Privacy Notice

This page was last updated: February 2024

 

Fair Processing Notice under the Data Protection Act 2018 - How we use your personal information

This fair processing notice explains why the GP practice collects information about you and how that information may be used.

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. NHS Trust, GP Practice, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology solutions to ensure that your information is kept confidential and secure. Records which this practice hold about you may include the following information:

• Details about you, such as your address, carer, legal representative, emergency contact details, next of kin
• Any contact the practice has had with you (the patient), such as appointments, telephone, eConsults, emails submitted by you, 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

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. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided. Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – if this information needs to be identifiable, the practice will always gain your explicit consent before releasing the information for this purpose. For more information on this, please see the practice's Research page.

 

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• General Data Protection Regulations 2018 (formerly Data Protection Act 1998) 
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management
• Information: To Share or Not to Share Review

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. Any visitor to the premises who will or could be exposed to your identifiable information will sign a confidentiality agreement.

We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the new information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.

 

---

Risk Stratification  

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP practice. A risk score is then arrived at through an analysis of your anonymised information using software managed by our clinical system provider and is only provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. 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.

 

Medicine Management

The practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost effective treatments. This service is provided by pharmacists and Technicians employed by West Hampshire Clinical Commissioning Group and / or ESP Network Ltd. They are bound by the same confidentiality rules as our staff are.

 

ESP Hub, Care Navigators, Social Prescribers and Health & Wellbeing Coaches

The Eastleigh Southern Parishes (ESP) Hub is an organisation that operates across the ESP Network practices. It offers evening, weekend and bank holiday appointments with a number of clinicnans, including GPs, Nurses, Musculoskeletal practitioners or Mental Health practitioners. By booking an appointment with ESP Hub, patients are explicitly consenting to The Hub staff accessing their medical records to provide medical care.

In addition, the practice works alongside ESP Network (Eastleigh Southern Parishes Network Ltd.) who employs the Care Navigators, Social Prescribers and Health & Wellbeing Coaches. These are non-clinical staff whose role is to help our patients manage the Health and Social care system. They have access to patients' records via their own clinical system when the patient has explicitly consented to this.

From August 2022, any notes recorded via the above staff / services will automatically file back to the practice's medical record.

 

Southern Health Support Team

The practice also works alongside Southern Health which employs various community teams (listed below). In order for this team to accurately manage their patient caseload's care, they have access to patient records via the practice's clinical system.

• Complex Care Team
• District Nurses
• Frailty Team
• Leg Ulcer Service
• Midwives

 

---

Who are our partner organisations?  

• NHS Trusts / Foundation Trusts
• Integrated Care Boards (ICB) such as Hampshire & Isle of Wight ICB, including the ICB Pharmacy and Significant Incidents teams and NHS Frimley ICB for the South East Complaints Team
• Other GP Practices
• NHS England via the General Practice Extraction Service (GPES)
• NHS Commissioning Support Units (including for Individual Funding Requests)
• Independent Contractors such as Dentists and Opticians
• Chemists / Pharmacists, including prescriptions
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Multi Agency Safeguarding Board (MASH) - Safeguarding Adults / Children
• Social Care Services
• Health and Social Care Information Centre (HSCIC)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Voluntary Sector Providers
• Private Sector Providers
• Other ‘data processors’ which you will be informed of

You will be informed who your data will be shared with and in some cases asked for explicit consent for this to happen when this is required. We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.

 

Who are our partner software suppliers / businesses?

We use a number of pieces of software and organisations outside of the NHS to facilitate your healthcare and enable our staff to contact you. These are as follows:

