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Email: [email protected]

More information
There is more information about the Accessible Information Standard on
the NHS England website at www.england.nhs.uk/accessibleinfo

The Bay Medical Practice is committed to providing a safe, comfortable environment where
patients and staff can be confident that best practice is being followed at all times and the safety
of everyone is of paramount importance.

This Chaperone Policy adheres to local and national guidance and policy –i.e.:-
‘NCGST Guidance on the role and effective use of chaperones in Primary and Community Care
settings’.

The Chaperone Policy is clearly advertised on our website (when available) and can be read at
the Practice upon request. A Poster is also displayed in the every consulting room. (See example
in Annex A).

All patients are entitled to have a chaperone present for any consultation, examination or
procedure where they consider one is required. The chaperone may be a family member or
friend, but on occasions a formal chaperone may be preferred.

Patients are advised to ask for a chaperone if required, at the time of booking an appointment, if
possible, so that arrangements can be made and the appointment is not delayed in any way. The
Healthcare Professional may also require a chaperone to be present for certain consultations.
All staff are aware of and have received appropriate information in relation to this Chaperone
Policy.

All trained chaperones understand their role and responsibilities and are competent to perform
that role.

There is no common definition of a chaperone and their role varies considerably depending on
the needs of the patient, the healthcare professional and the examination being carried out.
Their role can be considered in any of the following areas:

•  Emotional comfort and reassurance to patients
• Assist in examination (e.g. during IUCD insertion)
• Assist in undressing
• Act as interpreter
• Protection to the healthcare professional against allegations / attack)

Checklist for consultations involving intimate examinations
• Chaperones are most often required or requested where a male examiner is carrying out
an intimate examination or procedure on a female patient, but the designation of the
chaperone will depend on the role expected of them, whether participating in the
procedure or providing a supportive role.
• Establish there is a genuine need for an intimate examination and discuss this with the
patient and whether a formal chaperone (such as a nurse) is needed.
• Explain to the patient why an examination is necessary and give the patient an
opportunity to ask questions. The chaperone would normally be the same sex as the
patient and the patient will have the opportunity to decline a particular person as a
chaperone, if that person is considered not acceptable for any reason.
• Offer a chaperone or invite the patient to have a family member / friend present.
• If the patient does not want a chaperone, record that the offer was made and declined in
the patient’s notes.
• Obtain the patient’s consent before the examination and be prepared to discontinue the
examination at any stage at the patient’s request.
• Record that permission has been obtained in the patient’s notes.
• Once the chaperone has entered the room, they should be introduced by name and the
patient allowed privacy to undress / dress. Use drapes / curtains where possible to
maintain dignity. There should be no undue delay prior to examination once the patient
has removed any clothing.
• Explain what is being done at each stage of the examination, the outcome when it is
complete and what is proposed to be done next. Keep discussion relevant and avoid
personal comment.
• If a chaperone has been present, record that fact and the identity of the chaperone in the
patient’s notes.
• During the examination, the chaperone may be needed to offer reassurance, remain alert
to any indication of distress but should be courteous at all times.
• Record any other relevant issues or concerns in the patient’s notes, immediately
following the consultation.
• Chaperones should only attend the part of the consultation that is necessary – other
verbal communication should be carried out when the chaperone has left.
• Any request that the examination be discontinued should be respected.
• Healthcare professionals should note that they are at an increased risk of their actions
being misconstrued or misrepresented, if they conduct intimate examinations where no
other person is present.

Annex A
Chaperones
It is our policy to respect the privacy
and dignity of our patients.
If you would like a chaperone to be
present during a physical
examination/consultation,
or
if you would prefer to be examined
by a health professional of the same
gender as yourself, please let us
know and we will do our best to
comply with your wishes.

WHAT IS A PRIVACY NOTICE AND WHY DOES IT
APPLY TO ME?
A Privacy Notice tells people how organisations use information that they hold about
them. A new law called the UK General Data Protection Regulation 2018, also known as
UK GDPR, says that we need to provide you with this Privacy Notice and let you know:

▪ What information we hold about you
▪ How we keep this very important information safe and secure and where
we keep it
▪ How we use your information
▪ Who we share your information with
▪ What your rights are
▪ When the law gives us permission to use your information

WHY DOES THE LAW GIVE YOU PERMISSION TO
USE MY INFORMATION?
The law gives us permission to use your information in situations where we need it to take
care of you. Because information about your health is very personal, sensitive and private
to you, the law is very strict about how we use it.

