team, Children Services, MASH, Social Services as appropriate
Risk Stratification - Preventative Care
Purpose - ‘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.
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.
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data
Legal Basis
GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2022 NHS England Risk Stratification which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.
Processors – Sollis, GraphNet
Public Health
Screening programmes (identifiable)
Notifiable disease information (identifiable)
Smoking cessation (anonymous)
Sexual health (anonymous)
Purpose – Personal identifiable and anonymous data is shared.
The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.
More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes [Or insert relevant link] or speak to the practice
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Data Processors Public Health England, the Jarvis Breast Centre, Royal Surrey County Hospital Bowel Screening, Primary Care Services England, Heath Intelligence and other NHS screening services.
NHS Trusts
Purpose – Personal information is shared with other secondary care trusts in order to provide you with direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.
Legal Basis - 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 as stated below:
Processors – Surrey and Sussex Trust
Care Quality Commission
Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.
More detail on how they ensure compliance with data protection law (including GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy-statement
Legal Basis - Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below
Processors – Care Quality Commission
Payments, Invoice validation
Purpose - Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QUOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.
Legal Basis - Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below
Data Processors – NHS England, CCG, Public Health
Patient Record Data Base
Purpose – Your medical record will be shared, in order that a data base can be maintained and managed in a secure way
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – EMIS
Medical reports
Subject Access Requests
Purpose – Your medical record may be shared in order that solicitors instructed on your behalf or insurance companies seeking a medical report can have a copy to your medical history for a specific purpose.
Legal Basis – Your explicit consent will be required before a GP can share your record for this purpose.
Processor – iGPR
Medicines Optimisation
OptimiseRX
AnalyseRX
Oberoi
Purpose – Your anonymous aggregated information will be shared in order to optimise medication. This will enable your GP to provide a more efficient medication regime for your personal care. Some of the anonymous information may be used nationally to drive wider understanding of the medication is used. No patients will be able to identified from the data shared.
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor - FDB
AccurRX
Purpose – Your anonymous information will be shared in order to optimise your medication within your record. This will enable your GP to provide a more efficient medication regime.
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – FDB
Medicines Management Team
Purpose – your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes can be implemented.
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor –Medicines Management Team
GP Federation
Services they provide include
GP Extended Access
Video consultations
Minor injuries services
COVID at Home
BP@ Home
CYP
Purpose – Your medical record will be shared with the federation in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended / enhanced access clinics, COVID@Home, BP@Home, CYP, Pharmacists, Physician Associates
COVID@Home and BP@Home both use the Inhealthcare platform to support the remote monitoring of patient health information.
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – Alliance for Better Care Ltd
PCN
Purpose – Your medical record will be shared with the network practices in order that they can provide direct care services to the patient population. Eg PA
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – Moat House and Wall House
Smoking cessation
Purpose – personal information is shared in order for the smoking cessation service to be provided.
Legal Basis – consented
Processor – Stop Smoking Service
Social Prescribers
Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their social care needs.
Legal Basis – Consented
Processors - Wellbeing Service (Social Prescribers), Voluntary services, Mental Health Provder (Surrey and Borders)
Subject Access Requests Requestors
Purpose – Personal information will be shared with the person or their representative at their request
Legal Basis – Contractual agreement with the patient – and consented
Processor – Patients and or their representatives – e.g. family members, solicitors, insurance companies
Medical Reports
Purpose – Personal information will be shared with Insurance companies, or potential or active employers at the patients request
Legal Basis – Consented
Processor – Patients and or their representatives – e.g. Insurance companies, RAF, Navy
Police
Purpose – Medical reports may be requested by the police for criminals
Legal Basis – Consented or Article 10 GDPR
Processor – Police Constabulary
Coroners
Purpose – Personal information may be shared with the coroner
Legal Basis – Legal Obligation
Processor – The Coroner
Private healthcare providers
Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patients request
Legal Basis – Consented and under contract between the patient and the provider
Provider – Via ERS
Texting Service
Purpose – Personal identifiable information shared with the texting service in order that text messages including appointment reminders, campaign messages related to specific patients health needs and direct messages to patients
Legal Basis – Consent from patients and direct care
Provider - AccuRX, Mjog
Remote consultation
Including – Video Consultation
Clinical photography
Purpose – Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice during the COVID-19 pandemic.
