a.      Direct Medical Care and Administration

NHS Trusts – Hospitals, Community or Mental Health Trusts.

Other care providers with NHS contracts (e.g. services providing ultrasound scans, medical imaging; specialist providers such as those providing day surgery, other direct care tests / services)

Personal data concerning your GP medical record may be shared with NHS Trusts in order to enable their healthcare professionals make the best informed decision about your health needs, and provide you with the best possible care if you visit these providers for routine care and referrals.

Your information will also be shared with other care providers to provide best care, for example for medical imaging tests the practice cannot perform itself.

Note that NHS contracts are commonly delivered by private organisations; some of these providers will be partnerships, companies and other bodies, along with statutory NHS bodies such as NHS Trusts.

Your personal information may also be processed for local administrative purposes such as:

·    Waiting list management;

·    local clinical audit;

·    Performance against local targets;

·    activity monitoring;

·    production of datasets to submit for commissioning purposes and national collections.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Emergency Services (Ambulance trusts, police, A&E departments, out of hours services, 111)

There are circumstances when intervention is necessary in order to save or protect a patient’s life or to prevent them from serious immediate harm, for example, during a collapse or diabetic coma or serious injury or accident. In many of these circumstances the patient may be unconscious or too ill to communicate.

Medical professionals have a duty of care to share data in emergencies to protect their patients or other persons. In these circumstances, your GP medical record will be shared with emergency healthcare services, the police or fire service in order to enable you receive the best treatment or service.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (d) – the processing is necessary in order to protect the vital interests of the data subject;

Article 9 (2) (C) – the processing is necessary to protect the vital interests of the data subject

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      Make pre-determined decisions about the type and extent of care you will receive in an emergency, these are known as “Advance Directives” and are held in Urgent Care Plans;

·      access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have the right to object to some or all of your personal information being shared with the recipients. You also have the right to have an “Advance Directive” placed in your records and brought to the attention of relevant healthcare workers or staff.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

GP Federations and Primary Care Networks

(groups of Practices working together, and with other providers, to provide joined-up and effective care)

North Central London Integrated Care Service

GP Federations are groups of GPs (patient centred organisation), working collaboratively and developing closer integration with other partners across health, social and third sector partners to facilitate an enhanced delivery of health and care services.

Primary Care Networks (PCNs) are similar, but are led at the GP level and may involve a variety of other organisations also noted in this privacy notice.

North Central London Integrated Care Service are a wider grouping performing shared functions across health and care.

In each case the Practice remains the data controller for the information about you.

Through various hubs in the community the GP Federations and PCNs provide direct health and care services such as continued extended access, home visits, universal offers, musculoskeletal service, GP at front door and other neighbourhood services across North Central London (which covers the boroughs of Barnet, Camden, Enfield, Haringey and Islington)

If you visit receive treatment/consultation on any of these services, personal data concerning your GP medical record may be shared with the GP Federation and Multidisciplinary Teams (MDT) in order to enable them make the best informed decision about your health/care needs, and provide you with the best possible care.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Pharmacists

Medicines Optimisation

Delivery of direct care e.g. vaccination, prescription fulfilment.

Medicines optimisation looks at the value which medicines deliver, making sure they are clinically-effective and cost-effective. It is about ensuring patients get the right choice of medicines, at the right time, and are engaged in the process by their clinical team.

Medicines optimisation enables community pharmacies to request medication electronically from the Practice and view relevant information from your GP record in order to provide you with the best medicines.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Local Authority – Social Services

The practice works closely with Local Authorities to support and care for people of all ages to deliver the best possible social care.

Personal data concerning your GP medical record may be shared with Local Authorities and Multidisciplinary Teams (MDTs) delivering social care in order to enable them make the best informed decision about your social care needs if required.