So, before we can use your information in the ways we have set out in this Privacy Notice,
we have to have a good reason in law, which is called a ‘lawful basis’. Not only do we
have to do that, but we also have to show that your information falls into a special group
or category, because it is very sensitive. By doing this the law makes sure we only use
your information to look after you and that we do not use it for any other reason.

If you would like more information about this please ask to speak to our Data Protection
Officer (DPO) mentioned in this Privacy Notice who will explain this in more detail.
ABOUT US
We, at the The Bay Medical Practice, Broadway, Sandown, Isle of Wight, PO36 9GA and 1
Carter Road, Shanklin, Isle of Wight, PO37 7HR are responsible for collecting, storing and
handling your information when you registered with us as a patient. Because we do this,
the law says we are Data Controllers. Sometimes we may use your information for a
particular purpose and when we do so, the law says we are Data Processors.

WHAT INFORMATION DO YOU HOLD ABOUT ME?
We hold information about you such as:
▪ Your name
▪ Address
▪ Mobile number
▪ Information about your parent(s) or person with parental responsibility
▪ All your health records
▪ Appointment records
▪ Visits to see your GP
▪ Treatments you have had
▪ Medicines prescribed for you and any other information to help us look
after you

HOW DO YOU KEEP IT SAFE?
▪ The law says that we must do all we can to keep your information private,
safe and secure.
▪ We use secure computer systems and we make sure that any written
information held about you is under lock and key and kept in a safe place.
This includes taking great care with any passwords we use which we
change on a regular basis. We also train our staff to respect your privacy
and deal with your information in a manner that makes sure it is always
kept and dealt with in a safe way.

WHAT DO YOU DO WITH MY INFORMATION?
▪ We only usually use your information to help us care for you. That means
we might need to share your information with other people who are
concerned and involved with looking after your health.
▪ We might need to share your information with the police, courts, social
services, solicitors and other people who have a right to your information,
but we always make sure that they have a legal right to see it (or have a
copy of it) before we provide it to them.

WHO ELSE WILL SEE MY INFORMATION?
▪ Usually only doctors, nurses and other people who work with us are
allowed to see your information.
▪ Sometimes though, if you need to go to the hospital or be seen by a
special doctor, we will share your information with them but this only so
that we can take care of you.
▪ Sometimes we might be asked to take part in medical research that might
help you in the future. We will always ask you or your parent(s) or adult
with parental responsibility if we can share your information if this happens.
▪ Possibly the police, social services, the courts and other organisations and
people who may have a legal right to see your information.

WHAT ARE MY RIGHTS?
▪ If you want to see what information we hold about you then you have a
right to see it and you can ask for it.
▪ To ask for your information you will usually need to put your request in
writing and tell us what information you want us to give you.
▪ We usually need to answer you within one month. Your parent(s) or adult
with parental responsibility can help you with is if you need help.
▪ Usually we will give this to you free of charge.
▪ If you think there are any errors in the information we hold about you then
you can ask us to correct it but the law says we can’t remove any of the
information we hold about you even if you ask us to. This is because we
need this information to take care of you.
▪ You have a right to ask us not to share your information.
▪ If you would like to talk to us about not sharing your information, even if
this means you don’t want us to share your information with your parent(s)
or adult with parental responsibility, please let us know. We will be happy to
help.

WHAT IF I HAVE A QUESTION?
▪ A member of our staff/receptionist will be happy to talk to you about any
questions you may have and we will do our best to help you.
▪ The Surgery has a person called a Data Protection Officer (DPO) who deals
with all queries about patient information. Our receptionist may put you in
touch with this person who will listen to your concerns and give you the
advice you need.
▪ Our DPO can be contacted though The Bay Medical Practice.

