Policies and Procedures

You can now see your test results and read notes from your appointments in your NHS account.

This will help you see your test results and read notes from your appointments.

What’s changed

You will now be able to see all the information within your health record automatically.

If you are over 16 and have an online NHS account, such as through the NHS App or NHS website, you can now see all your notes from your GP.

For most people, access will be automatic and you won’t need to do anything.

What health information you can see

You will be able to access:

• notes from GP appointments
• test results
• any letters saved on your records

This only applies to records from your GP, not from hospitals or other specialists.

Privacy advice

If you do not want to see your health record or if you have any concerns, please talk to your GP.

The NHS app and website are secure so no one is able to access your information except you.

If you do not have the NHS app or an online account

These changes only apply to people with the NHS app or an online NHS account.

If you do not want an online account, you can still access your health records by asking at reception.

If you have a complaint or concern about the service you have received from the doctors or any of the staff working in this GP surgery, please let us know. This includes Primary Care Network staff working as part of our GP surgery. We operate a complaints procedure as part of an NHS system for dealing with complaints. Our complaints system meets national criteria.

How to complain

We hope that most problems can be sorted out easily and quickly when they arise and with the person concerned. For example, by requesting a face-to-face meeting to discuss your concerns.

If your problem cannot be sorted out this way and you wish to make a complaint, we would like you to let us know as soon as possible. By making your complaint quickly, it is easier for us to establish what happened. 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 this is within 12 months of the incident.

Complaints should be addressed to the GP surgery team verbally or in writing to the Practice Manager. Alternatively, you may ask for an appointment with the GP surgery to discuss your concerns. They will explain the complaints procedure to you and make sure your concerns are dealt with promptly. Please be as specific as possible about your complaint.

What we will do

We will acknowledge your complaint within three working days. We will aim to have investigated your complaint within ten working days of the date you raised it with us. We will then offer you an explanation or a meeting with the people involved, if you would like this. When we investigate your complaint, we will aim to:

• Find out what happened and what went wrong.
• Make it possible for you to discuss what happened with those concerned, if you would like this.
• Make sure you receive an apology, where this is appropriate.
• Identify what we can do to make sure the problem does not happen again.

Complaining on behalf of someone else

We take medical confidentiality seriously. If you are complaining on behalf of someone else, we must know that you have their permission to do so. A note signed by the person concerned will be needed unless they are incapable (because of illness) of providing this.

Complaining to NHS England

We hope that you will use our Practice Complaints Procedure if you are unhappy. We believe this will give us the best chance of putting right whatever has gone wrong and an opportunity to improve our GP surgery.

However, if you feel you cannot raise the complaint with us directly, please contact NHS England. You can find more information on how to make a complaint at https://www.england.nhs.uk/contact-us/complaint/complaining-to-nhse/.

Unhappy with the outcome of your complaint?

If you are not happy with the way your complaint has been dealt with by the GP surgery and NHS England and would like to take the matter further, you can contact the Parliamentary and Health Service Ombudsman (PHSO). The PHSO makes final decisions on unresolved complaints about the NHS in England. It is an independent service which is free for everyone to use.

To take your complaint to the Ombudsman, visit the Parliamentary and Health Service Ombudsman website or call 0345 015 4033

Your Data Matters to the NHS

Information about your health and care helps us to improve your individual care, speed up diagnosis, plan your local services and research new treatments. The NHS is committed to keeping patient information safe and always being clear about how it is used.

How your data is used

Information about your individual care such as treatment and diagnoses is collected about you whenever you use health and care services. It is also used to help us and other organisations for research and planning such as research into new treatments, deciding where to put GP clinics and planning for the number of doctors and nurses in your local hospital.  It is only used in this way when there is a clear legal basis to use the information to help improve health and care for you, your family and future generations.

Wherever possible we try to use data that does not identify you, but sometimes it is necessary to use your confidential patient information.

You have a choice

You do not need to do anything if you are happy about how your information is used. If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service. You can change your mind about your choice at any time.

Will choosing this opt-out affect your care and treatment?

No, choosing to opt out will not affect how information is used to support your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.

What do you need to do?

If you are happy for your confidential patient information to be used for research and planning, you do not need to do anything.

To find out more about the benefits of data sharing, how data is protected, or to make/change your opt-out choice visit www.nhs.uk/your-nhs-data-matters

National Data Opt- Out

The National Date opt-out is a service that allows patients to opt out of their confidential patient information being use for research and planning. The data extracted will be pseudonymized (not directly identifiable) For more information about opting out please call 0300 3035678 or please visit;

https://digital.nhs.uk/services/national-data-opt-out

The current NHS Digital (NHSD) extract of GP data for Research purposes (known as the GPDPR) has been delayed due to NHSD wishing to review the way in which this data will be collected, to conduct more public involvement and information about the plans and change the way in which patients can opt out of the extract of their GP data. Currently the only way to opt out is to complete a Type 1 opt out form and return this to the practice by the 1^st September.  However, this extract will not be taken until the NHSD have changed the way it will take the data and respect the patient’s choice for using their data.  NHSD are introducing the following changes to the opt out process which will mean that patients will be able to change their opt-out status at any time:

• Patients do not need to register a Type 1 opt-out by 1st September to ensure their GP data will not be uploaded.
• NHS Digital will create the technical means to allow GP data that has previously been uploaded to the system via the GPDPR collection to be deleted when someone registers a Type 1 opt-out.
• The plan to retire Type 1 opt-outs will be deferred for at least 12 months while we get the new arrangements up and running and will not be implemented without consultation with the RCGP, the BMA and the National Data Guardian.

