Policies & Procedures

In accordance with the General Data Protection Regulations 2018 and Access to Health Records Act, patients may request to see their medical records. No information will be released without the patient consent unless we are legally obliged to do so.

You have the right to get a copy of information that is held about you:

This is known as a subject access request. Please note:

• You can sign up for secure online access to your full GP electronic record
• You can then look at your medical record whenever you want.

If you wish to make a subject access request then:

• You can do this in writing (letter or email)
• You can download and fill in the subject access form below if easier
• You can make such a request verbally to a member of staff or a doctor or nurse that you are consulting with at the practice.

Please let us know exactly what information you would like. We will provide the information within 28 calendar days. There is usually no fee for this (from 25th May).

We will also provide you with a link to supplementary information  which for nearly all requests will be the detailed privacy notice for our GP records database. (EMIS Health Ltd).

• Subject Access Request Form
• EMIS Health Privacy Notice

If you do not wish anonymous information about you to be used in such a way, please let us know.

Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.

As you are probably aware the NHS is changing and GPs and Patients are being encouraged to work together to redesign services and pathways to allow more cost effective care, close to home.

This brief note is to ensure you are clear that this has produced a potential conflict of interest where Canterbury Medical Practice sometimes needs to take on the role of both referrer and provider. As a result they have a commercial interest in the provision of such services e.g. Cardiology Service

All consultants and referrals will continue to prioritise the best interests of the patients; including any discussion around choice of providers. Any financial interest there may be in an organisation providing healthcare will not influence the way our clinicians prescribe, treat or refer.

GDPR and Data Breaches: 

To view our policy please open or download as a pdf document here:

CMP Data Breach Policy May 2018

GDPR and The National Data Opt Out:

On 25th May, The Data Protection Act 2018 comes into force. Canterbury Medical Practice has ensured that we have met our responsibilities under the new legislation.

Full details can be found in our policies where you can find:

• Our Privacy Policy
• Detailed privacy notices for data processing that we perform on our patients’ medical information
• Your data subject rights

In addition, NHS Digital launches the National Data Opt Out on that day.

FIND OUT MORE

Preparation

If such an examination or procedure is needed in connection with your care as a patient at this surgery:-

• where possible we will tell you beforehand
• we will describe the procedure to you so that you understand what is involved, including if you are likely to experience any pain or discomfort.
• We will request your consent to the examination or procedure, and record this in your patient notes.
• We will offer you a chaperone (a number of our surgery team have this role)

The doctor or nurse in charge of the examination or procedure may in any case feel that it is in everyone’s best interests if a chaperone is provided, in which case we will advise you.

During the examination

You will have a private changing room or screened changing area.

If you need assistance with undressing/dressing please ask, this will be provided.

If you requested a chaperone, they will:-

• meet you before the examination/procedure begins
• reassure you and make sure you know what is involved
• assist you with undressing/dressing if you have requested this
• stay with you and the doctor or nurse conducting the procedure, throughout the procedure
• help you clarify any queries you may have with the doctor or nurse

If at any time during the procedure you feel uncomfortable or concerned please ask the doctor or nurse to stop and explain things again. It may not always be possible to stop immediately, this will depend on the procedure being undertaken.

Consent

• Consent means you are agreeing to something
• You have the right to say no to any treatment or procedure
• Before a doctor or nurse can examine or treat you, they will ask you to give your consent

Treatment

• Might be an injection, a minor operation or something else

How do you give consent?

• You can say you agree
• You can show you agree
• You can sign a form if you agree

If you are not sure or don’t understand PLEASE ASK

GP practices are required to make information available via a “publication scheme”. This may be held in paper form or by electronic means. It will include information commonly requested and is available on request. The practice’s publication scheme follows the model scheme for GP practices approved by the Information Commissioner.

How up to date is the Information?

The practice complies with the principles of the Freedom of Information Act, and as such updates the publication scheme document on an annual basis, and at other intervals during the year should significant changes occur.

What Sort of Information is Available?

• Fees and Charges
• Format of the publication scheme
• Information held by the practice (with some exceptions)
• How information requests are processed
• Details of the practice, structure and relationship to the NHS
• Services provided
• Financial and funding information
• Complaints, policies and procedures.
• General policies and procedures

Note: Information related to individual/health/clinical records is not available under the legislation. Please ask reception for details of access for this purpose under the Data Protection Act.

Making an Access Request

All requests (with the exception of a copy of the publication scheme) are to be made in writing to the practice.

Fees

The information contained in the publication scheme is available at no charge. In some circumstances, a fee may be charged for the provision of information, and the classes of information incurring a fee are listed in the publication scheme document. Please ask reception for a copy

Complaints or Suggestions

We welcome feedback from members of the public as to the information they would like to see in our publication scheme.

Please write to the Practice Manager with any ideas which you may have or send us an email kmicb.cmp@nhs.net

If you are dissatisfied with the way in which your request for access under the Act has been handled, or if you wish to appeal against a refusal to release any information requested, please write in the first instance to the Practice Manager.

