It is important that our Surgery is always a safe place to work and visit. Patients and staff must not feel threatened.

Practice staff will always work with patients to resolve difficulties when they arise. This process is helped by a positive and calm manner from both the patient and staff member. If the patient displays hostile behaviour or an angry attitude this can make staff and other patients feel threatened.

In light of this the Practice has clear procedures on unacceptable behaviour.

Such unacceptable behaviours include, but are not limited to:

• Any display of a violent temper
• Shouting or raised voice, pointing fingers
• Not engaging with staff positively
• Being pushy or trying to intimidate staff
• Hostile or aggressive behaviour
• Threats, swearing, spitting
• Any mention or display of any object that could be used as a weapon
• Any comments of a personal nature made to members of staff or other patients

Patients will be warned if their behaviour is unacceptable and asked to stop. Where patients do not comply they will receive a First Warning Letter.
Where patients behaviour is unacceptable on a subsequent occasion, they will receive a Final Warning Letter.
Any further display of unacceptable behaviour will result in REMOVAL from the practice list.

In some instances, we may choose to Remove without warning.

We are pleased that incidents of unacceptable behaviour in the surgery are rare.

Repeatedly Missing Appointments

The Surgery is under a lot of pressure to provide as many appointments as possible. If they choose to patients may receive an SMS text reminder for their appointments and can text back to cancel their appointment. If you would like to take advantage of this service please let us know and give us your mobile number.  Please note the text back facility cannot be used when there are less than three hours before the appointment.

Missed appointments are a waste of resources and we must take action to keep these to a minimum; therefore it is an unacceptable behaviour for patients to repeatedly miss booked appointments.

Patients who frequently miss booked appointments will be contacted by letter with a behaviour warning and reminder of this policy.

Patients who persistently miss booked appointments risk being removed from the practice register.

Complaints & Comments Leaflet

Let the Practice Know your views

Towcester Medical Centre is always looking for ways to improve the services it offers to patients. To do this effectively, the practice needs to know what you think about the services you receive. Tell us what we do best, where we don’t meet your expectations, plus any ideas and suggestions you may have. Only by listening to you can the practice continue to build and improve upon the service it offers.

PRACTICE COMPLAINTS PROCEDURE

If you have a complaint about the service you have received from any member of staff working in this practice, please let us know. The practice operates a Complaints Procedure as part of the NHS system for dealing with complaints. Our complaints system meets national criteria.

Note: If you make a complaint, it is practice policy to ensure you are not discriminated against, or subjected to any negative effect on your care, treatment or support.

HOW TO COMPLAIN

In the first instance please discuss your complaint with the staff member concerned or the reception supervisor if appropriate.

Where the issue cannot be resolved at this stage, please contact the Practice Manager who will try to resolve the issue and offer you further advice on the complaints procedure.

If your problem cannot be resolved at this stage and you wish to make a formal complaint, please let us know as soon as possible, ideally within a matter of days. This will enable the practice to get a clear picture of the circumstances surrounding the complaint.

If it is not possible to raise your complaint immediately, please let us have details of your complaint within the following timescales:

• Within 6 months of the incident that caused the problem

OR

• Within 6 months of discovering that you have a problem, provided this is within 12 months

The practice will acknowledge your complaint within three working days and aim to have looked into your complaint within 28 days of the date you raised it with us. At this stage you should be offered an explanation or a meeting with the person(s) involved.

When the practice looks into your complaint it aims to:

• Ascertain the full circumstances of the complaint
• Make arrangements for you to discuss the problem with those concerned, if you would like this
• Make sure you receive an apology, where this is appropriate
• Identify what the practice can do to make sure the problem does not happen again

If you are unable to discuss your complaint directly with the Practice, or your complaint relates to another NHS provider, you can ask the Integrated Care Board to investigate your complaint. The contact details for the ICB are:

Telephone 01604 476777

Email northantsicb.patientexperience@nhs.net

In writing:

Patient Experience Team

Francis Crick House

Summerhouse Road

Moulton Park

Northampton

NN3 6BF

Independent Complaints Advocacy Service

As a last resort, if you are not happy with the response from this practice, you can refer your complaint to the Parliamentary and Health Service Ombudsman who investigates complaints about the NHS in England. You can call the Ombudsman’s Complaints Helpline on 0345 015 4033 or http://www.ombudsman.org.uk or Textphone (Minicom): 0300 061 4298.

