We understand how important it is to keep your personal information safe and secure and we
take this very seriously. We have taken steps to make sure your personal information is looked
after in the best possible way and we review this regularly.
Please read this privacy notice (‘Privacy Notice’) carefully, as it contains important information
about how we use the personal and healthcare information we collect on your behalf.
1. WHY WE ARE PROVIDING THIS PRIVACY NOTICE
We are required to provide you with this Privacy Notice by Law. It explains how we use the personal
and healthcare information we collect, store and hold about you. If you are unclear about how we
process or use your personal and healthcare information, or you have any questions about this
Privacy Notice or any other issue regarding your personal and healthcare information, then please
do contact our Data Protection Officer (details below).
The Law says:
A. We must let you know why we collect personal and healthcare information about you;
B. We must let you know how we use any personal and/or healthcare information we hold on
you;
C. We need to inform you in respect of what we do with it;
D. We need to tell you about who we share it with or pass it on to and why; and
E. We need to let you know how long we can keep it for.
2. THE DATA PROTECTION OFFICER
The Data Protection Officer for the Surgery can be contacted through The Bay Medical Practice on
01983 409292 or via email [email protected] if:
• You have any questions about how your information is being held;
• Or any other query relating to this Policy and your rights as a patient.
3. ABOUT US
We, at the The Bay Medical Practice (‘the Surgery’) situated at Broadway, Sandown, Isle of Wight
PO36 9GA and 1 Carter Road, Shanklin, Isle of Wight, PO37 7HR, are a Data Controller of your
information. This means we are responsible for collecting, storing and handling your personal and
healthcare information when you register with us as a patient.
There may be times where we also process your information. That means we use it for a particular
purpose and, therefore, on those occasions we may also be Data Processors. The purposes for which
we use your information are set out in this Privacy Notice.
4. INFORMATION WE COLLECT FROM YOU
The information we collect from you will include:
A. Your contact details (such as your name, telephone/mobile number and email address,
including place of work and work contact details);
B. Details and contact numbers of your next of kin;
C. Your age range, gender, ethnicity;
D. Details in relation to your medical history;
E. The reason for your visit to the Surgery;
F. Medical notes and details of diagnosis and consultations with our GPs and other health
professionals within the Surgery involved in your direct healthcare.
5. INFORMATION ABOUT YOU FROM OTHERS
We also collect personal information about you when it is sent to us from the following:
A. A hospital, a consultant or any other medical or healthcare professional, or any other person
involved with your general healthcare;
B. Independent Contractors such as dentists, opticians, pharmacists;
C. Private Sector Providers;
D. Voluntary Sector Providers;
E. Social Care Services;
F. Local Authorities;
G. 3
rd Parties (such as friends/family/neighbour);
H. Police & Judicial Services;
I. Education Services.
6. YOUR SUMMARY CARE RECORD
Your summary care record is an electronic record of your healthcare history (and other relevant
personal information) held on a national healthcare records database provided and facilitated by
NHS England.
This record may be shared with other healthcare professionals and additions to this record may also
be made by relevant healthcare professionals and organisations involved in your direct healthcare.
You may have the right to demand that this record is not shared with anyone who is not involved in
the provision of your direct healthcare. If you wish to enquire further as to your rights in respect of
not sharing information on this record then please contact the surgery
To find out more about the wider use of confidential personal information and to register your
choice to opt out if you do not want your data to be used in this way, please visit www.nhs.uk/mydata-choice
Note if you do choose to opt out, you can still consent to your data being used for specific purposes.
However, if you are happy with this use of information you do not need to do anything. You may
however change your choice at any time.
7. WHO WE MAY PROVIDE YOUR PERSONAL INFORMATION TO, AND WHY
Whenever you use a health or care service, such as attending Accident & Emergency or using
Community Care Services, important information about you is collected to help ensure you get the
best possible care and treatment. This information may be passed to other approved organisations
where there is a legal basis, to help with planning services, improving care, research into developing
new treatments and preventing illness. All of this helps in proving better care to you and your family
and future generations. However, as explained in this privacy notice, confidential information about
your health and care is only used in this way where allowed by law and would never be used for any
other purpose without your clear and explicit consent.
We may pass your personal information on to the following people or organisations because these
organisations may require your information to assist them in the provision of your direct healthcare
needs. It, therefore, may be important for them to be able to access your information in order to
ensure they may properly deliver their services to you:
A. Hospital professionals (such as doctors, consultants, nurses, etc);
B. Other GPs/Doctors;
C. Pharmacists;
D. Nurses and other healthcare professionals;
E. Dentists;
F. Any other person that is involved in providing services related to your general healthcare,
including mental health professionals.