If, after receiving a reply, you remain dissatisfied you may appeal to the Information Commissioner. Details of how to do this will be supplied as part of your reply.

Further information available at:

http://www.ico.gov.uk/

http://www.foi.nhs.uk/

Privacy Notice

Canterbury Medical Practice

This privacy notice explains why Canterbury Medical Practice collects information about you, how we keep it safe and confidential and how that information may be used. (please see GDPR privacy tab for more detailed notices)

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 within any NHS organisation. These records help to provide you with the best possible healthcare.

We collect and hold data for the sole purpose of providing healthcare services to our patients. In carrying out this role we may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form. The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and information such as outcomes of needs assessments.

Details we collect about you

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously or elsewhere (e.g. NHS Hospital Trust, other GP Surgery, Out of Hours GP Centre, A&E, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

Records which we may hold about you may include the following:

• Details about you, such as your address and next of kin, emergency contacts and power of attorney.
• Your home telephone number, mobile phone number, email address
• Any contact the surgery has had with you, such as appointments, clinic visits, immunisations, emergency appointments, etc.
• Notes and reports about your health, 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 we keep your information confidential and safe

All your GP NHS health records are kept electronically. Our GP records database is hosted by EMIS Health Ltd, who is acting as a data processor, and all information is stored on their secure servers in Leeds and is protected by appropriate security, and access is restricted to authorised personnel.

We also make sure that data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

We only email you, or use your mobile number to text you, regarding matters of medical care, such as appointment reminders and (if appropriate) test results.

 Unless you have separately given us your explicit consent, we will not email you for non-medical matters (such as surgery newsletters and other information).

We maintain our duty of confidentiality to you always. 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.

How we use information about you

Confidential patient data will be shared within the healthcare team at the practice, including nursing staff, admin staff, secretaries and receptionists, and with other healthcare professionals to whom a patient is referred. Those individuals have a professional and contractual duty of confidentiality.

Details of who is authorised to access your GP record can be found on our website.

Data Analysts:

Canterbury Medical Practice uses Data Analysts. The CCG has a small medicines management team of pharmacy technicians who work closely with GPs and local health providers to help get the best out of medicines for local people, sometimes these may include data audits. More details of this will be available on our website.

Referrals for specific health care purposes:

We sometimes provide your information to other organisations for them to provide you with medical services. We will always inform you of such a referral, ask for consent (explicit or implied). You always have the right not to be referred in this way.

These may include:

• Referrals for home oxygen services
• Referrals for Diabetes dietary advice (Clinical Nutrition & Dietetics)
• Referrals for Diabetes Eye Screening (“DESP” Diabetic Eye Screening Programme)
• Referrals for Pre-Diabetes (“Healthier You” Diabetes Prevention Programme)

Data Sharing Schemes:

A number of data sharing schemes are active locally, enabling healthcare professionals outside of the surgery to view information from your GP record, with your explicit consent, should that need arise.

These schemes are as follows:

• The National Summary Care Record (SCR)
• EMIS Web data streaming (A&E and GP out of hours)
• Remote Consultations (GP out of hours) CHOC
• NHS111 Adastra Web Access
• SECAMB (EPCR Ipad – Kainos)
• NHS Health Checks (Health Diagnostics LTD)
• Quit Smoking (One System for Health)
• MIG (Medical Interoperability Gateway)
• PAS (patient access system, EKHUFT A&E)
• IGPR (Electronic Reporting and Screening Tool)
• IPLATO (patient care messaging)

Details of these schemes, and of your right to opt-out of any or all of them, will be available on our website.

Mandatory disclosures of information

We are sometimes legally obliged to disclose information about patients to relevant authorities. In these circumstances the minimum identifiable information that is essential to serve that legal purpose will be disclosed. That organisation will also have a professional and contractual duty of confidentiality. Data will be anonymised if at all possible before disclosure, if this would serve the purpose for which the data is required.

Organisations that we are sometimes obliged to release information to include:

• NHS Digital (e.g. the National Diabetes Audit – anonymised data)
• CQC
• DVLA
• GMC
• HMRC
• NHS Counter Fraud
• Police
• The Court
• Public Health England
• Local Authorities (Social Services)
• The Health Service Ombudsman

Permissive disclosures of information:

Only with your explicit consent, Canterbury Medical Practice can release information about you, from your GP record, to relevant organisations.

These may include:

• Your employer
• Insurance companies
• Solicitors
• Local Authorities, such as the county council or housing
• Police

Accessing your information on other databases:

Canterbury Medical Practice can access certain medical information about you, when relevant or necessary, that is held on other databases (i.e. under the control of another data controller). These include East Kent Hospital University Hospitals Trust (EKHUFT) databases and NHS Digital’s Open Exeter database. Accessing such information would only be for your direct medical care.

This may include:

• Cervical Smear results/recall date
• Child immunisation recalls

For more information about open Exeter please click here

CPRD (clinical practice research datalink)

CPRD is jointly funded by the NHS National Institute for Health Research (NIHR) and the Medicines and Healthcare Products Regulatory Agency (MHRA) who are part of the Department of Health.