The source of the information shared in this way is your electronic GP record and your Local Authority social care records. Your GP is the data controller for your electronic GP record, your local authority is the data controller for your social care record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (d) (processing for vital interests of data subject) and/or;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Multidisciplinary Care Teams and clinics (MDTs)

Personal data concerning your GP medical record may be shared with clinics delivering care or Multidisciplinary Teams (MDTs) in the area in order to provide you with the best possible care. For example, if you suffer from a long-term condition, specialist MDTs may deliver services alongside your GP. These MDTs commonly run clinics for conditions, so that you can receive the best possible care from practitioners specialising in the treatment area.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Care Homes

Personal data concerning your GP medical record may be shared with Care Homes delivering your care in order to enable their care professionals make the best informed decision about your care needs, and provide you with the best possible care if you are resident in a Care Home.

Note that many care homes are private sector organisations.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

The NHS Account and the NHS App

The NHS Account and the NHS App is available to all patients over 13 years of age registered with a GP in England. Details are available online from

https://www.nhs.uk/nhs-app/

The purpose of the processing is to allow you to access NHS services more easily, to be able to see information about your health and care. The app includes a wide range of services which vary with each provider.

You need to have verified your NHS account to access all the services on the NHS account and app; some services are available without full verification.

If you are an NHS App user, we use the NHS Account Messaging Service provided by NHS England to send you messages relating to your health and care.

The data controller for data on the NHS app depends on the use and provider. Full details can be found at

https://www.nhs.uk/nhs-app/nhs-app-legal-and-cookies/nhs-app-privacy-policy/privacy-policy/

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the appropriate data controller or DPO and your request will be carefully considered. Note that the practice is data controller only for its data on the NHS app, not for that of other organisations, nor for the account or the app itself..

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

b.     Other primary care services delivered for the purposes of direct care

Integrated Urgent Care Service (IUC) - covering Out of Hours and NHS 111 service

Integrated Urgent Care Service (IUC) is an urgent care service delivered across North Central London (NCL) (Barnet, Camden, Enfield, Haringey and Islington) for the provision of a functionally integrated 24/7 urgent care access, clinical advice and treatment service for patients. IUC incorporates NHS 111 and Out of Hours (OOH) services, which is often referred to as an IUC Clinical Assessment Service.

The purpose of IUC is to ensure that patients receive the best possible healthcare service in their community.

If you visit the urgent care centre or call NHS 111 for health related needs, personal data in your GP record will be shared with healthcare professionals in order to enable them make the best the best informed decision about your health needs.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Continuing Health Care (CHC)

NHS Continuing Health Care (CHC) is free care outside of hospital that is arranged and funded by the NHS to support living with complex medical conditions and on-going healthcare needs which can be delivered in the patient’s home, at their care home or in non-acute hospitals.

CHC is free, unlike support from social services for which a fee may be charged, depending on your income and savings. CHC is different from NHS Funded Nursing Care, which some people with less complex needs living in care homes receive.

If you require CHC needs personal data concerning your GP medical record will be shared with the care home or in non-acute hospitals looking after you.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Data Protection Act 2018 Section 10

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Online Consultation Provider is FOOTFALL

Footfall provides a service where patients can register with a GP, book appointments, have online consultations and communicate with your GP. Your consent is required to use the system, but information provided will, with your consent, be provided to your GP and become part of the medical record.

PATCHES allows you to provide symptoms so it can signpost you to the most appropriate service using artifical intelligence (AI Triage)

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

PATCHES have a separate privacy notice for their activity as a data controller https://patchs.ai/privacypatients/privacy-policy

Article 6 1(a) – consent of the data subject

Article 9 2(a) – informed consent

[Once data is passed to the GP, it is treated as part of the patient record – please see the patient record system.