CONTACTING THE CARE QUALITY COMMISSION

If you have a genuine concern about a staff member or regulated activity carried on by this Practice then you can contact the Care Quality Commission on 03000 616161, or alternatively visit the following website: http://www.cqc.org.uk

Download the complaints form

Fees for Private Medicals and Reports

The above link provides a list which covers the work we’re asked to undertake most frequently.  Other work may be chargeable at different rates depending on the length of time it will take to complete and the complexity of the information required. If you have something that needs to be completed by a doctor please ask at reception.  The receptionist will refer your requirement to the administrators who handle chargeable work who will notify you of the cost.

The timescale for completion of this type of work is between 4 and 6 weeks and may be longer if there are a large number of requests.  Please note that a doctor is unable to simply sign something during a consultation in order for it to be completed quickly. When a doctor is asked to sign a letter or a form it is generally to verify medical information relating to the patient which still requires investigation into the patients history which takes time, particularly if the history is lengthy or complex.

Please be aware that we do not have card payment facilities at either surgery so payments need to be made in cash or by cheque.

How We Use Your Medical Records
Important Information for Patients

• We handle all medical records in-line with laws on data protection and confidentiality
• Our guiding principle is that we hold your information in the strictest confidence
• We share medical records with those who are involved in providing you with care and treatment
• Sometimes we share medical records for medical research butwe don’t share any patient identifiable data in these circumstances without express consent
• You can object to your information being used for medical research and to plan health services
• We share information when the law requires us to do so e.g. to prevent infectious diseases from spreading or to check care being provided is safe
• You have the right to object to your medical records being shared with other care providers, if this limits your treatment options we will tell you
• You have the right to access a copy of your medical record
• You have the right to have any mistakes corrected and forward any complaints to the Information Commissioner’s Office

NHS is changing the way patient data is used for planning and research…

We aim to provide high quality care to all our patients and it is vitally important for us to continually improve our service as a result of patient feedback. We welcome all feedback whether it is positive or negative. Matters are easier to deal with if you tell us near to the time of the event, however we understand this may not always be possible.

Compliments
It is always nice to hear when we are doing things well and we appreciate any compliments we receive. If you would like to leave any compliments, then you can do so by addressing them to Karen Wheeler our Practice Manager and she will let the individual or group of people know.

Comments/Suggestions
If you wish to make a comment, give a compliment or raise a concern please contact Chloe Lamont our Practice Manager.

You can speak to her by calling the surgery:
01327 359953
You can write to her at the surgery:
Towcester Medical Centre, Link Way, Towcester, NN12 6HH
You can send her an e-mail:
chloe.lamont1@nhs.net

Concerns
We understand that there will be times when you feel you may have cause for concern. We operate a comprehensive complaints process and take all concerns seriously. We will investigate your concerns as quickly as possible and get back to you.

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

The average pay for GPs working in the Towcester Medical Centre in the last financial year before tax and National Insurance was £52,392
This is for 1 full time GPs, 5 part time GPs, and 1 locum GPs who worked in the practice for more than 6 months.
It should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time doctors spend working in the practice, and should not be used to form any judgement about GP earnings, nor to make any comparison with any other practice.

We will provide you with timely, high quality care and will manage your illnesses in the best possible way, seeking advice from colleagues when this is needed.

We will treat you courteously, preserve your confidentiality and respect your wishes

We will listen to your comments and complaints and respond to them promptly.

In return please treat us with courtesy and respect. Use our appointment system and the out of hours service appropriately. If you cannot attend an appointment we ask you to notify us so that another patient can be seen at that time.

We expect you to share responsibility for your health and follow the advice and treatment you are given, or speak to the doctor if you feel you cannot do that. To enable us to care for you properly, please attend for reviews and blood tests if these are indicated.

We operate a zero tolerance policy towards abusive, threatening or violent behaviour.

Finally if our relationship breaks down irretrievably we both have the right to terminate our relationship.

TOWCESTER M.C. Privacy Notice for Patients

 Data Protection Privacy Notice for Patients

 Introduction

 This privacy notice lets you know what happens to any personal data that you give to us, or any information that we may collect from you or about you from other organisations.

This privacy notice applies to personal information processed by or on behalf of the practice.