Legal Basis – Direct Care and Consent
Patients will be asked to provide consent if required to provide photographs of certain areas of concern. There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children.
Processor – e-Consult, AccuRX, Footfall
MDT meetings
Purpose – Personal information will be discussed with other providers of care, in order to provide a secure video meeting platform to discuss patients needs during the COVID-19 pandemic.
Legal Basis – Direct Care
Processor – MS Teams
COVID-19
Research and Planning
Purpose – for the collection of Personal confidential data regarding the diagnosis, testing, self-isolating, fitness to work, treatment medical and social interventions and recovery from Covid-19. To enable research and planning during the Covid-19 pandemic.
Legal Basis - Notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI), which were made under sections 60 (now section 251 of the NHS Act 2006) and 64 of the Health and Social Care Act 2001. Data will only be extracted for those patients who have consented to the process.
Provider - BioBank
General Practice Extraction Service (GPES)
Covid-19 Planning and Research data
Purpose : Personal confidential and Special Category data will be extracted at source from GP systems for the use of planning and research for the Covid-19 pandemic emergency period. Requests for data will be required from NHS Digital via their secure NHSX SPOC Covid-19 request process.
Legal Basis : NHS Digital has been directed by the Secretary of State under section 254 of the 2012 Act under the COVID-19 Direction to establish and operate a system for the collection and analysis of the information specified for this service: GPES Data for Pandemic Planning and Research (COVID-19). A copy of the COVID-19 Direction is published here:
Patients who have expressed an opt out preference via Type 1 objections with their GP surgery, not to have their data extracted for anything other than their direct care will not be party to this data extraction.
Processor : NHS Digital NHS X
General Practice Extraction Service (GPES)
At risk patients data collection Version 3
Purpose - The objective of this collection is on an ongoing basis to identify patients registered at General Practices who may be:
• clinically extremely vulnerable if they contract COVID-19
• at moderate or high risk of complications from flu or COVID-19
This General Practice Extraction Service (GPES) data will be extracted weekly and be used to assist in producing a weekly update of the Shielded Patient List (SPL).
The data, as specified by the DPN, supports the COVID-19 Public Health Directions 2020 from the Secretary of State for Health and Social Care. Organisations that are in scope of the notice are legally required to comply.
More information regarding this data collection can be found here:
COVID-19 at risk patients Data Provision Notices
Legal Basis - Sections 259(1)(a), 259(5) and 259(8) of the Health and Social Care Act 2012.
Where a patient’s record contains a defined long-term medical condition, which poses a COVID-19 risk and/or a condition/code which identifies a patient as being of moderate or high risk of complications from flu/COVID-19, data will be extracted for
Processor – NHS Digital or NHS X
Medication/Prescribing
Purpose : Prescriptions containing personal identifiable and health data will be shared with chemists/pharmacies, in order to provide patients with essential medication or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Where patients have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver medication
Legal Basis : Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Patients will be required to nominate a preferred pharmacy.
Processor – Pharmacy of choice
GP Registrar - trainee
Purpose – We are a GP training surgery. On occasion you may be asked if you are happy to be seen by one of our GP registrars. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE.
Legal Basis – 6 1 (a) consent, patients will be asked if they wish to take part in training sessions.
9 2 (a) - explicit consent will be required when making recordings of consultations
Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.
Processor – RCGP, HEE, iConnect, Fourteen Fish
Learning Disability Mortality Programme
LeDer
Purpose : The Learning Disability Mortality Review (LeDeR) programme was commissioned to improve the standard and quality of care for people with a learning disability.
Legal Basis: It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information without the patient’s consent.
Processor : Bristol University.
Technical Solution
Purpose: Personal confidential and special category data in the form of medical record, is extracted under contract for the purpose of pseudonymisation. This will allow no patient to be identified within the data set that is created. SCWCSU has been commissioned to provide a data processing service, no other processing will be undertaken under this contract.
Legal Basis: Under GDPR the legitimate purpose for this activity is under contract to provide assistance.