8. OTHER PEOPLE WHO WE PROVIDE YOUR INFORMATION TO
A. Commissioners;
B. Integrated Care Boards / Systems (ICB/ICS);
C. Local authorities;
D. Community health services;
E. For the purposes of complying with the law e.g. Police, Solicitors, Insurance Companies;
F. Anyone you have given your consent to, to view or receive your record, or part of your
record. Please note, if you give another person or organisation consent to access your
record, we will need to contact you to verify your consent before we release that record. It
is important that you are clear and understand how much and what aspects of your record
you give consent to be disclosed.
G. Advanced Access – we provide extended access services to our patients which means you
can access medical services outside of our normal working hours. In order to provide you
with some of this service, we engage with Tower House Surgery who provide local registered
GPs and Practice Nurses. These staff will have to have access to your medical record to be
able to offer you the service. Please note to ensure that this practice complies with the law
and to protect the use of your information, we have data sharing agreements and other
clear arrangements in place to ensure your data is always protected and used for those
purposes only.
H. Data Extraction by the ICB – the ICB at times extracts medical information about you, but
the information we pass to them via our computer systems cannot identify you to them.
This information only refers to you by way of a code that only your practice can identify (it is
pseudo-anonymised). This therefore protects you from anyone who may have access to this
information at the Clinical Commissioning Group from ever identifying you as a result of
seeing the medical information and we will never give them the information that would
enable them to do this.
There are good reasons why the Clinical commissioning Group may require this pseudoanonymised information, these are as follows:
Understanding of population activity at a Practice, Super Practice, Federation, Primary Care
Home, CCG and STP Level;
Grouping the population into patient cohorts (segments)based on demographic and clinical
features; using these cohorts as a lens through which to understand current and future
activity, financial impact and long-term outcomes. Monitoring of bespoke cohorts of
patients e.g. frail elderly;
Understand and forecast costs;
“Business as Usual” analytical support for commissioning;
Analysis to enable services and contracts to be better aligned with the population and their
needs;
Opportunity identification using case mix adjusted benchmarking;
Service evaluation as a resource to undertake match case control analysis.
Population Health Analytics as follows:
Medicines Management, to identify cohorts of patients where prescribing could be
improved, and monitoring progress with agreed changes to prescribing, as well as provide
Nursing/Care Homes with medication support for residents;
Monitoring progress with schemes to improve care, e.g. long-term conditions, completion of
direct and local enhanced services;
Supporting Practices with data quality Improvements by identifying data quality issues or
inconsistencies;
Understanding activity in Primary Care for specific conditions to identify service
improvements;
Surveillance e.g. monitoring flu-like illness
Health needs assessment, for example, identifying numbers of patients with specific health
conditions, or combinations of conditions;
Health services research including identification of patients eligible to be invited to
participate in research, where patient consent has been obtained.
9. ANONYMISED INFORMATION
Sometimes we may provide information about you in an anonymised form. If we do so, then none of
the information we provide to any other party will identify you as an individual and cannot be traced
back to you.
10. YOUR RIGHTS AS A PATIENT
The Law gives you certain rights to your personal and healthcare information that we hold, as set out
below:
A. Access and Subject Access Requests
You have the right to see what information we hold about you and to request a copy of this
information.
We will provide this information free of charge however, we may in some limited and exceptional
circumstances have to make an administrative charge for any extra copies if the information
requested is excessive, complex or repetitive.
We have one month to reply to you and give you the information that you require. We would ask,
therefore, that any requests you make are in writing and it is made clear to us what and how much
information you require.
B. Online Access
You may ask us if you wish to have online access to your medical record. However, there will be
certain protocols that we have to follow in order to give you online access, including written consent
and production of documents that prove your identity.
Please note that when we give you online access, the responsibility is yours to make sure that you
keep your information safe and secure if you do not wish any third party to gain access.
C. Correction
We want to make sure that your personal information is accurate and up to date. You may ask us to
correct any information you think is inaccurate. It is very important that you make sure you tell us if
your contact details including your mobile phone number has changed.
D. Removal
You have the right to ask for your information to be removed however, if we require this
information to assist us in providing you with appropriate medical services and diagnosis for your
healthcare, then removal may not be possible.
E. Objection
We cannot share your information with anyone else for a purpose that is not directly related to your
health, e.g. medical research, educational purposes, etc. We would ask you for your consent in order
to do this however, you have the right to request that your personal and healthcare information is
not shared by the Surgery in this way. Please note the Anonymised Information section in this
Privacy Notice.
F. Transfer
You have the right to request that your personal and/or healthcare information is transferred, in an
electronic form (or other form), to another organisation, but we will require your clear consent to be
able to do this.
11. THIRD PARTIES MENTIONED ON YOUR MEDICAL RECORD
Sometimes we record information about third parties mentioned by you to us during any
consultation. We are under an obligation to make sure we also protect that third party’s rights as an
individual and to ensure that references to them which may breach their rights to confidentiality, are
removed before we send any information to any other party including yourself. Third parties can
include: spouses, partners, and other family members.