This Notice explains:

• Who we are and how we use your personal information?
• Information about our Data Protection Officer
• What kinds of personal information we hold about you and what information we use
• The legal grounds for processing your personal information, including when we share it with other organisations.
• What to do if your personal information changes
• For how long your personal information is retained for/stored by us
• What your rights are under Data Protection laws

 The General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA18) became law on 25th May 2018. The GDPR is a single EU-wide regulation on the protection of confidential and sensitive information and the DPA18 implements the regulations into comprehensive UK legislation. Following the decision for the UK to leave the European Union and following the end of the transition period, from January 1^st, 2021 the UK has been subject to an Adequacy Agreement which will allow data to continue to be shared with European Union Countries without further safeguarding being necessary.  This is to allow the European Commission suitable time to grant the UK with adequacy status, meaning they have met the required standards in ensuring data transfers to and from the UK are safe.  All references to GDPR will now be referred to as UK GDPR.

 For the purpose of applicable data protection legislation (including UK GDPR) and the Data Protection Act 2018 the practice responsible for your personal data, and referred to at the Data Controller, is TOWCESTER M.C..

This Notice describes how we collect, use, and process your personal data, and how in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

How we use your information and the law

TOWCESTER M.C. will be the “Data Controller” of your personal data.

We collect basic personal data about you, which includes name, address, telephone number, email address, date of birth, next of kin information, NHS number etc.

We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, religious beliefs, (if required in a healthcare setting) ethnicity, sexuality etc.  and we may also receive this information about you from other health providers or third parties.

Your rights over your personal information

As an individual you have the following rights over your persona information:

Right to be informed – you have the right to be informed on how we handle, process, and share your personal information; this privacy notice ensures as a practice we satisfy this right.

Right to access your personal information– you can request access to and/or copies of the personal data we hold about you, free of charge (subject to exemptions) within one calendar month.  Such requests can be made verbally or in writing, but we do request that you provide us with adequate information to process your request, such as providing full name, address, date of birth, NHS number and details of your request and, where necessary, any documents to verify your identity.

On processing a request there may be occasions when information may be withheld if we as a practice believe that releasing the information to you could cause serious harm or distress. Information may also be withheld if another person (i.e., third party) is identified in the record, and they do not want their information disclosed to you. However, if the other person mentioned in your records was acting in their professional capacity in caring for you, in normal circumstances they could not prevent you from having access to that information.

To request a copy or request access to information we hold about you and/or to request information to be corrected if it is inaccurate, please contact: Dr Andrew Odwell LINK WAY, TOWCESTER, SOUTH NN12 6HH

Right to rectification – The correction of personal data when incorrect, out of date or incomplete will be acted upon within one calendar month of receipt of such a request.  Please ensure TOWCESTER M.C. has the correct contact details for you at all times.

Right to erasure – Under Article 17 of the UK GDPR individuals have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances, for example when your personal data is no longer necessary for the purpose which it was originally collected or processed for, or if you wish to withdraw your consent after you have previously given your consent.

Right to restrict processing – Article 18 of the UK GDPR gives individuals the right to restrict the processing of their personal data in certain circumstances. This means that you can limit the way that the practice uses your data. This is an alternative to requesting the erasure of your data. Individuals have the right to restrict the processing of their personal data where they have a particular reason for wanting the restriction.

Right to data portability – The right to data portability gives individuals the right to receive personal data they have provided to the Practice in a structured, commonly used, and machine-readable format (i.e., email, upload to a portable device etc.).

Right to object to processing – you have the right to object to processing, however, please note if we can demonstrate compelling legitimate grounds which outweighs your interest, then processing can continue.  If we did not process any information about you and your health care if would be very difficult for us to care and treat you.

Rights in relation to automated decision making and profiling – Automated individual decision-making is a decision made by automated means (i.e., a computer system) without any human involvement.  If any of the processes we use rely on automated decision making, you do have the right to ask for a human to review any computer-generated decision at any point.

 Why we need your information.

The healthcare professionals who provide you with care maintain records about your health and any treatment or care you have received previously.  These records help to provide you with the best possible healthcare and treatment.

NHS health records may be electronic, paper-based or a mixture of both.  We use a combination of working practices and technology to ensure that your information is kept confidential and secure.