Canterbury Medical Practice sometimes undertakes accredited research projects. This involves accessing identifiable patient information. We will only do so with the explicit consent of the individual and Research Ethics Committee approval. For more information on the governance of this please click here

COVID-19 (Data sharing with NHS Digital):

Canterbury Medical Practice is supporting vital coronavirus (COVID-19) planning and research by sharing your data with NHS Digital. The health and social care system has faced significant pressures due to the coronavirus outbreak. The information shared is essential to deliver care to individuals, protect public health and important in the research , monitoring and tracking the virus.

As a practice we are supporting NHS Digital by sharing your data to support this fundamental research and as part of the legal requirement under the Health and Social Care Act 2012.

The type of personal information we share: 

• Diagnosis and findings
• Medications and other prescribed items
• Investigations, tests and results
• Treatment and outcomes
• Vaccinations and immunisations

NHS Digital will analyse the data collection and securely and lawfully share this data with other appropriate organisations. These agencies are involved with protecting public health, providing health and social care public services, carrying out vital research (including clinical trials), monitoring and managing the outbreak and identifying vital trends.

For more information please visit: https://digital.nhs.uk/coronavirus/gpes-data-for-pandemic-planning-and-research/general-practice-transparency-notice

Opt-out of sharing your information:

You have the right to opt-out (or object) to ways in which your information is shared, both for direct medical care purposes (such as the national NHS data sharing schemes), i.e. primary uses of your information, or for purposes other than your direct medical care – so-called secondary uses. Details of these purposes, and how you can opt out, will be found on our website

Accessing your own medical information:

You have the right to access your own GP record. Details of how to do this can be found on our web site and the patient information booklet. You can also sign up to have secure online access to your electronic GP record. Again, details of how to do this can be found on our website and the patient information leaflet.

Notification

GDPR requires organisations to register a notification with the Information Commissioner (ICO) 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 here

Complaints:

If you have concerns or are unhappy about any of our services, please contact the complaints manager, information on this is available on our website.

For independent advice about data protection, privacy, and data sharing issues,

Email Us Here  

The Information Commissioner

Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Phone: 08456 30 60 60

Website: www.ico.gov.uk

Further Information:

If you would like any further information about primary or secondary uses of your GP record, opting out, the NHS Databases, access to your medical record, confidentiality, or about any other aspect of NHS data sharing or your medical records, then please do contact the surgery’s Caldicott Guardian / Information Governance lead:

Dr James Hinksman

Email 

Please raise your complaint as soon as you can, whilst you remember the details clearly. The quickest way is to raise it with Complaints Team via the email above. The Complaints Team will acknowledge your complaint and make early contact with you (within three working days) to discuss the way forward.

Your complaint will be investigated and a response will be made by the Practice Manager to you within 25 workings days.

If it involves a third party

If your complaint is about a hospital or other organizations we will aim to provide you with a coordinated response covering all aspects of your complaint. Where a complaint is solely about a third party, we may seek your agreement to pass the complaint onto them.

Complaints can be made by patients either on their own behalf or by a representative (with their consent)

Once investigated and concluded a letter will be sent to you setting out how we investigated your complaint as well as details of the actions taken or to be taken as a result. We hope that your complaint will be resolved at this stage, but if not we may invite you to discuss what else might be done.

If you have a complaint or concern that you cannot be resolved locally with your practice please contact:

NHS Commissioning Board
PO Box 16738, Redditch, B97 9PT.
Telephone: 0300 311 2233
Email: nhscommissioningboard@hscic.gov.uk

SEAP
SEAP are an Independent Advocacy Service who are available to support you and represent your views when making a complaint. They can accompany you to meetings to discuss your complaint and provide support or an interpreter.

SEAP, 7^th floor Cavendish House, Breeds Place, Hastings TN34 3AA.
Telephone: 0330 440 9000
Email: info@seap.org.uk

Parliamentary and Health Service Ombudsman
Millbank Tower, Millbank, London, SW1P 4QP.
Telephone: 0345 0154033
Email: phso.enqires@ombudsman.org.uk

Your Summary Care Record will contain important information about any medicines you are taking, allergies you suffer from and any bad reactions to medicines that you have had.

Giving healthcare staff access to this information can prevent mistakes being made when caring for you in an emergency or when your GP practice is closed.

Your Summary Care Record will also include your name, address, date of birth and your unique NHS Number to help identify you correctly.

You may want to add other details about your care to your Summary Care Record. This will only happen if you ask for the information to be included. You should discuss your wishes with the healthcare staff treating you.

Click here to view a leaflet containing more information.

You can choose not to have a Summary Care Record. You need to let your GP practice know by filling in and returning an opt-out form.

Click here to download an opt-out form.

The NHS operate a zero tolerance policy with regard to violence and abuse and the practice has the right to remove violent patients from the list with immediate effect in order to safeguard practice staff, patients and other persons. Violence in this context includes actual or threatened physical violence or verbal abuse which leads to fear for a person’s safety.

In this situation we will notify the patient in writing of their removal from the list and record in the patient’s medical records the fact of the removal and the circumstances leading to it.