Privacy Statement

How we use your information

 

This privacy notice explains why Pennine GP Alliance collects information about you, and how that information may be used.

As data controllers, Pennine GP Alliance has fair processing responsibilities under the Data Protection Act 1998. In practice, this means ensuring that your personal confidential data (PCD) is handled in ways that are transparent and that you would reasonably expect. The Health and Social Care Act 2012 changed the way that personal confidential data are processed, therefore it is important that patients are made aware of, and understand these changes and that you have an opportunity to object and know how to do so.

Pennine GP Alliance does not provide care directly to patients, however, through our partnership working within health and social care providers, we make use of information in order to deliver on programs and projects intended to benefit the citizens of Calderdale.

Pennine GP Alliance does not hold unique copies of NHS health records but has access to patient data, such as names, addresses and NHS numbers through GP records.

Pennine GP collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that the information is kept confidential. We can disclose personal information if:

  • It is required by law
  • You consent – either implicitly or for the sake of their own care or explicitly for other purposes
  • It is justified in the public interest

Some of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict measures to ensure that individual patients cannot be identified.

On some occasions, it may be necessary to undertake clinical audits of records to ensure that the best possible care has been provided to you or to prevent the spread of infectious disease, wherever possible this will be done in anonymised form.

Under the powers of the Health and Social Care Act 2012 (HSCA) the Health and Social Care Information Centre (HSCIC) can request Personal Confidential Data (PCD) from GP Practices without seeking patient consent. Any patient can choose to withdraw their consent to their data being used in this way. When the Practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-out’ of each new scheme.

A patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

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 the Data Protection Act 1998 (which is overseen by the Information Commissioner’s Office), Human Rights Act, the Common Law Duty of Confidentiality, and the NHS Codes of Confidentiality and Security.

All of our staff, contractors and committee members receive appropriate and on-going training to ensure they are aware of their personal responsibilities and have contractual obligations to uphold confidentiality, enforceable through disciplinary procedures. Only a limited number of authorised staff have access to personal information where it is appropriate to their role and is strictly on a need-to-know basis.

We maintain our duty of confidentiality to you at all times. 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), or where the law requires information to be passed on.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:

  • NHS Trusts
  • Specialist Trusts
  • 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’ during specific project work, eg Diabetes UK

Access to personal information

You have a right under the Data Protection Act 1998 to access/view information Pennine GP Alliance holds about you, and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject access’. If we do hold information about you we will:

  • give you a description of it;
  • tell you why we are holding it;
  • tell you who it could be disclosed to; and
  • let you have a copy of the information in an intelligible form.

If you would like to make a ‘subject access request’. please contact the Practice Manager in writing. There may be a charge for this service.

Any changes to this notice will be published on our website and on the Practice notice board.

The Practice is registered as a data controller under the Data Protection Act 1998. The registration number is Z4973732 and can be viewed online in the public register at http://ico.org.uk/what_we_cover/register_of_data_controllers

Further information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found in:

The NHS Care Record Guarantee: http://www.nigb.nhs.uk/pubs/nhscrg.pdf

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

The HSCIC Guide to Confidentiality gives more information on the rules around information sharing: http://content.digital.nhs.uk/media/12822/Guide-to-confidentiality-in-health-and-social-care/pdf/HSCIC-guide-to-confidentiality.pdf

An independent review of information about patients is shared across the health and care system led by Dame Fiona Caldicott was conducted in 2012. The report, Information: To share or not to share? The Information Governance Review, be found at https://www.gov.uk/government/publications/the-information-governance-review

NHS England – Data Services for Commissioners provides further information about the data flowing within the NHS to support commissioning. https://www.england.nhs.uk/ourwork/tsd/data-services/

Please visit the Health and Social Care Information Centre’s website for further information about their work. Information about their responsibility for collecting data from across the health and social care system can be found at http://www.hscic.gov.uk/collectingdata

The Information Commissioner’s Office is the Regulator for the Data Protection Act 1998 and offers independent advice and guidance on the law and personal data, including your rights and how to access your personal information. For further information please visit the Information Commissioner’s Office website at https://ico.org.uk/.

Version 1.0

March 2018