You have the right to:

·      To withdraw your consent to this processing – this has the same effect as right to object;

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data – as this is consent based we will immediately arrange for your data to be removed from all those organisations it has been shared with.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Online Consultation Provider – FOOTFALL

FOOTFALL provides a service where patients can complete a set of online forms which will then refer them to their GP or other services to ensure the correct treatment can be accessed as quickly as practicable.

eConsult forward information to the practice where you give consent to do so; they are a data controller for your data until it is forwarded to the practice, at which point the practice is data controller for the information provided.

eConsult is a nationally available contract to GPs.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

eConsult have a separate privacy notice for their activity as a data controller https://econsult.net/nhs-patients/privacy-policy

Article 6 1(a) – consent of the data subject

Article 9 2(a) – informed consent

[Once data is passed to the GP, it is treated as part of the patient record – please see the patient record system.]

You have the right to:

·      To withdraw your consent to this processing – this has the same effect as right to object;

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data – as this is consent based we will immediately arrange for your data to be removed from all those organisations it has been shared with.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Voluntary sector, Resilience networks and Social Prescribing

GP services can only be a part of care, and commonly voluntary/3rd sector organisations can help with conditions by providing support and other services. Where these may be helpful, we will, with your informed consent, share with these organisations to help you

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6 1(a) – consent of the data subject

Article 9 2(a) – explicit consent

You have the right to:

·      To withdraw your consent to this processing – this has the same effect as right to object;

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data – as this is consent based we will immediately arrange for your data to be removed from all those organisations it has been shared with.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Weight Management Coaching Provider

MoreLife

Where a change in behaviour is needed to improve health, app and coaching services can help. GPs can refer to providers who have these services, with your informed consent to share. Patients can also self-refer if they meet the requirements for the Intervention.

MoreLife provide these services to patients in some areas of North Central London

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6 1(a) – consent of the data subject

Article 9 2(a) – explicit consent

You have the right to:

·      To withdraw your consent to this processing – this has the same effect as right to object;

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data – as this is consent based we will immediately arrange for your data to be removed from all those organisations it has been shared with.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

c.      Statutory Disclosures of Information

Safeguarding Concerns – to prevent an individual, or to prevent a serious crime

Some members of public are recognised as needing safeguarding protection, for example children and vulnerable adults. If an individual is identified as being at risk from harm, we have a duty to do what we can to protect that individual, and we are bound ‘Safeguarding’ laws to do so.

Where there is a suspected or actual safeguarding issue we will share information that we hold about you with other relevant agencies such as local Ambulance trusts, the police, A&E departments, out of hours services, 111 or Social Services)

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (d) – the processing is necessary in order to protect the vital interests of the data subject 

Article 9 (2) (C) – the processing is necessary to protect the vital interests of the data subject;

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Related Legislation:

Data Protection Act 2018 Section 10 (in particular the provisions under Schedule 2 Part 1 Section 18 relating to safeguarding)

Section 47 of The Children Act 1989.

Section 45 of the Care Act 2014

This sharing is a legal and professional requirement and therefore there is no right to object.

The Children Act 1989 requires local authorities to investigate where a child is the subject of an emergency protection order, is in police protection or where there is a reasonable cause to suspect that a child is suffering or is likely to suffer harm.

The Act requires the local authority to safeguard and promote the welfare of children who are in need, within their geographical area and to request help from specified authorities including General Practices, NHS Trusts, Integrated Care Systems / Boards (ICSes / ICBs – formerly CCGs) and NHS England.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

The Care Quality Commission (CQC)

The Care Quality Commission (CQC) is a regulatory body established under the Health and Social Care Act. The CQC regulates health and social care services in England to ensure that safe health and care are provided. The law allows CQC to access identifiable patient data/medical records in our clinical system for the purposes of their assessment and investigation of significant safety incident.

The data will be shared with the Care Quality Commission, its officers and staff and members of the inspection teams that visit us from time to time.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

Data Protection Act 2018 Section 10

The Health and Social Care Act 2008, s64

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Law Enforcement and Regulatory Bodies

In some circumstances the Practice may be legally required to share personal information with law enforcements and regulatory bodies (without the consent of the data subject) such as: the Police; Courts of Justice; HMRC and DVLA for the purposes of prevention or detection of crime; apprehension or prosecution of offenders; the assessment or collection of any tax or duty or, of any imposition of a similar nature.