This means that you can opt out at any time in the future and NHSD will delete data that they already have taken for research purposes, the deadline of the 01/09/2020 has been delayed until a new system of opt out is developed.  Hopefully, this will be a simple centralised approach via the NHS app or NHS website to avoid paper form and administration work for your GP. We will update you when we know more about the NHSD plans to change how you can control who has access to your data.

Download a copy of the patient leaflet

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 information
• Information about our Data Protection Officer
• What kinds of personal information about you we hold and use (process)
• The legal grounds for our processing of your personal information (including when we share it with others)
• What should you do if your personal information changes?
•  For how long your personal information is retained / stored by us?
• What are your rights under Data Protection laws

 The General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA 2018) became law on 25th May 2018. The GDPR is a single EU-wide regulation on the protection of confidential and sensitive (special) information, the DPA 2018 deals with elements of UK law that differ from the European Regulation, both came into force in the UK on the 25th May 2018, repealing the previous Data Protection Act (1998).

 For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the Data Protection Act 2018 the practice responsible for your personal data is Sina Health Centre.

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.

Sina Health Centre will be what’s known as the ‘Controller’ of your personal data.

We collect basic personal data about you and location-based information.  This does include name, address and contact details such as email and mobile number etc.

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

Why do we need your information?

The health care 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 do 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 General Data Protection Regulation we will be lawfully using your information in accordance with:

Article 6, 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, (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.

We use your personal and healthcare information in the following ways:

• 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;
• 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 consent to do so.

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 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).

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 (eg 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

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 preventing ill health and not just the treatment of sickness. If necessary, 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 contact the practice for further information about opt out.

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.

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 CCGs Medicines Management Team under a Data Processing contract with the Practice.

Anonymised information

Sometimes we may provide information about you in an anonymised form. Such information is used analyse population- level heath issues and helps the NHS to plan better services. If we share information for these purposes, then none of the information will identify you as an individual and cannot be traced back to you.

GP Connect Service

The GP Connect service allows authorised clinical staff at NHS 111 to seamlessly access our practice’s clinical system and book directly on behalf of a patient. This means that should you call NHS 111 and the clinician believes you need an appointment with your GP Practice, the clinician will access available appointment slots only (through GP Connect) and book you in. This will save you time as you will not need to contact the practice direct for an appointment.

The practice will not be sharing any of your data and the practice will only allow NHS 111 to see available appointment slots. They will not even have access to your record. However, NHS 111 will share any relevant data with us, but you will be made aware of this. This will help your GP in knowing what treatment / service / help you may require.

Please note if you no longer require the appointment or need to change the date and time for any reason you will need to speak to one of our reception staff and not NHS 111.

Patient Communication

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 in the event that 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. As this is operated on an ‘opt out’ basis we will assume that you give us permission to contact you via SMS if you have provided us with your mobile telephone number. Please let us know if you wish to opt out of this SMS service. We may also contact you using the email address you have provided to us. Please ensure that we have your up to date details.

There may be occasions where authorised research facilities would like you to take part in research. Your contact details may be used to invite you to receive further information about such research opportunities.

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, at the heart of what we do.

Our legal basis for processing For the General Data Protection Regulation (GDPR) purposes 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…’

Research

Clinical Practice Research Datalink (CPRD) collects de-identified patient data from a network of GP practices across the UK. Primary care data are linked to a range of other health related data to provide a longitudinal, representative UK population health dataset.  You can opt out of your information being used for research purposes at any time (see below), full details can be found here:

https://cprd.com/transparency-information

The legal bases for processing this information

CPRD do not hold or process personal data on patients; however, NHS Digital (formally the Health and Social Care Centre) may process ‘personal data’ for us as an accredited ‘safe haven’ or ‘trusted third-party’ within the NHS when linking GP data with data from other sources. The legal bases for processing this data are:

• Medicines and medical device monitoring: Article 6(e) and Article 9(2)(i) – public interest in the area of public health
• Medical research and statistics: Article 6(e) and Article 9(2)(j) – public interest and scientific research purposes

Any data CPRD hold or pass on to bona fide researchers, except for clinical research studies, will have been anonymised in accordance with the Information Commissioner’s Office Anonymisation Code of Practice. We will hold data indefinitely for the benefit of future research, but studies will normally only hold the data we release to them for twelve months.

Categories of personal data

The data collected by Practice staff in the event of a safeguarding situation will be as much personal information as is possible that is necessary to obtain 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 (such as health 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).

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 Data Protection Officer as below.

How do we maintain the confidentiality of your records? 

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

• Data Protection Act 2018
• The General Data Protection Regulations 2016
• 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 General Data Protection Regulation (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 [Practice Name] an appropriate contract (art 24-28) 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 Data Protection Officer in 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 DPO as below.

National Opt-Out Facility

You can choose whether your confidential patient information is used for research and planning.