WHAT IF I HAVE A SERIOUS COMPLAINT ABOUT
HOW YOU LOOK AFTER MY INFORMATION?
▪ We will always do our best to look after your information and to answer
your questions.
▪ If you are still not happy with something we have done with your
information you can speak to our DPO.
▪ If our DPO has not been able to help you or if you prefer not to speak to
our DPO then you have a right to pass your complaint to an organisation
called the Information Commissioner’s Office (ICO) who will look into what
has gone wrong. For more information visit ico.org.uk

UPDATES TO THIS PRIVACY NOTICE
▪ The law says we must keep all information we provide in this Privacy Notice
up to date.
▪ We regularly review and update our Privacy Notice. This Privacy Notice was
last updated on 11 July 2023

Sandown Branch: Broadway, Sandown, Isle of Wight, PO36 9GA. Tel: 01983 409290

Shanklin Branch: 1 Carter Road, Shanklin, Isle of Wight, PO37 7HR. Tel: 01983 862245

Comments, complaints and suggestions

Our aim is to provide the highest level of care for all our patients.

We will always be willing to hear if there is any way that you think that we can improve the service we provide.

Making a complaint

If you have any complaints or concerns about the service that you have received from the doctors or staff working for this practice, please let us know.

We hope that most problems can be sorted out easily and quickly, often at the time they arise and with the person concerned. If your problem cannot be sorted out in this way and you wish to make a complaint, we would like you to let us know as soon as possible – ideally within a matter of days or at most a few weeks – because this will enable us to establish what happened more easily. If it is not possible to do that, please let us have details of your complaint:

· Within 6 months of the incident that caused the problem; or

· Within 6 months of discovering that you have a problem, provided that is within 12 months of the incident.

Each branch has a dedicated contact who will be pleased to deal with any complaint. They will explain the procedure to you and make sure that your concerns are dealt with promptly. You can make your complaint:

In person

Ask to speak to Karen Hermans (Practice Manager), located at our Sandown site.

In writing – some complaints may be easier to explain in writing.

Please give as much information as you can, then send your complaint to the either branch and they will be forwarded to the Practice Manager.

What we shall do

Our complaints procedure is designed to make sure that we settle any complaints as quickly as possible.

We shall acknowledge your complaint within 3 working days and aim to have looked into your complaint within 10 working days of the date when you raised it with us. We shall then be in a position to offer you an explanation, or a meeting with the people involved.

When we look into your complaint, we shall aim to:

· find out what happened and what went wrong

· make it possible for you to discuss the problem with those concerned, if you would like this

· make sure you receive an apology, where appropriate

· identify what we can do to make sure the problem doesn’t happen again.

At the end of the investigation your complaint will be discussed with you in detail, either in person or in writing.

Complaining on behalf of someone else

Please note that we keep strictly to the rules of medical confidentiality. If you are complaining on behalf of someone else, we have to know that you have his or her permission to do so. A note signed by the person concerned will be needed, unless they are incapable (because of illness) of providing this.

What you can do next

We hope that, if you have a problem, you will use our practice complaints procedure. We believe that this will give us the best chance of putting right whatever has gone wrong and the opportunity to improve our practice. However this does not affect your right to approach NHS England if you feel you cannot raise your complaint with us or you are dissatisfied with the way we are dealing with your complaint.

NHS England can be contacted as follows:

Email: [email protected]

Contact Number: 0300 311 2233

Postal address: NHS England, PO Box 16738, Redditch, B97 9PT

You have the right to independent advice or help from:

Southwest Advocacy Network (SWAN)

Tel: 03333 447928. Email: [email protected]

Web: www.swanadvocacy.org.uk/iow

Southwest Advocacy Network are commissioned by the Isle of Wight Council to provide information and support to patients wishing to make an NHS complaint. This service is free, independent of the NHS and confidential.

If you remain dissatisfied with the responses to your complaint, you have the right to ask the Parliamentary and Health Service Ombudsman to review your case.

You can contact them on 0345 015 4033, or write to them at:

Health Service Ombudsman, Millbank Tower,

Millbank, London, SW1P 4QP

www.ombudsman.org.uk

Help us get it right

We constantly try to improve the service we offer.

Please let us know when you think we have done something well or if you have any suggestions as to how we can do something better

All GP practices are required to declare the mean earnings (e.g. average pay) for GPs working to deliver NHS services to patients at each practice.

The average pay for GPs working in The Bay Medical Practice in the last financial year was £131,241 before tax and National Insurance. This is for 5 full time GPs and 13 part time GPs who worked in the practice for more than six months.