GPs are obliged to notify the DVLA when fitness to drive requires notification but an individual cannot or will not notify the DVLA themselves, and if there is concern for road safety, which would be for both the individual and the wider public.

The Practice will review each request based on its merits before deciding whether to release information to the ‘relevant authorities’.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (G) – the processing is necessary for reasons of substantial public interest

Related Legislation:

There are a variety of acts which place responsibilities on health providers to provide information for law enforcement and regulatory bodies.

This sharing is a legal and professional requirement and therefore there is no right to object. Personal data processed these purposes are exempt the first data protection principle (processed lawfully, fairly and in a transparent manner).

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Medical Examiner Service

When a person dies, all death are now reviewed by the medical examiner service. We are required to share information about the deceased’s medical record with the examiner. This record may contain information regarding the living – for example, family members, persons who treated the deceased. Data is reviewed only by persons under a professional duty of confidence as part of the medical examiner service.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Additionally, as the sharing is mandated for improvement of health and care

Article 6(1)(e) ‘…for the performance of a task carried out in the public interest or in the exercise of official authority…’

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.

Additionally, as the sharing is intended to improve health and care

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation

The National Health Service Trust (Scrutiny of Deaths) (England) Order 2021

This sharing is a legal and professional requirement and therefore there is no right to object.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Medico-Legal

Medico-Legal - Where a medical professional is holding personal data for the purpose of providing medical reports in connection with legal action.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

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

Art.18 (2): Processing for the establishment, exercise or defence of legal claims.

This sharing is a legal and professional requirement and therefore there is no right to object.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

General Medical Council (GMC)

General Medical Council (GMC) is a public body that maintains the official register of medical practitioners within the United Kingdom. Its primary responsibility is ‘to protect, promote and maintain the health and safety of the public’ by controlling entry to the register, and suspending or removing members when necessary.

Under the Medical Act 1983, the GMC has the power to request access to a patient’s medical records for the purposes of an investigation into a doctor’s fitness to practise.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (c) - processing for legal obligation;

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

The Medical Act 1983

Data Protection Act 2018 Section 10

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

The Health Service Ombudsman (HSO)

The Health Service Ombudsman (HSO) was set up by Parliament to provide an independent complaint handling service for complaints that have not been resolved by the NHS in England and UK government departments.

The HSO has the power to request access to a patient’s medical records for the purpose of an investigation.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

The Health Services Commissioners Act 1993,s12

Data Protection Act 2018 Section 10

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

NHS Counter Fraud

Under the NHS Act 2006, investigations into fraud in the NHS may require access to confidential patient information.

This means that we are compelled by the law to share your data.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

s10 NHS Act 2006

This sharing is for a legal obligation and hence the rights to access, object or restrict processing are limited.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

NHS England Transformation Directorate (formerly NHS Digital )

Transformation Directorate of NHS England, previously known as NHS Digital, and previously the Health and Social Care Information Centre) is a national information and technology partner to the health and social care system. NHS Digital use digital technology to transform the NHS and social care.

NHS Digital carries out National Data collections/ extraction from the GP record. These include:

General Practice Extraction Service (GPES)

This is an extraction of much of your GP data for use by the NHS centrally for planning and research. It is controlled by NHS Digital and is a statutory requirement upon your GP under sections 259(1)(a) and 259(5) of the Health and Social Care Act 2012.

Further details for patients are provided at https://digital.nhs.uk/data-and-information/data-collections-and-data-sets/data-collections/general-practice-data-for-planning-and-research.