Name	Description	Can employees of the organisation access patient information?	GDPR Statement
EVAD	Telephone system, including call recording via secure cloud-based servers	All the call recordings are recorded onto EVAD's cloud-based secure servers. Support staff from EVAD are able to dial in remotely with the consent of our staff for problem solving.	EVAD Privacy Policy
Trusted Technolgy Partnership	The practice’s primary general IT support provider	Trusted Technolgy Partnership support staff are able to remotely dial in with the consent of our staff for problem solving.	Trusted Technolgy Partnership GDPR Policy
Microsoft	The practice’s primary PC software is provided and updated by Microsoft. This includes Microsoft Office 365.	Microsoft (including Office 365) is supported via Healthcare Computing as detailed above.	Microsoft Privacy Statement
EMIS	Clinical system that holds patient demographic and medical information	The servers and the connection to the practice are encrypted, so EMIS staff are not able to access patient information in this way. EMIS support staff are able to dial in remotely with the consent of our staff for problem solving.	EMIS Group Privacy Notice
Docman	Clinical software which holds patient letters and documents	Docman support staff can remotely dial in with the consent of our staff for problem solving.	Docman Privacy Policy
eConsult	Provides the platform for online consultations requests	Patient data is encrypted, consultation information is stored in pseudonymised form on eConsult's servers.	eConsult Privacy Notices
accuRx	SMS system between the practice and patients Assists with the management of our recalls and screening of our chronic disease patients	Patient’s EMIS (clinical system) numbers are uploaded to the accuRx website. This website has an encrypted link to the patient database which is interrogated for the patient’s name and mobile number. accuRx employees would only have access to this identifiable information when troubleshooting – they will sometimes dial into a Blackthorn Health Centre staff member’s PC with the consent of the member of staff to fix a problem. Our appointment reminder system is managed via accuRx. An SMS reminder is sent via accuRx's system prior to your appointment, as detailed above. accuRx also provides our COVID-19 vaccine appointment system.	accuRx Privacy Policy
iPlato	Video Consultation-Software	The Video Consultation software is managed via iPlato. An SMS invite link is sent via iPlato's system. Patient’s EMIS (clinical system) numbers are uploaded to the iPlato website. This website has an encrypted link to the patient database which is interrogated for the patient’s name and mobile number. iPlato employees would only have access to this identifiable information when troubleshooting – they will sometimes dial into a Blackthorn Health Centre staff member’s PC with the consent of the member of staff to fix a problem.	iPlato Privacy Policy
Ardens	Ardens provides the practice with various supporting tools, including searches / audits, referral documents and patient protocols	Ardens support staff are able to dial in remotely with the consent of our staff for problem solving.	Ardens Privacy Policy
Restore Medical Record Storage & Datashred	Store the practice's Lloyd George (medical records) off site Shred paper on which is printed patient or other confidential data	Representatives comes to the practice and delivers requested / collects the medical records at the Practice's request. Representatives comes to the practice and collects our shredding bins full of paper. This is then disposed of off-site.	Restore Datashred Privacy Policy
Edenbridge Health Care	Edenbridge provide the practice with the Apex GP Practice software which enables practices to review their appointment data	Edenbridge support staff are able to dial in remotely with the consent of our staff for problem solving.	Edenbridge Health Care Privacy Policy
Lexacom Cloud	Dictation software which clinical staff use to dictate letters for the secretaries to type	Lexacom support staff are able to dial in remotely with the consent of our staff for problem solving.	Lexacom Cloud Privacy Policy
Dragon Dictate (Nuance)	Dictation software used to assist staff when dictating into a PC	Nuance support staff are able to dial in remotely with the consent of our staff for problem solving.	Nuance Privacy Policy
Royal Mail	Royal Mail is an external mailing agency which we use to send individual letters	All letters / parcels are sealed in a labeled envelope. Royal Mail staff will only have access to the contents of these letters / parcels as per their privacy policy.	Royal Mail Privacy Policy
CFH Docmail	Docmail is an external printing and mailing agency which we use to send individual and  larger batches of letters	Docmail staff can dial in remotely with the consent of our staff for problem solving.	CFH Docmail Terms of Service
MedLink	Assists with the management of our recalls and screening of our chronic disease patients	Patient data is encrypted, consultation information is stored in pseudonymised form on MedLink's servers.	MedLink Privacy Policy
Health Intelligence	Manage recall and screening of diabetic patients for diabetic retinopathy	The Diabetic Eye Screening Programme is operated by Health Intelligence (commissioned by NHS England). This supports invitation for eye screening and ongoing care. This data may be shared with any Hospital Eye Services a patient is under the care of to support further treatment and with other healthcare professionals involved in patient care.	HIOW DESP Privacy Notice
Numed	Numed provides software and support for our ECG machine	Numed support staff can remotely dial in with the consent of our staff for problem solving.	Numed GDPR Statement of Compliance
Engage Health Systems	Engage Health Systems provide our patient check-in screen located in the reception area	Engage Health Systems support staff can remotely dial in with the consent of our staff for problem solving.	Engage Health Systems Privacy Notice
Jayex	Jayex provide our patient caller display board located in the reception area	Jayex support staff can remotely dial in with the consent of our staff for problem solving.	Jayex Privacy Notice
eMR (medi2data)	eMR is a software tool that assists us with creating patient reports, such as Subject Access Requests (SARs) as well as insurance and solicitor reports.	eMR staff have no access to patient information as it is fully encrypted whilst being transmitted to the insurer.	medi2data Privacy Policy
SumUp	SumUp process the practice bank card or online bank payment for any private related work	SumUp staff have no direct access to patient information, other than any demographic information added to an invoice.	SumUp Privacy Policy
eMED3 (fit / sick note)	Department of Work & Pensions (DWP) uses fit note data to inform policy development. For more information, please see the practice's Data Sharing & Confidentiality page	This data is anonymously shared with the DWP. DWP does NOT have access to the practice's clinical systems.	DWP Patient Information
NHS Prescription Services (Business Service Authority)	Certain prescriptions are sent to the NHS Prescription Services on a monthly basis in order for the NHS to reimburse practices for the use of NHS funded medication / appliances	The NHS Prescription Services team will have access to these prescriptions and will handle / store this data as per their privacy policy.	NHS Prescription Services Privacy Notice
University Hospital Southampton NHS Foundation Trust	UHS will be overseeing the local NHS Lung Health Check programme for our patients	UHS will invite those eligible patients as advised by the Practice.	UHS NHS Lung Health Check Programme
NHS Digital	General Practice Data for Planning and Research (GPDPR)	NHS Digital collects a cariety od fata to help improve services.	NHS Digital Privacy Notice
Clinical Practice Research Datalink (CPRD)	CPRD is a Government organisation that provides anonymised patient data for research to improve patient and public health	Identifiable data flows to NHS Digital but you cannot be identified from the information sent to CPRD.	Clinical Practice Research Datalink Privacy Notice
EMIS Recruit	EMIS Recruit is a portal for research studies, embedded into EMIS Web (the Practice's clinical system), that uses advanced analytics and algorithms to find eligible research patients for potential research studies.	Identifiable data flows through EMIS Web.	EMIS Recruit Product Page
Biosciences BioSci Ltd.	Biosciences BioSci Ltd. are working with the practice to help summarise new patient medical records.	Biosciences BioSci Ltd. team will be working at the practice and will have access to selected patient's electronic and paper record.
MDU / MPS / MDDUS / NHS Resolution	Indemnity organisations	We will sometimes send by email or discuss by phone identifiable information when the organisation is supporting a GP in a patient complaint or litigation. Information will be redacted where possible.	MDU Privacy Policy MPS Privacy Notice MDDUS Privacy Notice NHS Resolution: How We Use Your Data
Datix	Datix is used to anonymously record and inform the ICB of Significant Incidents that may occur	This system is managed by Hampshire & Isle of Wight ICB.	Datix Privacy Policy
Tree View Designs	Website provider	Any patient data that is submitted via this website is encrypted and is stored on Tree View Designs' servers.	Tree View Designs Privacy & Transparency Notice