Records about you may include the following information:

• Details about you, such as your address, your carer or legal representative and emergency contact details.
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments.
• Notes and reports about your health.
• Details about your treatment and care.
• Results of investigations such as laboratory tests, x-rays etc.
• Relevant information from other health professionals, relatives or those who care for you.
• Contact details (including email address, mobile telephone number and home telephone number)

To ensure you receive the best possible care, your records are used to facilitate the care you receive, including contacting you. Information held about you may be used to help protect the health of the public and to help us manage the NHS and the services we provide. Limited information may be used within the GP practice for clinical audit to monitor the quality of the service we provided.

How we lawfully use your data.

We need your personal, sensitive, and confidential data in order to provide you with healthcare services as a General Practice, under the UK GDPR we will be lawfully using your information in accordance with:

Article 6 (1)(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Article 9 (2) (h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems.

This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.

Risk Stratification 

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from several sources including NHS Trusts and from this GP Practice. The identifying parts of your data are removed, analysis of your data is undertaken, and a risk score is then determined. This is then provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on initiatives for preventing ill health and not just the treatment of sickness, so being far more proactive in an ever-changing health climate.  As a result of risk stratification, your GP may be able to offer you additional services. Please note that you have the right to opt-out of your data being used in this way in most circumstances; please see appendix A for further information and contact the practice if you wish to discuss opt-out preferences.

Individual Risk Management at a GP practice level however is deemed to be part of your individual healthcare and is covered by our legal powers above.

Our data processor for Risk Stratification is: Dr Andrew Odwell

Medicines Management

The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments. The reviews are carried out by the Clinical Commissioning Group’s Medicines Management Team under a Data Processing contract with the Practice.

Patient Communication

The Practice would like to use your name, contact details, and email address to inform you of NHS services, or provide inform about your health/information to manage your healthcare or information about the management of the NHS service.  There may be occasions where authorised research facilities would like you to take part in research in regard to your particular health issues, to try and improve your health. Your contact details may be used to invite you to receive further information about such research opportunities, but you must give your explicit consent to receive messages for research purposes.

Safeguarding

The Practice is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently, and conscientiously applied with the wellbeing of all patients at the heart of what we do.

Our legal basis for processing information for safeguarding purposes, as stipulated in the UK GDPR is:

Article 6(1)(e) ‘…exercise of official authority…’.

For the processing of special categories data, the basis is:

Article 9(2)(b) – ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law…’

Categories of personal data

The data collected by Practice staff in the event of a safeguarding situation, will be minimised to include only the personal information as is necessary in order to handle the situation. In addition to some basic demographic and contact details, we will also process details of what the safeguarding concern is. This is likely to be special category information.

Sources of the data

The Practice will either receive or collect information when someone contacts the organisation with safeguarding concerns, or we believe there may be safeguarding concerns and make enquiries to relevant providers.

Recipients of personal data

The information is used by the Practice when handling a safeguarding incident or concern. We may share information accordingly to ensure duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals (i.e., their GP or mental health team).

Research

Clinical Practice Research Datalink (CPRD) collects anonymised patient data from a network of GP practices across the UK. Primary care data is linked to a range of other health related data to provide a fully representative UK population health dataset.  You can opt out of your information being used for research purposes at any time (as detailed in Appendix A) and full details on CRPD can be found here:

https://cprd.com/transparency-information

General Practice Data for Planning and Research

The NHS needs data about the patients it treats in order to plan and deliver its services and to ensure that care and treatment provided is safe and effective. The General Practice Data for Planning and Research data collection will help the NHS to improve health and care services for everyone by collecting patient data that can be used to do this. For example, patient data can help the NHS to:

• monitor the long-term safety and effectiveness of care.
• plan how to deliver better health and care services.
• prevent the spread of infectious diseases.
• identify new treatments and medicines through health research.

GP practices already share patient data for these purposes, but this new data collection will be more efficient and effective.  We have agreed to share the patient data we look after in our practice with NHS Digital who will securely store, analyse, publish, and share this patient data to improve health and care services for everyone. This includes:

• informing and developing health and social care policy
• planning and commissioning health and care services
• taking steps to protect public health (including managing and monitoring the coronavirus pandemic)
• in exceptional circumstances, providing you with individual care.
• enabling healthcare and scientific research

This means that we can get on with looking after our patients and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it to improve health and care for everyone.

Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality.

NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and GP practices.

What data is shared about you with NHS Digital?