6 1 (e) Public Task
9 2 (h) Health Care
Processor: SCW CSU
Medication/Prescribing
Purpose : Prescriptions containing personal identifiable and health data will be shared with chemists/pharmacies, in order to provide patients with essential medication or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Where patients have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver medication
Legal Basis : Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Patients will be required to nominate a preferred pharmacy.
Processor – Pharmacy of choice
Anticoagulation Monitoring
Purpose: Personal Confidential data is shared with LumiraDX in order to provide an anticoagulation clinic to patients who are on anticoagulation medication. This will only affect patients who are within this criteria.
Legal Basis: The legal basis for this activity under UK GDPR is Article 6 1 (b) processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract.
Article 6 (e) Public Task (Direct Care) and 9 2 (h) Health Data
Processor : LumiraDX INRStar
Healthy.io - ACR project for patients with diabetes
This practice is working with a company called Healthy.io to provide a pilot programme sponsored by NHS Digital to monitor urine albumin:creatinine ratio (ACR) annually for patients with diabetes. This enables patients with diabetes to test their kidney function from home. With your permission, 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 those at risk of kidney disease and proactively manage early interventions for the benefit of patient care. If you do not wish to be contacted by Healthy.io, you will have the opportunity to say so by replying to the text message sent from our practice and when you will be contacted by Healthy.io onboarding team.
GPiMHS
This practice works alongside SABP who provide the GP Integrated Mental Health Service (GPiMHS) from within our GP practice. If you and your GP agree that you would benefit from the GPiMHS, you will be referred to the service. The clinicians employed by SABP that are responsible for providing treatment under the GPiMHS will have access to your GP record in order to provide the best care to you. For more information about the GPiMHS see www.sabp.nhs.uk/application/files/6515/8919/0608/CMHTP_-_GPimhs_MHICS_Privacy_Notice_v1.0.pdf
MMS Therapy Optimisation Programme for Stroke Prevention in Non-Valvular Atrial Fibrillation
Practice receives support from a range of third-party organisations as data processors who are engaged under a legal contract and will only process personal confidential data under the written instructions of the Practice.
VTRACE Visitors Management system
At The House Partnership we use VTRACE Visitors Management system to collect the following visitor information: First Name, Last Name, Email Address, Vehicle Reg, Visitor Type, who they are visiting. All events are automatically dated and time stamped.
This data is being collected using VTRACE to ensure GDPR compliance is maintained when collecting visitor records of all attendees, visitors or staff entering or leaving the building. It provides constant and convenient visibility of individuals on premises especially in the case of an emergency.
The VTRACE client, which is installed on each PC using VTRACE, uses an https connection to the VTRACE server where data is stored. This is a secure, remote Server hosted by Codegate. Codegate’s secure hosted environment conforms to current guidelines from the National Cyber Security centre. Data transfer is encrypted using AES128 and the https protocol uses TLS 1.2 (with approved Cipher suites) or higher. Furthermore, this is underpinned by Codegate’s Cyber Essentials Plus, ISO 27001 and ISO 9001 accreditations.
User Access to VTRACE is protected by Local Authentication comprising of a Unique User Identity and Password. The User enters a secure Password using a combination of Upper and Lowercase Letters, Numbers, Punctuation and Special Symbols.
Data is stored for a default of 30 days in accordance with the GDPR notice but this can be set to Zero to delete the data in instances where visitors do not want their data to be retained.
SAFE Panic Button system
At The House Partnership we use SAFE (Send Alert for Emergency) which is a simple PC Based Panic Button system which allows users to send an emergency alert to other machines on a network, raising the alarm for immediate
assistance.
All the SAFE Alerts are recorded in a Log on the secure hosted server. This includes the following: - Date and Time stamp of the Alert; Location of Alert i.e., Room Name, Number or Location identity assigned during set-up); Location of Acceptance response.
The purpose of retaining a SAFE Log file is to provide an Audit of an incident should we require it. The log is retained for a period of 12 months before deletion.
SAFE is NOT intended to store any personal or patient data and will be used as a standalone system working autonomously from other systems such as emis.
Child Health Information Services
The House Partnership work with Child Health to support the direct care of patients. Health screening, physical examination and vaccination services are monitored to ensure that every child has access to all relevant health interventions.