Who can use your confidential patient information for research and planning?

It is used by the NHS, local authorities, university and hospital researchers, medical colleges and pharmaceutical companies researching new treatments.

Making your data opt-out choice

You can choose to opt out of sharing your confidential patient information for research and planning. There may still be times when your confidential patient information is used: for example, during an epidemic where there might be a risk to you or to other people’s health. You can also still consent to take part in a specific research project.

Will choosing this opt-out affect your care and treatment?

No, your confidential patient information will still be used for your individual care. Choosing to opt out will not affect your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.

What should you do next?

You do not need to do anything if you are happy about how your confidential patient information is used.

If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service.

You can change your choice at any time. To find out more or to make your choice visit nhs.uk/your-nhs-data-matters or call 0300 303 5678

NHS Digital Data Collection from the Practice

The NHS needs data about the patients it treats 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.

This means that GPs can get on with looking after their 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.

NHS Digital purposes for processing patient data

Patient data from GP medical records kept by GP practices in England is used every day to improve health, care and services through planning and research, helping to find better treatments and improve patient care. The NHS is introducing an improved way to share this information – called the General Practice Data for Planning and Research data collection.

NHS Digital will collect, 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

Any data that NHS Digital collects will only be used for health and care purposes. It is never shared with marketing or insurance companies.

What patient data NHS Digital collect

This collection will start from 1 September 2021. Patient data will be collected from 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 the data collection started, and was previously registered at a GP practice in England when the data collection started

We will not collect your name or where you live. Any other data that could directly identify you, for example 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. The diagram below helps to explain what this means. Using the terms in the diagram, the data we collect would be described as de-personalised.

Image provided by Understanding Patient Data under licence.

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. This would mean that the data became personally identifiable data in the diagram above. 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.

More information about when we may be able to re-identify the data is in the who we share your patient data with section below.

The Data NHD Digital collect

We will only collect structured and coded data from patient medical records that is needed for specific health and social care purposes explained above.

Data that directly identifies you as an individual patient, including your NHS number, General Practice Local Patient Number, full postcode, date of birth and if relevant date of death, is replaced with unique codes produced by de-identification software before it is sent to NHS Digital. This means that no one will be able to directly identify you in the data.

NHS Digital will be able to use the 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. This would mean that the data became personally identifiable in the diagram above. It will still be held securely and protected, including when it is shared by NHS Digital.

NHS Digital will collect

• data on your sex, ethnicity and sexual orientation
• clinical codes and data about diagnoses, symptoms, observations, test results, medications, allergies, immunisations, referrals and recalls, and appointments, including information about your physical, mental and sexual health
•  data about staff who have treated you

More detailed information about the patient data we collect is contained in the Data Provision Notice issued to GP practices.

NHS Digital Does not collect.

• your name and address (except for your postcode in unique coded form)
• written notes (free text), such as the details of conversations with doctors and nurses
• images, letters and documents
• coded data that is not needed due to its age – for example medication, referral and appointment data that is over 10 years old
•  coded data that GPs are not permitted to share by law – for example certain codes about IVF  treatment, and certain information about gender re-assignment

Opting out of NHS Digital collecting your data (Type 1 Opt-out)

If you do not want your identifiable patient data (personally identifiable data in the diagram above) to be shared outside of your GP practice for purposes except for your own care, you can register an opt-out with your 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 people who have registered a Type 1 Opt-out will be informed. More about National Data Opt-outs is in the section Who we share patient data with.

NHS Digital will not collect any patient data for patients who have already registered a Type 1 Opt-out 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, 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.

Data sharing with NHS Digital will start on 1 September 2021.

If you have already registered a Type 1 Opt-out with your GP practice your data will not be shared with NHS Digital.

If you wish to register a Type 1 Opt-out with your GP practice before data sharing starts with NHS Digital, this should be done by returning this form to your GP practice. 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 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 us before you registered the Type 1 Opt-out.

If you do not want NHS Digital to share your identifiable patient data (personally identifiable data in the diagram above) with anyone else for purposes beyond your own care, then you can also register a National Data Opt-out. There is more about National Data Opt-outs and when they apply in the National Data Opt-out section below.

NHS Digital legal basis for collecting, analysing and sharing patient data.

When we collect, analyse, publish and share patient data, there are strict laws in place that we must follow. Under the UK General Data Protection Regulation (GDPR), this includes explaining to you what legal provisions apply under GDPR that allows us to process patient data. The GDPR protects everyone’s data.

NHS Digital has been directed by the Secretary of State for Health and Social Care under the General Practice Data for Planning and Research Directions 2021 to collect and analyse data from GP practices for health and social care purposes including policy, planning, commissioning, public health and research purposes.

NHS Digital is the controller of the patient data collected and analysed under the GDPR jointly with the Secretary of State for Health and Social Care.

All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the Data Provision Notice issued by NHS Digital to GP practices.

NHS Digital has various powers to publish anonymous statistical data and to share patient data under sections 260 and 261 of the 2012 Act. It also has powers to share data under other Acts, for example the Statistics and Registration Service Act 2007.