---

Requirement to process confidential patient information

As per an amendment to the Health Service (Control of Patient Information) Regulations 2002, certain confidential patient information will be automatically processed to allow the government to continue monitoring COVID-19 outbreaks and the vaccination programme. The COPI notice is currently in place until Sunday 30th April 2023, pending any further extensions.

 

Access to personal information / Subject Access Requests

You have a right under the General Data Protection Regulations 2018 to request access to view or to obtain copies of what information the practice holds about you (the patient - data subject) and to have it amended should it be inaccurate. In order to request this, you need to do the following:

• Your request should be made in writing to the GP practice, this can be made by email or letter (note for information from the hospital you should write directly to them).
• We will initially offer you online access to your Detailed Coded Record. This contains your electronic medical record and summarised paper record. It does not contain any letters from the hospitals or other attachments on your record. The advantage of applying for access to this record is that it updates as your medical record updates, so you will always have the most current information.
• If the Detailed Coded Record is not adequate for your needs, we will process a copy of your medical record, usually via email. If you are not able to receive an email containing your medical record, you will print a copy for yourself. There may be a charge to have a printed copy of the information held about you if the administrative burden of photocopying and printing is excessive.
• We are required to respond to you within a month. However, if there is a delay due to unforeseen circumstances, you will be promptly notified of this.
• You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located.
• If you are collecting this request in person, you may need to show photographic ID in order to obtain your request.

 

Objections / Complaints

Should you have any concerns about how your information is managed at the GP, please contact the Practice Manager via the contact us page or via a letter for the attention of the Practice Manager.

If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) www.ico.gov.uk, casework@ico.org.uk, telephone: 0303 123 1113 (local rate).

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 have any concerns about how your data is shared then please contact the practice.

 

Cookies  

Our practice website uses cookies to function correctly. You may delete cookies at any time but doing so may result in some parts of the site not working correctly.

 

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 such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.

 

Notification    

The General Data Protection Regulations 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

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

The practice is registered with the Information Commissioners Office (ICO).

 

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential is Blackthorn Health Centre.

If you are still unhappy following a review by the practice you can then complain to the Information Commissioners Office (ICO). www.ico.org.uk, casework@ico.org.uk, telephone: 0303 123 1113 (local rate).

 

Who is the Data Protection Officer?

As a public authority, we have to appoint a Data Protection Officer (DPO). The DPO for this practice is detailed below. They assist us in monitoring internal compliance, provides advice regarding Data Protection Impact Assessments (DPIAs), and helps us demonstrate compliance with an enhanced focus on accountability.

Name: Caroline Sims

E-Mail Address: caroline.sims5@nhs.net