Data will be shared from 1 July 2021. Data may be shared from the GP medical records about:

• any living patient registered at a GP practice in England when the collection started – this includes children and adults.
• any patient who died after this data sharing started and was previously registered at a GP practice in England when the data collection started.

We will not share your name or where you live. Any other data that could directly identify you, for example your NHS number, General Practice Local Patient Number, full postcode, and date of birth, is replaced with unique codes which are produced by de-identification software before the data is shared with NHS Digital.

This process is called pseudonymisation and means that no one will be able to directly identify you in the data. NHS Digital will be able to use the same software to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason. Only NHS Digital has the ability to do this.  An example would be where you consent to your identifiable data being shared with a research project or clinical trial in which you are participating, as they need to know the data is about you.

For more information about when NHS Digital may be able to re-identify the data, and how NHS Digital will use your data see the NHS Digital General Practice Data for Planning and Research Transparency Notice.

Opting Out

If you don’t want your identifiable patient data to be shared for purposes except for your own care, you can opt-out by registering a Type 1 Opt-out or a National Data Opt-out, or both. These opt-outs are different, and they are explained in more detail below. Your individual care will not be affected if you opt out using either option.

Type 1 Opt-Outs – If you do not want your identifiable patient data to be shared outside of the GP practice for purposes except your own care, you can register an opt-out with the GP practice. This is known as a Type 1 Opt-out.  Type 1 Opt-outs were introduced in 2013 for data sharing from GP practices, but may be discontinued in the future as a new opt-out has since been introduced to cover the broader health and care system, called the National Data Opt-out. If this happens, patients who have registered a Type 1 Opt-out will be informed. There is more information about National Data Opt-outs below.

NHS Digital will not collect any patient data for patients who have already registered a Type 1 Opt-in line with current policy. If this changes patients who have registered a Type 1 Opt-out will be informed.

If you do not want your patient data shared with NHS Digital for the purposes above, you can register a Type 1 Opt-out with your GP practice. You can register a Type 1 Opt-out at any time. You can also change your mind at any time and withdraw a Type 1 Opt-out.

If you have already registered a Type 1 Opt-out with us your data will not be shared with NHS Digital.  If you wish to register a Type 1 Opt-out with your us before data sharing starts with NHS Digital, this should be done by returning this form to us practice by 23 June 2021 to allow time for processing it. If you have previously registered a Type 1 Opt-out and you would like to withdraw this, you can also use the form to do this. You can send the form by post or email to your us at the GP Practice or call 0300 3035678 for a form to be sent out to you.

If you register a Type 1 Opt-out after your patient data has already been shared with NHS Digital, no more of your data will be shared with NHS Digital. NHS Digital will however still hold the patient data which was shared with them before you registered the Type 1 Opt-out.

If you do not want NHS Digital to share your identifiable patient data with anyone else for purposes beyond your own care, then you can also register a National Data Opt-out.

National Data Opt-Out

If you don’t want your confidential patient information to be shared by NHS Digital with other organisations for purposes except your own care – either GP data, or other data it holds, such as hospital data – you can register a National Data Opt-out.

If you have registered a National Data Opt-out, NHS Digital will not share any confidential patient information about you with other organisations, unless there is an exemption to this, such as where there is a legal requirement or where it is in the public interest to do so, such as helping to manage contagious diseases like coronavirus. You can find out more about exemptions on the NHS website.

From 1 October 2021, the National Data Opt-out will also apply to any confidential patient information shared by the GP practice with other organisations for purposes except your individual care. It will not apply to this data being shared by GP practices with NHS Digital, as it is a legal requirement for us to share this data with NHS Digital and the National Data Opt-out does not apply where there is a legal requirement to share data.

You can find out more about and register a National Data Opt-out or change your choice on nhs.uk/your-nhs-data-matters or by calling 0300 3035678.

The legal bases for processing this information.

The Health and Social Care Act 2012 covers the sharing and collection of health and care data.  It says that when the Secretary of State for Health and Social Care needs to collect and analyse data to help the health service, they can tell NHS Digital to do this for them.  The instruction, which NHS Digital must act on, is called a direction.  In this case:

1.) The Secretary of State for Health and Social Care sent a direction to NHS Digital, instructing them to collect and analyse general practice data for health and social care purposes including policy, planning, commissioning, public health, and research purposes.