Information Child Health process includes Demographics, NHS number, Ethnicity, Newborn Bloodspot and Newborn Hearing, Newborn and Infant Physical Examinations, Vaccination and Immunisations status, Looked After Children status. They record demographics and HepB status for mothers and mothers-to-be. SCW CHIS maintains a record of all children resident in the areas they look after. This includes children aged 0-19 years old and older where they are known to have a special educational need (up to the age of 26) and their mothers/related parties, and mothers-to-be.
All information is managed in accordance with the NHS Code of Practice for Records Management. The CHIS will maintain a record of all children from birth up to the age of 19 (up to the age of 26 for children with special educational needs and/or disabilities). If a new CHIS provider is appointed, the data will be securely transferred to the new provider under instruction from NHS England.
SCW CHIS ensures all personal data is processed in a secure way and access is strictly controlled.
Examples of their security include:
- Encryption – meaning that the information is hidden so that it cannot be read without special knowledge (such as a password).
- Controlling access to systems and networks, this allows us to stop people who are not allowed to see the data from accessing it.
- Controlling access for different user roles, so only certain data required for a specific role is accessible.
- Training our staff to ensure they know how to responsibly and securely handle data
- Regular testing of our technology including keeping up with the latest security updates.
- We do not process any personal data outside of England.
- Third-party contracts are regularly reviewed and updated
Zonder
Purpose:
Zonder is used by the practice to support and improve patient care and practice efficiency. This includes assisting with the management, analysis and processing of patient information to help clinicians and staff make informed decisions, improve communication, and enhance the delivery of healthcare services.
Legal Basis:
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases relied upon are:
- Article 6(1)(e) – Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
- Article 9(2)(h) – Processing is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems and services.
Processor: Zonder acts as a data processor on behalf of the practice. Data is processed only in accordance with the practice’s instructions, under a contractual agreement that meets UK GDPR requirements, and appropriate technical and organisational measures are in place to protect patient data. Zonder does not use patient data for its own purposes and does not sell or share data for marketing.
Abtrace
Purpose:
Abtrace is used by the practice to support population health management and improve patient care. It helps identify patients who may benefit from review, monitoring or intervention, particularly for long-term conditions, by analysing clinical data held within the practice’s clinical systems. This supports proactive, preventative and personalised care.
Legal Basis:
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases relied upon are:
- Article 6(1)(e) – Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
- Article 9(2)(h) – Processing is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems and services.
Processor:
Abtrace acts as a data processor on behalf of the practice. Patient data is processed strictly in line with the practice’s instructions and under a Data Processing Agreement that meets UK GDPR requirements. Appropriate technical and organisational safeguards are in place to ensure the confidentiality and security of patient information. Abtrace does not use patient data for marketing purposes and does not sell patient data.
OpenSAFELY COVID-19 and Data Analytics Services
Purpose:
NHS England has been directed by the government to establish and operate the OpenSAFELY COVID-19 Service and the OpenSAFELY Data Analytics Service. These services provide a secure environment that supports research, clinical audit, service evaluation and health surveillance for COVID-19 and other purposes.
Each GP practice remains the controller of its own GP patient data but is required to let approved users run queries on pseudonymised patient data. This means identifiers are removed and replaced with a pseudonym.
Only approved users are allowed to run these queries, and they will not be able to access information that directly or indirectly identifies individuals.
Legal Basis –
UK GDPR – Article 6 basis:
UK GDPR Article 6(1)(c) - processing is necessary for compliance with a legal obligation to which the controller is subject (the Directions).
UK GDPR Article 9 basis:
UK GDPR Article 9(2)(g) - processing is necessary for reasons of substantial public interest, on the basis of domestic law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject, by virtue of compliance with a direction supplemented by:
Patients who do not wish for their data to be used as part of this process can register a type 1 opt out with their GP.
Here you can find additional information about OpenSAFELY.
Processor:
NHS England
The House Partnership
EMIS
Reviews of and Changes to our Privacy Notice
We will keep our Privacy Notice under regular review. This notice was last reviewed in December 2025.
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…’; and
- 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...”
Rights to Object
You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.