Regulation 3 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) also allow confidential patient information to be used and shared appropriately and lawfully in a public health emergency. The Secretary of State has issued legal notices under COPI (COPI Notices) requiring NHS Digital, NHS England and Improvement, arm’s-length bodies (such as Public Health England), local authorities, NHS trusts, clinical commissioning groups and GP practices to share confidential patient information to respond to the COVID-19 outbreak. Any information used or shared during the COVID-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use confidential patient information.

The legal basis under GDPR for General Practice Data for Planning and Research

How NHS Digital use patient data

NHS Digital will analyse and link the patient data we collect with other patient data we hold to create national data sets and for data quality purposes.

NHS Digital will be able to use the de-identification software to convert the unique codes back to data that could directly identify you in certain circumstances for these purposes, where this is necessary and where there is a valid legal reason. There are strict internal approvals which need to be in place before we can do this and this will be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD).

These national data  sets are analysed and used by NHS Digital to produce national statistics and management information, including public dashboards about health and social care which are published. We never publish any patient data that could identify you. All data we publish is anonymous statistical data.

For more information about data we publish see Data and Information and Data Dashboards.

We may also carry out analysis on national data sets for data quality purposes and to support the work of others for the purposes set out in Our purposes for processing patient data section above.

Who NHS Digital share patient data with

All data which is shared by NHS Digital is subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the relevant health and social care purpose will be shared.

All requests to access patient data from this collection, other than anonymous aggregate statistical data, will be assessed by NHS Digital’s Data Access Request Service, to make sure that organisations have a legal basis to use the data and that it will be used safely, securely and appropriately.

These requests for access to patient data will also be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD). Organisations approved to use this data will be required to enter into a data sharing agreement with NHS Digital regulating the use of the data.

There are a number of organisations who are likely to need access to different elements of patient data from the General Practice Data for Planning and Research collection.

These include but may not be limited to:

• the Department of Health and Social Care and its executive agencies, including Public Health England and other government departments
• NHS England and NHS Improvement
• primary care networks (PCNs), clinical commissioning groups (CCGs) and integrated care organisations (ICOs)
• local authorities
• research organisations, including universities, charities, clinical research organisations that run clinical trials and pharmaceutical companies

If the request is approved, the data will either be made available within a secure data access environment within NHS Digital infrastructure, or where the needs of the recipient cannot be met this way, as a direct dissemination of data. We plan to reduce the amount of data being processed outside central, secure data environments and increase the data we make available to be accessed via our secure data access environment. For more information read about improved data access in improving our data processing services.

Data will always be shared in the uniquely coded form (de-personalised data in the diagram above) unless in the circumstances of any specific request it is necessary for it to be provided in an identifiable form (personally identifiable data in the diagram above). For example, when express patient consent has been given to a researcher to link patient data from the General Practice for Planning and Research collection to data the researcher has already obtained from the patient.

It is therefore possible for NHS Digital to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason which permits this without breaching the common law duty of confidentiality.

This would include:

• where the data was needed by a health professional for your own care and treatment
• where you have expressly consented to this, for example to participate in a clinical trial
• where there is a legal obligation, for example where the COPI Notices apply – see Our legal basis for collecting, analysing and sharing patient data above for more information on this
• where approval has been provided by the Health Research Authority or the Secretary of State with support from the Confidentiality Advisory Group (CAG) under Regulation 5 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) – this is sometimes known as a ‘section 251 approval’

This would mean that the data was personally identifiable in the diagram above. Re-identification of the data would only take place following approval of the specific request through the Data Access Request Service, and subject to independent assurance by IGARD and consultation with the Professional Advisory Group, which is made up of representatives from the BMA and the RCGP. If you have registered a National Data Opt-out, this would be applied in accordance with the National Data Opt-out policy before any identifiable patient data (personally identifiable data in the diagram above) about you was shared. More about the National Data Opt-out is in the section below.

Details of who we have shared data with, in what form and for what purposes are published on our data release register.

Where NHS digital stores patient data

NHS Digital only stores and processes patient data for this data collection within the United Kingdom (UK).

Fully anonymous data (that does not allow you to be directly or indirectly identified), for example statistical data that is published, may be stored and processed outside of the UK. Some of our processors may process patient data outside of the UK. If they do, we will always ensure that the transfer outside of the UK complies with data protection laws.

Where do we store your information electronically?

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 3rd 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 Processor as above).

We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.

EMIS Web

The Practice uses a clinical system provided by a Data Processor called EMIS, from 10^th June 2019, EMIS started 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.

Who are our partner organisations?

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

• NHS Trusts / Foundation Trusts
• GP’s
• Primary Care Network
• 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
• Voluntary Sector Providers
• Private Sector Providers
• 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

This practice operates a Clinical Computer System 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 Organisation (above).  Wherever possible, their staff will ask 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 (as above) 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 anytime 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 Sina Health Centre an appropriate contract (art 24-28) 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 will we store your information?

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 online at (https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016).

How can you access, amend move the personal data that you have given to us?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data and you do not agree, you have the right to object. We will respond to your request within one month (although we may be allowed to extend this period in certain cases). This is NOT an absolute right sometimes we will need to process your data even if you object.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project, or consent to send you information about us or matters you may be interested in), you may withdraw your consent at any time.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within one month (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will need to keep a note of your name/ other basic details on our register of individuals who would prefer not to be contacted. This enables us to avoid contacting you in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.