2.) NHS Digital sent all GP practices a document called a Data Provision Notice, giving details of the data it needs GP Practices like ours to share so it can comply with the direction.  All GP Practices in England are required to share data with NHS Digital when they are sent a Data Provision Notice.

Under data protection law, we can only share patient data if we have a legal basis under Articles 6 and 9 of the UK GDPR.  Our legal basis for sharing patient data with NHS Digital is Article 6(1)(c) – legal obligation, as we are required under the 2012 Act to share it with NHS Digital.

When we are sharing patient data about health, we also need a legal basis under Article 9 of the UK GDPR.  This is:

• Article 9(2)(g) – as we are sharing patient data for reasons of substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the General Practice Data for Planning and Research Directions. It is substantially in the public interest to process patient data for planning and research purposes to improve health and care services for everyone. This is permitted under paragraph 6 of Schedule 1 of the Data Protection Act 2018 (DPA).
• Article 9(2)(h) – as we are sharing patient data for the purposes of providing care and managing health and social care systems and services. This is permitted under paragraph 2 of Schedule 1 of the DPA.
• Article 9(2)(i) – as patient data will also be used for public health purposes. This is permitted under paragraphs 3 of Schedule 1 of the DPA.
• Article 9(2)(j) – as patient data will also be used for the purposes of scientific research and for statistical purposes. This is permitted under paragraph 4 of Schedule 1 of the DPA.

Third party processors

In order to deliver the best possible service, the practice will share data (where required) with other NHS bodies such as other GP practices and hospitals. In addition, the practice will use carefully selected third party service providers. When we use a third-party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties include:

• Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
• Delivery services (for example if we were to arrange for delivery of any medicines to you).
• Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).

Further details regarding specific third-party processors can be supplied on request to the practice.

How we maintain the confidentiality of your records

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

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

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.

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

Our practice policy is to respect the privacy of our patients, their families, and our staff and to maintain compliance with the UK GDPR and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.

All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary.  If a sub-contractor acts as a data processor for TOWCESTER M.C. an appropriate contract will be established for the processing of your information.

In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Dr Andrew Odwellin writing if you wish to withdraw your consent.  If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.

Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose in an identifiable format.   In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes.

With your consent we would also like to use your information

There are times that we may want to use your information to contact you or offer you services, not directly about your healthcare, in these instances we will always gain your consent to contact you.  We would however like to use your name, contact details, and email address to inform you of other services that may benefit you.  We will only do this with your consent.  There may be occasions where authorised research facilities would like you to take part on innovations, research, improving services or identifying trends, you will be asked to opt into such programmes if you are happy to do so.

At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice.

Where we store your electronic information

All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.

No third parties have access to your personal data unless the law allows them to do so, and appropriate safeguards have been put in place such as a Data Processing agreement.  We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category data.

EMIS Web

The Practice uses a clinical system provided by a Data Processor called EMIS.  Since June 2019, EMIS commenced storing your practice’s EMIS Web data in a highly secure, third party cloud hosted environment, namely Amazon Web Services (“AWS”).

The data will remain in the UK at all times and will be fully encrypted both in transit and at rest. In doing this there will be no change to the control of access to your data and the hosted service provider will not have any access to the decryption keys. AWS is one of the world’s largest cloud companies, already supporting numerous public sector clients (including the NHS), and it offers the very highest levels of security and support.

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/Foundation Trusts
• GP’s
• Primary Care Networks
• Integrated Care Systems
• NHS Commissioning Support Units
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• NHS England (NHSE) and NHS Digital (NHSD)
• Multi Agency Safeguarding Hub (MASH)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Other ‘data processors’ which you will be informed of

You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.

Computer System of Choice

This practice operates a Clinical Computer System of Choice on which NHS Staff record information securely.  This information can then be shared with other clinicians so that everyone caring for you is fully informed about your medical history, including allergies and medication.

To provide around the clock safe care, unless you have asked us not to, we will make information available to our Partner Organisations (as listed above).  Wherever possible, their staff will ask for your consent before your information is viewed.

Shared Care Records

To support your care and improve the sharing of relevant information to our partner organisations when they are involved in looking after you, we will share information to other systems.  You can opt-out of this sharing of your records with our partners at any time if this sharing is based on your consent.

We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.  All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for TOWCESTER M.C. an appropriate contract will be established for the processing of your information.