Introduction

Policy statement

In accordance with The Health and Social Care Act 2008, The Bay Medical Centre is committed to the prevention of healthcare associated infection and patient safety is of the utmost priority.  Good management and organisational processes are crucial to ensure that high standards of infection prevention (including cleanliness) are maintained.

This practice ensured that it maintained compliance with the HSCA 2008 for infection control and cleanliness.

Status

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time.  For the avoidance of doubt, it does not form part of your contract of employment.

Training and support

The practice will provide guidance and support to help those to whom it applies to understand their rights and responsibilities under this policy.  Additional support will be provided to managers and supervisors to enable them to deal more effectively with matters arising from this policy.

Scope

Who it applies to

This document applies to all employees of the practice, other individuals performing functions in relation to the practice, such as agency workers, locums, and contractors.

Why and how it applies to them

Infection prevention control is the responsibility of all staff at The Bay Medical Centre.  All personnel are to be fully au fait with the guidance given in the policies associated with this statement.

The practice aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010.  Consideration has been given to the impact this policy might have in respect to the individual protected characteristics of those to whom it applies.

Infection Prevention Control Statement

Infection Prevention Control (IPC) lead

At The Bay Medical Centre the IPC leads are: Dr Kirsty Bateman, Dr Simon Nevitt, Practice Nurse Becky Blake.

Responsibilities

The IPC leads are responsible for promoting good infection control practice within The Bay Medical Centre. They are responsible for:

• coordinating the audit programme, collating results and overseeing the development and progress of action plans where indicated.
• updating local risk assessments against the code of practice.
• ensuring that all staff receive appropriate induction and ongoing training in infection prevention.
• producing the annual IPC compliance and learning statement for the practice.
• acting as a local resource and monitoring IPC standards and progress.

Risk Assessments

Risk assessments are undertaken to control risks in the workplace. In the last year the following risk assessments were carried out/reviewed:

• Legionella (water) Risk Assessment: The practice has conducted/reviewed its water safety risk assessment to ensure that the water supply does not pose a risk to patients, visitors or staff.
• Immunisation: As a practice we ensure that all our staff are up to date with their Hepatitis B immunisations and offered any occupational health vaccinations applicable to their role (i.e. Seasonal Flu). We take part in the National Immunisation campaigns for patients and offer vaccinations in house and via home visits (for housebound patients) to our patient population.
• Curtains: The NHS Cleaning Specifications state the curtains should be cleaned or if using disposable curtains, replaced every 6 months. To this effect we use disposable curtains and ensure they are changed every 6 months. The window blinds are very low risk and therefore do not require a particular cleaning regime other than regular vacuuming to prevent build-up of dust.
• Toys and magazines: These have been removed due to COVID19 guidance.
• Cleaning Specifications, frequencies and cleanliness: An assessment of cleanliness is conducted by the IPC Lead on a monthly basis and logged.
• Hand washing sinks: The practice has clinical hand washing sinks in every room for staff to use. Some of our sinks do not meet the latest standards for sinks but we have removed plugs and reminded staff to turn taps that are not “hands free” with paper towels to keep patients safe.

Significant events

Significant event analysis (SEA) should act as a learning process for the whole practice, as significant events can reflect good as well as poor practice.  In relation to infection control, In the past year there have been 0 significant event raised. All significant events are reviewed and discussed in practice meetings each month. Any learning points are cascaded to all relevant staff where an action plan, including audits or policy review, may follow.

Audit

Audit is an essential component of any infection prevention and control strategy.

Infection Prevention and Control annual audits were completed in September 2022 by Rebecca Blake.

As a result of the audits, the following things have been implemented:

• Deep cleaning of floors at regular intervals.
• New, up to date hand hygiene posters at each clinical sink.
• Redecoration throughout building.
• Policies related to Infection Prevention and Control updated.

The Practice plan to undertake the following audits in 2023/2024

• Infection Prevention and Control audit – Annually
• Environmental Cleanliness audit – Every month
• Hand Hygiene & Asepsis audits – 1-2 monthly

The IPC leads will feed back in practice meetings and can provide further detailed information regarding the audits and subsequent action plans.