National Diabetes Audit (NDA) - A national monitoring system, auditing the care of patients with diabetes. The data extracted for the purpose of NDA includes NHS Number, date of birth and postcode, as well as clinical parameters related to diabetes. NDA is a mandatory data extraction under section 254 of the Health and Social Care Act 2012, this means that we are compelled by law to share your data

National Obesity Audit (NOA) – A national monitoring system auditing patient journey for weight management. The data extracted includes NHS number, date of birth, postcode, sex, ethnicity, Body Mass Index (BMI), obesity related co-morbidities, healthcare interventions such as weight loss advice and bariatric surgery. The NOA is a mandatory data extraction under 254 of the Health and Social Care Act 2012, this means that we are compelled by law to share your data. You can see their full privacy notice at https://digital.nhs.uk/data-and-information/clinical-audits-and-registries/national-obesity-audit/transparency-notice

Individual GP Level Data (IGPLD) - A national monitoring system to enable NHS Digital to provide GPs with clinical information on the care provision for their patients. The data extracted includes the NHS number. IGPLD is a mandatory data extraction under 254 of the Health and Social Care Act 2012, this means that we are compelled by law to share your data

FGM - NHS Digital collects data on FGM within the NHS in England on behalf of the Department of Health (DH). Data collected is used to produce information that helps improve NHS and local authorities to improve on how they support women and girls who have had or, who are at risk of FGM.

FGM Enhanced Dataset is a mandatory data extraction under section 254 of the Health and Social Care Act 2012, this means that we are compelled by law to share your data when required.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

S254 of the Health and Social Care Act 2012

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You do not have the right to object as the sharing is a legal and professional requirement under the law.

Whilst there is no right to object under 6(1)(c), NHS Digital respects Type 1 objections (9Nu0) present in the GP record and no data will be extracted and uploaded if so.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

NHS England

NHS England is responsible for securing, planning, designing and paying for Primary Care & Specialised NHS services not otherwise funded by North Central London Integrated Care Board. This includes planned and emergency hospital care, mental health, rehabilitation, community and primary medical care (GP) services.

We may often share personal information with NHS England potentially for safeguarding concerns that need escalating beyond our borough.

Where required the Practice may also have to share staff personal information with NHS England for the purpose of allegations framework or performers list.

The source of the information that may be shared in this instance are in the staff record and patient’s electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You do not have the right to object as the sharing is a legal and professional requirement under the law.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Local Authority Public Health

UK Health Security Agency

Office for Health Improvement and Disparities

(formerly Public Health England)

[Public Health England was replaced with two bodies during 2023]

All local authorities have public health departments with whom we are required to share certain information via various laws and regulations. Your information will be shared for this purpose with the local authority for your area of residence where required by the law.

The UK Health Security Agency (UKHSA) is responsible for protecting every member of every community from the impact of infectious diseases, chemical, biological, radiological and nuclear incidents and other health threats.

The Office for Health Improvement and Disparities is focused focus on improving the nation’s health so that everyone can expect to live more of life in good health, and on levelling up health disparities to break the link between background and prospects for a healthy life.

We are required by law to share information with these two bodies, although most information is shared with them via the link to the local authority.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 9(2) (b) – processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices.

Related Legislation:

The Health Protection (Notification) Regulations 2010 (SI 2010/659);

The Health Protection (Local Authority Powers);

Regulations 2010 (SI 2010/657)

Data Protection Act 2018 Section 10

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with the recipient.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

d.     Processing for the Purposes of Commissioning, Planning, Research and Risk Stratification

Integrated Care Systems / Boards (ICSes / ICBs)

Formerly known as Clinical Commissioning Groups CCG (s)

Integrated Care Boards (ICBs) are responsible for securing, planning, designing and paying for your NHS services, including planned and emergency hospital care, mental health, rehabilitation, community and primary medical care (GP) services. This is known as ‘Commissioning’. We are part of the North Central London (NCL) Integrated Care System (ICS) responsible for delivery of services.