Primary Care Network

The objective of primary care networks (PCNs) is for group practices together to create more collaborative workforces which ease the pressure of GP’s, leaving them better able to focus on patient care.

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 more easily integrate with the wider health and care system.

All GP practices are expected to come together in geographical networks covering populations of approximately 30–50,000 patients by June 2019 if they are to take advantage of additional funding attached to the GP contract. This size is consistent with the size of the primary care homes, which exist in many places in the country, but much smaller than most GP Federations.

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

Access to your personal information 

Data Subject Access Requests (DSAR): 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.

To request this, you need to do the following:

• Your request should be made to the Practice. (For information from a hospital or other Trust/ NHS organisation you should write direct to them.
• There is no charge to have a copy of the information held about you
• We are required to provide you with information within one month
• You will need to give adequate information (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 located information we hold about you at any time.

What should you do if your personal information changes?

You should tell us so that we can update our records please contact the Practice Manager 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.

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.

Third parties mentioned on your medical record

Sometimes we record information about third parties mentioned by you to us during any consultation, or contained in letters we receive from other organisations. 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.

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.

The Surgery’s website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy.

CCTV recording

CCTV is installed on our practice premises covering both the external area of the building and the internal area excluding consulting rooms. Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime. The images are recorded onto an integral hard drive of the equipment and are overwritten on a rolling basis. Viewing of these digital images is password protected and controlled by the Practice Manager.

Telephone system

Our telephone system records all telephone calls. Recordings are retained for up to three years, and are used periodically for the purposes of seeking clarification where there is a dispute as to what was said and for staff training Access to these recordings is restricted to named senior staff.

Objections / Complaints

Should you have any concerns about how your information is managed at the GP, please contact the GP Practice Manager or the Data Protection Officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.

Information Commissioner:

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.

If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.

Data Protection Officer:

The Practice Data Protection Officer is Paul Couldrey of PCIG Consulting Limited. Any queries regarding Data Protection issues should be addressed to him at:

Email:             Couldrey@me.com

Postal:            PCIG Consulting Limited

7 Westacre Drive

Quarry Bank

Dudley

West Midlands

DY5 2EE

Changes:

It is important to point out that we may amend this Privacy Notice from time to time.  If you are dissatisfied with any aspect of our Privacy Notice, please contact the Practice Data Protection Officer.

Covid-19 Privacy Notice

GDPR Poster – For Patients

Practice Information Governance Policy

How we use your information – Leaflet

Your Data Matters

What a DNA is

A DNA appointment is when a patient does not turn up for appointments, and does not contact the surgery to cancel or change the appointment.

This creates a significant strain on the NHS.

We understand that there are situations that can make it impossible for you to cancel your appointment, for example being admitted to hospital.

Our DNA policy

1. If you fail to attend 2 or more appointments in the the previous month, you will get a warning letter.
2. If you’ve had a warning letter and you miss another appointment, you’ll get another letter. This will say that you can only book appointments on the day, and not in advance.
3. If you do not attend same day appointments, we will invite you to discuss a contract and an appointment plan. This will include you calling to confirm an appointment, if not it will be cancelled.

Warning letters last 12 months.

Cancelling appointments

To avoid DNA appointments, you can use the NHS app or online services to cancel your appointments.

You can also get a text reminder of your appointment, and you can reply to this to cancel if necessary. Please make sure we have the right mobile number for you.

Contact us

If you would like to discuss DNAs, please contact the surgery.

See our contact details

Staff and Patients

The Practice is committed to ensuring that, as far as is reasonably practicable, the way in which we provide services to the public and the way in which we treat our staff reflects their individual needs and does not discriminate against individuals or groups on any grounds.

Equality and Diversity

The Practice aims to promote equality and diversity and value the benefits this brings. It is our aim to ensure that all staff feel valued and have a fair and equitable quality of working life.

Human Rights

The Practice is committed to the principles contained in the Human Rights Act. We aim to ensure that our employment policies protect the rights and interests of our staff and ensure that they are treated in a fair, dignified and equitable way when employed at the Practice.

Information Governance

Any Practice policy which impacts on or involves the use and disclosure of personal information (patient or employee) must make reference to and ensure that the content of the policy is comparable with the relevant statutory or legal requirement and ethical standards.

Data Protection Act 2018 and the NHS Confidentiality Code of Practice

The Data Protection Act (DPA) provides a framework which governs the processing of information that identifies living individuals.

Processing includes holding, obtaining, recording, using and disclosing of information and the Act applies to all forms of media, including paper and images.

It applies to confidential patient information but is far wider in its scope, e.g. it also covers personnel records.

The DPA provides a legal gateway and timetable for the disclosure of personal information to the data subject (e.g. Health Record to a patient, personal file to an employee).

Whilst the DPA applies to both patient and employee information, the Confidentiality Code of Practice (COP) applies only to patient information.

The COP incorporates the requirements of the DPA and other relevant legislation together with the recommendations of the Caldecott report and medical ethical considerations, in some cases extending statutory requirements and provides detailed specific guidance.

This Equal Opportunities and Diversity Policy contains the following sections:

1. Introduction
2. Practice Statement
3. Recruitment and Selection
4. Employee relations
5. Zero Tolerance

Introduction

The Practice is committed to equal opportunities and to building a valued workforce whose diversity reflects our community.