Guidance documentation and policies

The Bay Medical Centre refers to the Infection Prevention and Control Policy which includes:

• Hand Hygiene
• Personal Protective Equipment
• Cleaning and decontamination
• Handling specimens
• Waste management
• Spillages
• Needle stick Injuries
• Sharps Management
• Asepsis
• Infectious Disease/ Isolation Policy

Policies relating to infection prevention and control are available to all staff and are reviewed and updated annually. Additionally, all policies are amended on an ongoing basis as per current advice, guidance and legislation changes.  All policies can be accessed by all staff on TeamNet.

Summary

All staff undertake infection prevention and control training and are committed to maintaining high standards of infection prevention and cleanliness within The Bay Medical Practice.

Regular training, audits and reviews are key to the prevention of healthcare associated infection and are monitored by The Bay Management team and the IPC team.

The IPC Leads and Practice Managers Karen Hermans and Jason McLean are responsible for reviewing and producing the annual statement.

This annual statement will be updated on or before 01/09/2024

Signed by

01/09/2023

Rebecca Blake IPC Lead Practice Nurse

For and on behalf of Then Bay Medical Practice

View/ Download our Medical Examiner Process.

Patient Rights & Responsibilities

Users of the National Health Service have rights. The following explains what they are. They fall into three main categories.

Legislated Rights

Rights that have been written into law by means of Parliamentary Acts or Bills. (For example, UK GDPR and DPA 2018). As a patient of the NHS you have 7 rights.

• You are entitled to receive health care on the basis of clinical need, regardless of your income.
• You are entitled to be registered with a Medical practice. You are entitled to change your practice at any time. You do not have to give a reason for your decision.
• You are legally entitled to accept or refuse treatment as you see fit. This includes examinations, tests, diagnostic procedures, medication, operations, etc.
• You can refuse to be involved in research trials. If you do not agree to be involved in research trials, you can withdraw at any time.
• You are entitled to equal treatment regardless of race, gender, age or disability.
• You have a right to information on GP practices in your area and the services they provide. All practices must provide an information leaflet.
• You have a right to confidentiality. Personal information about your health is confidential and should only be disclosed to those who need that information to provide you with effective treatment, you can consent to share with other individuals outside of the NHS

Access to your Health Records.

You have a legal entitlement to see a copy of the records held about you. All records stored on computer can be accessed. If you wish to see your records you should apply in to the practice for a Subject Access Request.

Guideline Rights

• You are entitled to have reasonable access to high quality service and facilities.
• You are entitled to information on what is wrong with you and the treatment options available. Ask questions. You should be given truthful, clear answers.
• You are entitled to ask for a second opinion on your diagnosis or treatment.
• You can ask to have someone with you (friend, relative, interpreter) at any time. You may find this beneficial, particularly if you are asking questions or need moral support.

Human Rights

It is your right to be treated as a human being by another human being and as they would wish to be treated themselves, i.e. with dignity, politeness, respect and consideration. These may not necessarily be covered legally or even be contained in guidelines, but human rights will come into many of the areas mentioned above and are certainly just as important.

Consent

A doctor, nurse, or anyone else looking after your health, has to have your agreement before they can examine or treat you. This policy applies to both children and adults. Your consent will be sought before any of your information is shared with any individual not connected with your direct health care.

Patient Responsibilities

Patients, too, have certain responsibilities:

• Keeping appointments:  Please try to arrive on time. If you are unable to attend an appointment, please inform the clinic or surgery in good time. Address. If you move house, change address or telephone number, or the postcode is changed, please inform your GP practice or outpatient clinic.
• Treat all healthcare staff in a reasonable, courteous manner.
• Use emergency services in a responsible manner. Please use the out-of-hours services for emergencies only and not for routine care.
• Take care with medicines. Medicines are for one person only and should not be shared. Keep them safely away from children and in the original container. Take any unwanted medicines to a chemist for safe disposal.

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

What does Safer recruitment mean? Safer recruitment means ensuring that the staff and volunteers who are hired to work with children, young people and vulnerable adults have been suitably checked to prevent any harm being done to the people in their care.

Our policies listed below set out how we meet the above statement and ensure our recruitment procedures are fair and also adopt a values principle to our recruitment. We do not only recruit for qualifications and experience, but also recruit people who share the values of our organisation.