Sharing your information without consent

We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:

• where there is a serious risk of harm or abuse to you or other people.
• Safeguarding matters and investigations
• where a serious crime, such as assault, is being investigated or where it could be prevented.
• notification of new births
• where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS)
• where a formal court order has been issued
• where there is a legal requirement, for example if you had committed a Road Traffic Offence.

How long we store your information for

We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.

More information on records retention can be found in the NHS Records Management Code of Practice 2020

https://www.nhsx.nhs.uk/media/documents/NHSX_Records_Management_Code_of_Practice_2020_3.pdf

Destruction

This will only happen following a review of the information at the end of its retention period. Where data has been identified for disposal, we have the following responsibilities:

• to ensure that information held in manual form is destroyed using a cross-cut shredder or contracted to a reputable confidential waste company Shredsafe that complies with European Standard EN15713 and obtain certificates of destruction.
• to ensure that electronic storage media used to store, or process information are destroyed or overwritten to national standards.

Primary Care Networks

The objective of Primary Care Networks (PCNs) is for group practices working together to create more collaborative workforces which ease the pressure of GP’s, leaving them better able to focus on patient care. The aim is for all areas within England to be covered by a PCN.

Primary Care Networks form a key building block of the NHS long-term plan. Bringing general practices together to work at scale has been a policy priority for some years for a range of reasons, including improving the ability of practices to recruit and retain staff; to manage financial and estates pressures; to provide a wider range of services to patients and to integrate with the wider health and care system more easily.

All GP practices are expected to come together in geographical networks covering populations of approximately 30–50,000 patients and take advantage of additional funding attached to the GP contract.

This means the practice may share your information with other practices within the PCN to provide you with your care and treatment.

TOWCESTER M.C. is a member of the Brackley and Towcester PCN which includes the following local GP Practices:

Brook Health Centre

Brackley Medical Centre

Springfield Surgery

Access to your personal information 

You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. For any request you should:

• Make your request directly to the practice. (For information from a hospital or other Trust/ NHS organisation you should write directly to them).
• Be aware that there is no charge to have a copy of the information held about you.
• Be aware that information must be released to you within one calendar month (unless in exceptional circumstances, which you will be informed of a part of the process)
• Be aware you may be asked for key information to process the request (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records retrieved.

What to do if your personal information changes

You should tell us so that we can update our records as we are required to keep accurate and up-to-date records at all times.  Please contact the Practice as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number).   The practice will from time to time ask you to confirm that the information we currently hold is accurate and up to date.

Objections/Complaints

Should you have any concerns about how your information is managed at the practice, please contact the Dr Andrew Odwell in the first instance. If you are still unhappy following a review of your concerns by the practice, you have the right to lodge a complaint with a supervisory authority, the Information Commissioner’s Office using the contact details below:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 01625 545745

https://ico.org.uk/

If you are happy for your data to be used for the purposes described in this privacy notice, then you do not need to do anything.  If you have any concerns about how your data is shared, then please contact the Practice Data Protection Officer, Caldicott Guardian or IG Lead.

If you would like to know more about your rights in respect of the personal data that we hold about you, please use the contact details below:

IG Lead:

Dr Andrew Odwell

Caldicott Guardian:

Dr Andrew Odwell

Data Protection Officer:

Hayley Gidman

Useful Links

Please find below some links to external webpages which you may wish to access to find out additional information:

• Information Commissioners Office
• Information Governance Alliance
• NHS Constitution
• NHS Digital Guide to Confidentiality in Health and Social Care
• Health Research Authority
• Health Research Authority Confidentiality Advisory Group (CAG)
• National Data Opt-Out

May 2021

Towcester Medical Centre is an accredited Training Practice involved in the teaching of both GP Registrars and Medical Students. We value their fresh ideas, and learn a lot from them. Being approved for training also helps us to monitor and improve our patient care continually.

You may be offered an appointment with a Registrar, who is a fully qualified Doctor undergoing specialist GP training, or you may find your GP or Nurse accompanied by a Medical Student or Registrar.

We will always advise you if the doctor you are seeing is accompanied by a Registrar or medical student. If you are uncomfortable about this, please tell our receptionist, and an alternative appointment will be offered, or we will make sure that they are not present at your consultation.

As part of continuous improvement our registrars sometimes video their consultations, this is only viewed by them and their trainer and is deleted afterwards. This will not be done without your consent and you can change your mind at any point during or after the consultation.