In order to enable North Central London ICB carry out its statutory responsibilities effectively, efficiently and safely, we may share personal data about you with the ICB for the following purposes:

Individual Funding Requests;

Continuing Health Care;

appeals, queries or compliments; safeguarding concerns;

commissioning purposes such as payment for target achievement known as Quality and Outcomes Framework (QOF); and where the Practice is participating in agreed national or local enhanced services.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with the recipient.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

“Risk Stratification" (Population Health Management and Case Finding)

Direct Care

Recipient: Cerner - HealtheIntent / HealtheRegistries

Secondary Use

Recipient: NCL ICS

The Practice performs computerised searches of some or all of our records to identify individuals who may be at increased risk of certain conditions or diagnoses (e.g. diabetes, heart disease, risk of falling). Your records may be amongst those searched. This is often called “risk stratification” or “case finding”. These searches are sometimes carried out by Data Processors who link our records to other records that they access, such as hospital attendance records and national data sets. The results of these searches and assessment may then be shared with other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.

Risk stratification can be grouped into two purposes namely:

Direct Care – ‘Case Finding’ where carried out by a health professional (e.g. GPs and Provider) involved in an individual’s care or by a data processor acting under contract with such a provider, it is treated as direct care. This includes reviewing and checking on service outcomes by the health professionals involved in care. This is performed in HealtheIntent and has an objection (opt-out) you can exercise along with the London Care Record.

Secondary Use - understand the local population needs and plan for future requirement. Your identifiable personal data is used to create the data sets for this purpose, but no identifiable data is available to the persons performing indirect care tasks. This use is authorised by the Secretary of State via the Confidentiality Advisory Group (CAG).

You can object (opt-out) from this use at the ICS Website or with a form from your GP

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

Section 251B Health and Social Care Act 2012

Section 251 NHS Act 2006

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object or opt-out: You have the right to raise an objection to your personal data being shared in HealtheIntent or use for risk stratification. You also have the right opt out of HealtheIntent by completing an opt-out form with your Practice or online as below. Although we will first need to explain how this may affect the care you receive. Opting out of HealtheIntent includes opting out of the London Care Record.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

You can also opt-out of the London Care Record and HealtheIntent via the form available online at https://nclhealthandcare.org.uk/our-working-areas/using-digital-technology-to-improve-health-and-care/info-residents/opting-out-of-the-joined-up-health-and-care-record/

You can also opt-out of the Local Secondary Use via the form available online at https://nclhealthandcare.org.uk/your-health-and-care-data-can-help-improve-services/

You have the right to object to the sharing of your personal health data concerning your GP for the indirect care (planning) purposes. This is exercised via the National Data Opt-out; see the NHS Your Data Matters page. If you exercise this right, your data will no longer be supplied for the purpose. This covers the Local Secondary Use as well as national use.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Prescribing Improvement and alerting

Recipient:

First Databank UK

Optum

The Practice when prescribing passed pseudonomised data to prescribing improvement and alerting services to ensure that healthcare workers provide the most appropriate treatments and therapies. This allows the NHS to reduce cost and improve patient safety.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

Section 251 NHS Act 2006

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with the recipient.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Nutrition improvement

Recipient:

Oviva UK Ltd (Paediatric Cow's milk allergy)

Oviva UK Ltd (Adult Oral Nutritiopn Support)

Oviva UK Ltd (Diabetes Remission Services, commonly referred to as Type 2 Diabetes to Remission [T2DR] or Low Calorie Diet [LCD])

If your child has a cow’s milk allergy, or you are an adult patient with certain nutrition difficulties, Oviva UK will be used as a subprocessor to provide assistance for the condition.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

Section 251 NHS Act 2006

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with the recipient.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Research partners using pseudonymised patient data

The practice supplies pseudonymised data to organisations such as Clinical Practice Research Datalink (CPRD), for the purposes of performing research without using directly identifiable data. Data is matched before being provided with data from other sources (e.g. acute settings) and stored for research analysis. Researchers then approach the organisation for data extracts for research; for example, research using CPRD data and services has resulted in over 3,000 peer-reviewed publications investigating drug safety, health care delivery and disease risk factors. Researchers have to obtain a Research Ethics Committee (REC) approval, and, where necessary, a Confidentiality Advisory Group Approval (CAG) approval before being given access tom data.