Our Equality and Diversity Policy takes into account all current UK and EU legislation and guidelines, including codes of practice from the Equality and Human Rights Commission.

This Equality and Diversity Policy has been written in accordance with current best practice and has been updated in line with the Equality Act 2010.

Practice Statement

Under the Equality Act 2010, it is against the law for a company to discriminate against anyone on the grounds of colour, age, sex, race / nationality – including citizenship – ethnic or national origins, marital status, civil partnership, disability, sexual orientation, any religion, or religious or philosophical belief.

It is also possible for employees to claim for discrimination on a combination of two of these grounds. Similarly if employees discriminate against a colleague or patient, the Practice could be held vicariously liable for their acts, and be responsible for paying the compensation or damages to the victim of the discrimination.

If the Practice can prove that it has done all that was reasonable to prevent the discriminatory acts from occurring then its liability can be reduced or entirely eliminated. Having an equal opportunities policy and apprising all staff of its existence is one of the things that a reasonable employer should do.

The Practice has the following policies in place which need to be read along with this Equality and Diversity policy:

• Disability policy
• Culture & Religious policy
• Grievance Procedures
• Bullying and Harassment
• Age Discrimination
• Equal Opportunities policy
• Recruitment and Selection Policy
• Training and Development policy
• Dignity at work
• Being Open Policy
• Information Governance Policy i.e. confidentiality / consent

Recruitment and Selection

The Practice has implemented a Recruitment & Selection policy. The objective of this policy is to recruit the best person for a role and outlines the responsibilities of the recruiting managers in complying with legal and locally agreed requirements.

At every stage of the recruitment process, Managers will treat all applicants equally, showing no discrimination on the grounds of their ethnic origin or nationality, disability, gender, gender reassignment, marital status, age, sexual orientation, race, trade union activity or political or religious beliefs.

Applicants will be selected against criteria based solely on objective, job related criteria and their ability to do the job applied for. The Practice will consider providing appropriate assistance to ensure equality for all.

Relevant educational, training and development opportunities are open to all staff and all staff have a personal development plan in place, which must be reviewed annually. Information on education, training and development opportunities is widely publicised, and attendance monitored for.

Monitoring information is gathered periodically to ensure there are no inequalities in opportunities for promotion.

Employee Relations

The Practice has developed a number of ‘Employee Friendly’ Policies and also has in place Disciplinary, Dignity at Work and Grievance Policies to process employee relations issues.

As with any Practice Policy these are fair and consistent in their manner. Practice policies do not discriminate against anyone on the grounds of colour, age, sex, race / nationality – including citizenship – ethnic or national origins, marital status, civil partnership, disability, sexual orientation, any religion, or religious or philosophical belief.

Instances of harassment under any of the above are treated very seriously and are addressed under the Dignity at Work and Disciplinary Policies.

Zero Tolerance

The Practice is committed to developing and maintaining a safe and secure environment, for its patients, staff and visitors and has a duty to take all reasonable steps to protect and support its staff.

Violent and abusive behaviour includes bullying and / or harassment of any description. Violent or abusive behaviour by patients, visitors or staff is not tolerated and decisive action will be taken to protect staff, patients and visitors, including combating behaviour contrary to the principles outlined in this Policy on the grounds outlined in the Policy Statement.

All violent adverse incidents are reported, investigated and appropriate remedial action is taken. When a clinical risk/incident is reported, a risk assessment may be appropriate to identify the need for change. On-going follow up and review of progress may also be appropriate.

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

The average pay for GPs working in Sina Health Centre in the last financial year was £116,449 before tax and National Insurance.

This is for 3 full time GPs, and 1 locum GP who worked in the practice for more than six months.

How to make a complaint about primary care services is changing on 1 July 2023

From 1 July 2023 the way to make a complaint about primary care services to the commissioner is changing.

By primary care services we mean GPs, dentists, opticians or pharmacy services.

Please ensure your patients are aware of the following information via your website or other communications channels:

You have the right to make a complaint about any aspect of NHS care, treatment or service, this is written into the NHS Constitution on GOV.UK.

From 1 July 2023 the way you make a complaint about primary care services to the commissioner is changing.

By primary care services we mean GPs, dentists, opticians or pharmacy services.

There are two ways you can make a complaint:

• You can complain to the healthcare provider: this is the organisation where you received the NHS service, for example a GP surgery or dental surgery.

• You can complain to the commissioner of the service: this is the organisation that paid for the service or care you received.

After 1 July 2023 if you want to make a complaint about primary care services to the commissioner you will now contact the Black Country Integrated Care Board instead of NHS England.

You can do this by:

Telephone: 0300 0120 281

Email: bcicb.time2talk@nhs.net

Writing to us at: Time2Talk, NHS Black Country Integrated Care Board (ICB) Civic Centre, St Peter’s Square, Wolverhampton, WV1 1SH

If you want to make a complaint directly to the provider of the primary care service, you still can – that does not change on the 1 July 2023.

Ongoing complaints

If you have an ongoing complaint placed on or after 1 July 2022, you will receive a letter from NHS England informing you that the Black Country ICB is now handling your complaint, this will include confirmation of your case handler.