12. HOW WE USE THE INFORMATION ABOUT YOU
We use your personal and healthcare information in the following ways:
A. when we need to speak to, or contact other doctors, consultants, nurses or any other
medical/healthcare professional or organisation during the course of your diagnosis or
treatment or on going healthcare;
B. when we are required by Law to hand over your information to any other organisation, such
as the police, by court order, solicitors, or immigration enforcement.
We will never pass on your personal information to anyone else who does not need it, or has no
right to it, unless you give us clear consent to do so.
13. LEGAL JUSTIFICATION FOR COLLECTING AND USING YOUR INFORMATION
The Law says we need a legal basis to handle your personal and healthcare information.
CONTRACT: We have a contract with NHS England, Public Health England, the Local Authority and
the Hampshire & Isle of Wight Integrated Care Board (ICB) to deliver healthcare services to you. This
contract provides that we are under a legal obligation to ensure that we deliver medical and
healthcare services to the public.
CONSENT: Sometimes we also rely on the fact that you give us consent to use your personal and
healthcare information so that we can take care of your healthcare needs.
Please note that you have the right to withdraw consent at any time if you no longer wish to receive
services from us.
NECESSARY CARE: Providing you with the appropriate healthcare, where necessary. The Law refers
to this as ‘protecting your vital interests’ where you may be in a position not to be able to consent.
LAW: Sometimes the Law obliges us to provide your information to an organisation (see above).
14. SPECIAL CATEGORIES
The Law states that personal information about your health falls into a special category of
information because it is very sensitive. Reasons that may entitle us to use and process your
information may be as follows:
PUBLIC INTEREST: Where we may need to handle your personal information when it is considered to
be in the public interest. For example, when there is an outbreak of a specific disease and we need
to contact you for treatment, or we need to pass your information to relevant organisations to
ensure you receive advice and/or treatment;
CONSENT: When you have given us consent;
VITAL INTEREST: If you are incapable of giving consent, and we have to use your information to
protect your vital interests (e.g. if you have had an accident and you need emergency treatment);
DEFENDING A CLAIM: If we need your information to defend a legal claim against us by you, or by
another party;
PROVIDING YOU WITH MEDICAL CARE: Where we need your information to provide you with
medical and healthcare services
15. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We carefully consider any personal information that we store about you, and we will not keep your
information for longer than is necessary for the purposes as set out in this Privacy Notice.
16. UNDER 16s
There is a separate privacy notice for patients under the age of 16, a hard copy of which may be
obtained on request. It is also available on our website and is displayed in the surgery.
17. IF ENGLISH IS NOT YOUR FIRST LANGUAGE
If English is not your first language you can request a translation of this Privacy Notice. Please
contact the surgery.
18. COMPLAINTS
If you have a concern about the way we handle your personal data or you have a complaint about
what we are doing, or how we have used or handled your personal and/or healthcare information,
then please contact our Practice Manager Karen Hermans
However, you have a right to raise any concern or complaint with the UK information regulator, at
the Information Commissioner’s Office: https://ico.org.uk/.
19. OUR WEBSITE
The only website this Privacy Notice applies to is the Surgery’s website. If you use a link to any other
website from the Surgery’s website, then you will need to read their respective privacy notice. We
take no responsibility (legal or otherwise) for the content of other websites.
20. COOKIES
The Surgery’s website is provided by “Brightbulb Design”.
We do not use cookies to track your activity online.
We do not set first party cookies on this website containing any personal data unless specifically
instructed to do so by the user. For example, if a user requests to be remembered on a form, then a
cookie is set to retain the form data for next time.
21. SECURITY
We take the security of your information very seriously and we do everything we can to ensure that
your information is always protected and secure. We regularly update our processes and systems
and we also ensure that our staff are properly trained. We also carry out assessments and audits of
the information that we hold about you and make sure that if we provide any other services, we
carry out proper assessments and security reviews.
22. TEXT MESSAGING/ E-MAIL AND CONTACTING YOU
Because we are obliged to protect any confidential information we hold about you and we take this
very seriously, it is imperative that you let us know immediately if you change any of your contact
details.
We may contact you using SMS texting to your mobile phone if we need to notify you about
appointments and other services that we provide to you involving your direct care, therefore you
must ensure that we have your up-to-date details. This is to ensure we are sure we are actually
contacting you and not another person.
23. WHERE TO FIND OUR PRIVACY NOTICE
You may find a copy of this Privacy Notice on the Surgery’s notice board, on our website, included in
our registration pack or a copy may be provided on request.
24. CHANGES TO OUR PRIVACY NOTICE
We regularly review and update our Privacy Notice. This Privacy Notice was last updated on
11 July 2023