This data cannot be used to directly identify you without special measures; these are only authorised where they would be a risk to patient safety. As you cannot be directly identified, it is not possible to make rights requests on this data; it is excluded from the requirements of Articles 15-22.

This vital research informs clinical guidance and every day best practice such as demonstrating the safety of the MMR vaccine and the protective effects of the pertussis vaccine in pregnancy on infant health.

You have the right to object to the sharing of your personal health data concerning your GP medical for research purposes. This is exercised via the National Data Opt-out; see the NHS Your Data Matters page. If you exercise this right, your data will no longer be supplied for the purpose.

The pseudonymised data is retained indefinitely for longitudinal studies.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (j) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on domestic law

You have the right to:

Right to object: You have a general right to raise an objection to your personal data being shared with the recipient.

This is managed via the National Data Opt-out, see the NHS Your Data Matters page

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Research Partners using patient identifiable data

The practice participates projects and will only agree to do so if there is an agreed clearly defined reason for the research that is likely to benefit healthcare and patients. Such proposals will normally have a consent process, ethics committee approval, and will be in line with the principles of Article 89(1) of UK GDPR.

Research organisations do not usually approach patients directly but will ask us to make contact with suitable patients to seek their consent. Occasionally research can be authorised under law without the need to obtain consent. This is known as the Section 251 arrangement, however this generally falls into the pseudonymised data permissions noted above.

We may also use your medical records to carry out research within the practice.

The individual organisations involved will notify you via the consent process of their processing.

The source of the information shared in this way is your electronic GP record.

Many of these research processes are guided and assisted by Noclor NHS Research Office

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (j) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on domestic law

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with the recipient.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Employment Processing

The Practice ensures the protection of the rights and freedoms in respect of the processing of its   employees’ personal data, in particular for the purposes of the recruitment, obligations performance contract of employment, rights and benefits management planning, health and safety, equality and diversity in the workplace, health and safety at work.

The Practice ensures that personal data it collects from employees are used only for employment related purposes or where there is a statutory obligation to share the personal information with to regulatory bodies (e.g. courts, police or NHS England).

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

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

Employees have the right to:

·      To access, view or request copies of their personal information held by the Practice;

·      request rectification of any inaccuracy to their personal information;

·      restrict the processing of their personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: Employees have a general right to raise an objection to the sharing personal data.

If an employee wishes to exercise his/her rights they can contact the Practice (data controller) or the DPO and their request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

e.      Data Sharing Databases

London Care Record

(in North Central London, provided via

Cerner - Health Information Exchange (HIE))

The London Care Record (LCR) is an Electronic Health Record (EHR) linking system that brings together patient data across the health and care system in a secure manner, embedding a single aggregated longitudinal view of the patient natively in each EHR system irrespective of traditional organisational or technological boundaries.

The LCR includes information about patients/clients recorded by acute hospitals, mental health, community health, social care and GP Practices.

Healthcare professionals across London and the region are able to access can access subsets of their patients/service users’ medical or social records from a single system in order to provide the best possible care.

The source of the information shared in this way is your electronic GP record for the purposes of direct patient care and indirect care. The full local privacy notice for this system can be found at

https://nclhealthandcare.org.uk/our-working-areas/using-digital-technology-to-improve-health-and-care/london-care-record-and-healtheintent-systems-privacy-notice/

All records held by the Practice and in the LCR system are   kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object or opt-out: You have the right to raise an objection to your personal data being shared in the LCR. You also have the right opt out of the LCR by completing an opt-out with your Practice. Although we will first need to explain how this may affect the care you receive. Opting out of the LCR includes opting out of HealtheIntent.