If you have an ongoing complaint placed before 1 July 2022, you will receive a letter from NHS England informing you that your complaint is being retained by NHS England, this will include confirmation of your case handler.

Find out more about how to feedback or make a complaint about an NHS service 

The Complaints Leaflet can be found here

Patients registered at the Surgery have a named, accountable doctor who is responsible for coordinating their care.

Your named doctor will be allocated to you by the practice.

You can still talk to or make appointments to see any of our doctors or nurses, not just your named GP.

If you have a preference and would like to request a particular doctor at the practice to be your named GP please talk to one of our receptionists.

See our practice staff

NHS Black Country ICB is responsible for buying and monitoring healthcare services on behalf of all patients in Dudley, Sandwell, Walsall and Wolverhampton.

NHS Black Country ICB,
Civic Centre,
St Peters Square,
Wolverhampton,
WV1 1SH

For further information please visit: https://blackcountry.icb.nhs.uk/contact-us

We respect your right to privacy and keep all your health information confidential and secure. It is important that the NHS keeps accurate and up-to-date records about your health and treatment so that those treating you can give you the best possible care.

This information may be used for management and audit purposes. However, it is usually only available to, and used by, those involved in your care. You have the right to know what information we hold about you. If you would like to see your records please contact the Practice Manager.

Your confidentiality is important to us

You can be sure that anything you discuss with any member of this practice – family doctor, nurse, receptionist – will stay confidential.

Even if you are under 16 nothing will be said to anyone – including parents, other family members, carer workers or tutors – without your permission. The only reason why we might want to consider passing on confidential information without your permission, would be to protect you or someone else from serious harm. We would always try to discuss this with you first.

If you are being treated elsewhere – for example at a hospital or Brook centre – it is best if you allow the doctor or nurse to inform the practice of any treatment you are receiving.

If you have any worries about confidentiality please feel free to ask a member of staff.

Rights:

• Patients aged 16 –75 who have not seen a doctor/nurse in the previous 3 years may request a health check with a HCA.
• Patients aged over 75 and have not seen a doctor/nurse in the previous 12 months may request a health check with a HCA.
• Patients have the right to see their own health records subject to limitations.

Responsibilities:

• Arrive on time for your appointments
• Inform the practice of your intention to cancel an appointment in good time.
• Show the courtesy to staff you would yourself, expect to receive.
• Violent or aggressive patients may be removed from the list and referred to a specialist service.
• All patients are entitled to have a chaperone present for any consultation, examination or procedure where they consider one is required.

For example:

• A parent or guardian who has legal responsibility for a patient under 11
• A parent or guardian where a patient aged 11 or over has given permission
• A parent or guardian who has legal responsibility for a patient between 11 and 16 where GP has assessed that the patient is not capable of making their own decisions re medical health
• A carer for a patient over the age of 16 – we would need a letter from the patient giving them permission

• The patient has been assessed as lacking capacity to make a decision on granting proxy access and/or the applicant has a lasting power of attorney for health and welfare registered with the Office of the Public Guardian,

• the applicant is acting as a Court Appointed Deputy on behalf of the patient, or
• the GP considers it to be in the patient’s interest in accordance with the Mental Capacity Act 2005 code of practice.

• The patient is a child who has been assessed as not competent to make a decision on granting proxy access

Sina Health Centre Privacy Notice

1.    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 Sina Health Centre.

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 1st January 2021 the UK has been subject to an Adequacy Agreement which allows 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 is now 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 as the Data Controller, is Sina Health Centre. 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.

2.    How we use your information and the law

Sina Health Centre. 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.

3.    Your rights over your personal information

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

a.    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.

b.    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 us via our Practice Manager or Deputy Practice Manager.

c.    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 Sina Health Centre has the correct contact details for you at all times.

d.    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.

e.    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.

f.     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.).

g.    Right to object to processing

Article 21 of UK GDPR gives you 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.

h.    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.

4.    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 Practice has had with you, such as appointments, clinic visits, and 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.

5.    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.

6.    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.

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.

7.    Population Health Management

Population Health Management improves population health by data driven planning and delivery of proactive care to achieve maximum impact. It includes segmentation, stratification and impactability modelling to identify local ‘at risk’ cohorts – and, in turn, designing and targeting interventions to prevent ill-health and to improve care and support for people with ongoing health conditions and reducing unwarranted variations in outcomes.

The benefits of Population Health Management are:

·            Using data-driven insights and evidence of best practice to inform target interventions to improve the health & wellbeing of specific populations & cohorts

·            The wider determinants of health, not just health & care

·            Making informed judgements, not just relying on the analytics

·            Prioritising the use of collective resources to have the best impact

·            Acting together – the NHS, local authorities, public services, the VCS, communities, activists & local people. Creating partnerships of equals

·            Achieving practical tangible improvements for people & communities

Information about you is collected from several sources including NHS Trusts and from this GP Practice. The identifying parts of your data are removed, and an analysis of your data is undertaken. This analysis may be undertaken by external organisations who are acting on behalf of your GP Practice and have a Data Processing contract with the Practice. This is then provided back to your GP as data controller in an identifiable form.  As a result of population health management, your GP may be able to offer you additional services.

