Privacy Notice Temple Hill Group
Fair Processing Notice under the Data Protection Act 2018
- How we use your personal information
This fair processing notice explains why the GP practice collects information about you and how that information may be used.
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology solutions to ensure that your information is kept confidential and secure. Records which this Practice hold about you may include the following information:
- Details about you, such as your address, carer, legal representative, emergency contact details, next of kin
- Any contact the surgery has had with you, such as appointments, telephone calls and information/photographs submitted by you, etc.
- 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
To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided. 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 – if this information needs to be identifiable, the surgery will always gain your explicit consent before releasing the information for this purpose.
Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your anonymised information using software managed by our clinical system provider, and is only 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.
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. This service is provided by pharmacists and Technicians employed by Kent & Medway Clinical Commissioning Group. They are bound by the same confidentiality rules as our staff.
Health and care professionals provide care as a local team. This means that the right people can work together to ensure your care is planned and coordinated. They work within strict rules and focus on getting the best outcomes for their patients. They are ethically accountable to their professional bodies for their actions, including on what is appropriate to share and when. Sharing is subject to strict written agreements and/or contracts on how it will be used with tight controls to maintain confidentiality and security.
The Hub is an organisation which operates across Dartford Gravesham & Swanley and is run by the DGS Federation. It offers extended access appointments with a GP. It operates from Temple Hill Surgery. By booking an appointment with The Hub, patients are explicitly consenting to The Hub staff accessing their medical records to provide medical care.
- Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm.
- These circumstances are rare.
- We do not need your consent or agreement to do this
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:
- General Data Protection Regulations 2018 (formerly Data Protection Act 1998)
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality, Information Security and Records Management
Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. Any visitor to the premises who will or could be exposed to your identifiable information will sign a confidentiality agreement.
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 new 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. They should be supported by the policies of their employers, regulators and professional bodies.
Who are our partner organisations?
- NHS Trusts / Foundation Trusts
- 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
- Health and Social Care Information Centre (HSCIC)
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Voluntary Sector Providers
- Private Sector Providers
Access to personal information / Subject Access Requests
You have a right under the General Data Protection Regulations 2018 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. In order to request this, you need to do the following:
- Your request must be made in writing to the GP, this can be made by email or letter (note for information from the hospital you should write direct to them)
- We will initially offer you online access to your Detailed Coded Record. This contains your electronic medical record, and summarised paper record. It does not contain any letters from the hospitals or other attachments on your record. The advantage of applying for access to this record is that is updates as your medical record updates, so you will always have the most current information.
- If the Detailed Coded Record is not adequate for your needs, we will email you a copy of your medical record. If you are not able to receive an email containing your medical record, you will print a copy for you. There may be a charge to have a printed copy of the information held about you if the administrative burden of photocopying and printing is excessive.
- We are required to respond to you within 20 days
- 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
GP medical records will be kept in line with the law and national guidance. Information on how long records are kept can found at:
Objections / Complaints
Should you have any concerns about how your information is managed at the GP Practice, please contact the Practice Manager by email gp.G82647@nhs.net , telephone 01322 226090 or letter. If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) www.ico.gov.uk, https://ico.org.uk/global/contact-us/ or telephone: 0303 123 1113.
If you are happy for your data to be extracted and 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 we get from other organisations
We receive information about your health from other organisations who are involved in providing you with health and social care. For example, if you go to hospital for treatment or an operation the hospital will send us a letter to let us know what happens. This means your GP medical record is kept up to date when you receive care from other parts of the health service.
Change of Details
It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.
The General Data Protection Regulations 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.
This information is publicly available on the Information Commissioners Office website www.ico.org.uk
The practice is registered with the Information Commissioners Office (ICO) Registration Number: Z2437310.
As your registered GP practice, we are the data controller for any personal data that we hold about you.
Any changes to this notice will be published on our website and displayed in prominent notices in the surgery.
Our organisation is registered as a data controller with the Information Commissioners Office.
Data Protection Officer
As a public authority, we have to appoint a Data Protection Officer (DPO) who assists us in monitoring internal compliance, provides advice regarding Data Protection Impact Assessments (DPIAs), and helps us demonstrate compliance with an enhanced focus on accountability.
Data Controller contact details: Temple Hill Group (Jointly with NHS Digital for the National Health Service) c/o Mrs R Woodyard Practice Manager, Temple Hill Surgery, St Edmunds Road, Dartford, DA1 5ND. Tel: 01322 226090
Purpose of Processing
- To give direct health or social care to individual patients
- For example, when a patient agrees to a referral for direct care, such as to a hospital, relevant information about the patient will be shared with the other healthcare staff to enable them to give appropriate advice, investigations, treatments and/or care
- To check and review the quality of care (This is called audit and clinical governance).
Rights to object and the national data opt-out
You have a right to object under the GDPR and the right to ‘opt-out’ under the national data opt-out model. The national data opt-out model provides an easy way for you to opt-out of:
- Information that identifies you being used or shared for medical research purposes and quality checking or audit purposes.
Information about your health and care helps us to improve your individual care, speed up diagnosis, plan your local services and research new treatments.
In May 2018, the strict rules about how this data can and cannot be used were strengthened. The NHS is committed to keeping patient information safe and always being clear about how it is used.
You can choose whether your confidential patient information is used for research and planning.
To find out more visit: nhs.uk/your-nhs-data-matters
Who are our partner software suppliers / businesses?
We use a number of pieces of software and organisations outside of the NHS to facilitate your healthcare and enable our staff to contact you. These are as follows:
Clinical system holds patient demographic and medical information – remote server
The servers and the connection to the practice are encrypted, so EMIS staff are not able to access patient information in this way. EMIS support staff are able to dial in remotely with the consent of our staff for problem solving.
Individual Text and Video messaging system between the practice and patients.
They transmit and store data in encrypted form. This means nobody else can read it without the right credentials. When stored, your data is encrypted in an extremely secure UK-based Microsoft Azure data centre.
They meet the highest standards of safety and security, as set by NHS bodies and the government. We go through assurance processes for these and we regularly get outside independent experts to check our systems are secure. You can see a list of our security credentials in our Resource Centre.
Clinical software which holds patient letters and documents.
Docman support staff can remotely dial in with the consent of our staff for problem solving.
Dictation software which clinical staff use to dictate letters for the secretaries to type.
Olympus support staff are able to dial in remotely with the consent of our staff for problem solving.
MDU / MDDUS
We will sometimes send by email or discuss by phone identifiable information when the organisation is supporting a GP in a patient complaint or litigation. Information will be redacted where possible.
Numed provides software and support for our ECG machines.
Numed support staff can remotely dial in with the consent of our staff for problem solving.
Manage recall and screening of diabetic patients for diabetic retinopathy
The Diabetic Eye Screening Programme is operated by Health Intelligence (commissioned by NHS England). This supports invitation for eye screening and ongoing care. This data may be shared with any Hospital Eye Services a patient is under the care of to support further treatment and with other healthcare professionals involved in patient care.
Provision of GP Clinical System Templates
Support the delivery of NHS Health Checks
Edenbridge Healthcare APEX
Clinical System Reporting
Long-term condition prevalence
DXS Point of Care
Support Clinical System for Care Pathways
Electronic Ordering Communication Management
Electronic Test Requests and Results