• Recruitment Policy and Procedure
• Disclosure and Barring Service (DBS) Policy
• Policy Statement on the Recruitment of Ex-Offenders
• Privacy Notice – Candidates Applying for Work
• Equality and Diversity Policy

General

Practice365 strives to ensure that its services are accessible to people with disabilities. Practice365 has invested a significant amount of resources to help ensure that its websites are made easier to use and more accessible for people with disabilities, with the strong belief that every person has the right to live with dignity, equality, comfort and independence.

This accessibility statement applies to websites hosted by Practice365.co.uk.

Accessibility on Practice365

We want as many people as possible to be able to use this website. For example, that means you should be able to:

• change colours, contrast levels and fonts
• zoom in up to 300% without the text spilling off the screen
• navigate most of the website using just a keyboard
• navigate most of the website using speech recognition software
• listen to most of the website using a screen reader (including the most recent versions of JAWS, NVDA and VoiceOver)

We’ve also made the website text as simple as possible to understand.

AbilityNet has advice on making your device easier to use if you have a disability.

How accessible this website is

We know some parts of this website are not fully accessible:

• most older PDF documents are not fully accessible to screen reader software

Enabling the Accessibility Menu

Disclaimer

Practice365 continues its efforts to constantly improve the accessibility of its site and services in the belief that it is our collective moral obligation to allow seamless, accessible and unhindered use also for those of us with disabilities.

Here For You

If you are experiencing difficulty with any content on Practice365 website, widget, any of its services or require assistance with any part of our site or software, please contact us during normal business hours as detailed below and we will be happy to assist.

Contacting Us

If you wish to report a problem, have any questions or need assistance, please email us at [email protected]

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you’re not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS). If you are based in Northern Ireland, please reefer to Equalities Commission for Northern Ireland (ECNI) instead of the EASS and EHRC.

The Practice takes it very seriously if a member of staff or one of the doctors or
nursing team is treated in an abusive or violent way.

The Practice supports the government’s ‘Zero Tolerance’ campaign for Health
Service Staff. This states that GPs and their staff have a right to care for others
without fear of being attacked or abused. To successfully provide these services a
mutual respect between all the staff and patients has to be in place. All our staff aim
to be polite, helpful, and sensitive to all patients’ individual needs and circumstances.
They would respectfully remind patients that very often staff could be confronted with
a multitude of varying and sometimes difficult tasks and situations, all at the same
time. The staff understand that ill patients do not always act in a reasonable manner
and will take this into consideration when trying to deal with a misunderstanding or
complaint.

However, aggressive behaviour, be it violent or abusive, will not be tolerated and
may result in you being removed from the Practice list and, in extreme cases, the
Police being contacted.
In order for the practice to maintain good relations with their patients the practice
would like to ask all its patients to read and take note of the occasional types of
behaviour that would be found unacceptable:

• Using bad language or swearing at practice staff
• Any physical violence towards any member of the Primary Health Care Team or other patients, such as pushing or shoving
• Verbal abuse towards the staff in any form including verbally insulting the staff
• Racial abuse and sexual harassment will not be tolerated within this practice
• Persistent or unrealistic demands that cause stress to staff will not be accepted. Requests will be met wherever possible and explanations given

when they cannot

• Causing damage/stealing from the Practice’s premises, staff or patients
• Obtaining drugs and/or medical services fraudulently

We ask you to treat your GPs and their staff courteously at all times.

Removal from the practice list
A good patient-doctor relationship, based on mutual respect and trust, is the
cornerstone of good patient care. The removal of patients from our list is an
exceptional and rare event and is a last resort in an impaired patient-practice
relationship. When trust has irretrievably broken down, it is in the patient’s interest,
just as much as that of the practice, that they should find a new practice. An
exception to this is on immediate removal on the grounds of violence e.g. when the
Police are involved.

Removing other members of the household
In rare cases, however, because of the possible need to visit patients at home it may
be necessary to terminate responsibility for other members of the family or the entire
household. The prospect of visiting patients where a relative who is no longer a
patient of the practice by virtue of their unacceptable behaviour resides, or being
regularly confronted by the removed patient, may make it too difficult for the practice
to continue to look after the whole family. This is particularly likely where the patient
has been removed because of violence or threatening behaviour and keeping the
other family members could put doctors or their staff at risk