8.    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 Integrated Care Board’s Medicines Management Team under a Data Processing contract with the Practice.

9.    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.

10.  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…’

10.1 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.

10.2 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.

10.3 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).

11. 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, for full details on CRPD please visit www.cprd.com/transparency-information

12. General Practice Data for Planning and Research

The Government is delaying the implementation of the General Practice Data for Planning and Research (GP DPR) programme until four key areas of work are strengthened:

·            the ability for patients to opt out, or back in, to sharing their GP data with NHS Digital, with data being deleted even if it has been uploaded previously

·            the backlog of opt-outs has been fully cleared

·            a Trusted Research Environment (TRE) is available where approved researchers can work securely on de-identified patient data which does not leave the environment

·            a campaign of engagement and communication has increased public awareness of the programme, explaining how data is used and patient choices

This delay will also provide more time to speak with patients, doctors, health charities and others.

This Privacy Notice will be updated when further details of the proposed implementation have been confirmed.

For further information please refer to NHS Digitals webpage on this subject matter

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.

13. 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.

13.1 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 completing our Type 1 Opt-out preference form. If you do intend to opt out of the GP DPR we will update this Privacy Notice with the date by which you must provide your opt-out by 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 do this at any time. You can send the form by post or email to us at the Practice or call 01922 710027 for a form to be sent out to you.

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.

13.2 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.

There is an intention for the National Data Opt-out to apply to any confidential patient information shared by the GP practice with other organisations for purposes except your individual care. This means it will replace the Type-1 Opt-out. If this happens, patients who have registered a Type 1 Opt-out will be informed. Please note that the National Data Opt-out will not apply to confidential patient information 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.

You can also set your opt-out preferences via the NHS App if you are registered to use this application.

13.3 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 states 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:

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.

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.

14. 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.

15. 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 Sina Health Centre 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 practice in writing if you wish to withdraw your consent.  In 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 Practice 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.

16. 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.

17. 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.

All patient data is held in NHS Approved Data Centres. For example, EMIS Web (our clinical system) hold your data in an AWS data warehouse.

18. 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 (ICS)

·            Integrated Care Board (ICB)

·            Integrated Care Partnerships (ICPs)

·            NHS Commissioning Support Units

·            Independent Contractors such as dentists, opticians, pharmacists

·            Private Sector Providers

·            Voluntary Sector Providers

·            Ambulance Trusts

·            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.

19. Invoice Validation

If you have received treatment within the NHS, access to your personal information may be required to determine which Integrated Care Board should pay for the treatment or procedure you have received.

This information would most likely include information such as your name, address, NHS number, date of treatment and may be passed on to enable the billing process. These details are held in a secure environment and kept confidential. This information will only be used to validate invoices and will not be shared for any further purposes.

20. NHS Health Checks

All of our patients aged 40-74 not previously diagnosed with cardiovascular disease are eligible to be invited for an NHS Health Check. Nobody outside the healthcare team in the Practice will see confidential information about you during the invitation process and only contact details would be securely transferred to a data processor (if that method was employed). You may be ‘given the chance to attend your health check either within the practice or at a community venue. If your health check is at a community venue all data collected will be securely transferred back into the practice system and nobody outside the healthcare team in the practice will see confidential information about you during this process.

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.

21. 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 have a right to object 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 Sina Health Centre 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.

22. 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 2021

22.1 Destruction of records/information

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 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.

23. 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.

Sina Health Centre is a member of the West 2 PCN which includes the following local GP Practices:

·         Darlaston Medical Centre

·         Lockfield Surgery

·         Lockstown Practice

·         Moxley Medical Centre

·         Rough Hay Surgery

24. 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 Practice 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/email 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.

25. 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.

26. Objections/Complaints

Should you have any concerns about how your information is managed or wish to object to any of the data collection at the Practice, please contact the Practice Manager or your healthcare professional to discuss how the disclosure of your personal information can be restricted. All patients have the right to change their minds and reverse a previous decision. Please contact the Practice if you change your mind regarding any previous choice.

If you would like to make a ‘data subject access request’ please contact the practice in writing. We will endeavour to respond to your request within one calendar month or two months if the request is complex.

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

Suspected breaches in data protection can be reported to the Practice Data Protection Officer, Michelle K Wiles, bcicb.dpo@nhs.net. Breaches in data protection will result in an incident investigation. Serious breaches will be reported to the Information Commissioners Office (ICO).

It is the responsibility of all employees of the Practice to report suspected breaches of information security to the Practice Manager and Data Protection Officer without delay.

The Practice is registered as a data controller with the ICO. The registration number is Z7018377 and can be viewed online in the public register or by contacting the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

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 R Mohan

Caldicott Guardian: Dr R Mohan

Data Protection Officer: Michelle Wiles, Information Governance Manager – Black Country

27. Useful Links

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

·            Information Commissioners Office

·            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

·            Records Management Code of Practice

The NHS operate a zero tolerance policy with regard to violence and abuse and the practice has the right to remove violent patients from the list with immediate effect in order to safeguard practice staff, patients and other persons.

Violence in this context includes actual or threatened physical violence or verbal abuse which leads to fear for a person’s safety. In this situation we will notify the patient in writing of their removal from the list and record in the patient’s medical records the fact of the removal and the circumstances leading to it.