You can opt-out of the London Care Record via the form available online at https://nclhealthandcare.org.uk/our-working-areas/using-digital-technology-to-improve-health-and-care/info-residents/opting-out-of-the-joined-up-health-and-care-record/

If you wish to exercise any other of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.    

Cerner - HealtheIntent

Cerner - HealtheAnalytics

Cerner - HealthEDW

HealtheIntent is a platform that allows the practice and other healthcare providers to improve healthcare outcomes, patient experience, reduce adverse events and shift towards more preventative care. It covers both sharing and risk stratification.

HealtheIntent uses the shared care record (see above, LCR) plus additional data from care providers to give a better picture of your health.

The HealtheIntent platform contains three main tools - HealtheRecord, HealtheRegistries and HealtheAnalytics, and a data warehouse (HealthEDW).

o   HealthEDW is the data warehouse which securely holds all of the normalised, longitudinal data. Normalised means that all the same measurements are used so there is no confusion, longitudinal means that data is available over time.

o    HealtheRegistries provides a dashboard view for specific population cohorts usually a long-term condition e.g. diabetes. It provides users with an overview of indicators/measures and allows them to see how a patient is doing against these measures e.g. Hba1C result as well as their population (e.g. GP practice). This helps the user identify gaps or duplication in care at both an individual and population level.

o    HealtheAnalytics is a dashboard tool (Tableau) which can be used to identify trends and unwarranted variation in population cohorts. It will also enable clinicians and care professionals to ‘drill down’ to see which of their patients/clients require specific action.

The full privacy notice for the HealtheIntent system can be found at

https://nclhealthandcare.org.uk/our-working-areas/using-digital-technology-to-improve-health-and-care/london-care-record-and-healtheintent-systems-privacy-notice/

All records held by the Practice and in the systems are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services.

Related Legislation:

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object or opt-out: You have the right to raise an objection to your personal data being shared in HealtheIntent. You also have the right opt out of HealtheIntent by completing an opt-out form with your Practice. Although we will first need to explain how this may affect the care you receive. Opting out of HealtheIntent includes opting out of the London Care Record.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

You can also opt-out of the London Care Record via the form available online at https://nclhealthandcare.org.uk/our-working-areas/using-digital-technology-to-improve-health-and-care/info-residents/opting-out-of-the-joined-up-health-and-care-record/

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

EMIS Systems Local Record Sharing – Integrated Care

EMIS Local Record Sharing enables your GP medical record held on our secure EMIS Web clinical system to be shared with other healthcare Providers (e.g. acute hospitals, mental and community health and other GPs) who are commissioned to provide to provide health care services within your borough.

This local sharing is used to provide direct patient care for services such as continued extended access, home visits, universal offers, musculoskeletal service, GP at front door and other neighbourhood services across North Central London.

The information is accessed in real time and on-demand, meaning that data from your GP record is neither extracted, nor uploaded, nor sent anywhere in real time and on-demand, meaning that data from your GP record is neither extracted, nor uploaded, nor sent anywhere.

The source of the information shared in this way is your electronic GP record.

National Diabetic Retinal Screening Service – Diabetic eye screening is carried out in north central London by the North Central London Diabetic Eye Screening Programme (NCL-DESP).

NCL-DESP is provided by North Middlesex University Hospital NHS Trust which conducts screening across five London boroughs: Barnet, Camden, Enfield, Haringey and Islington.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice and the EMIS Local Record Sharing system are be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (c) - processing for legal obligation;

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9(2) (b) – processing necessary in the field of employment, social security and social protection law.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

Section 251B Health and Social Care Act 2012

Common Law of Duty of Confidentiality

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with the recipients.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

National NHS Digital Services “Spine” including:

·      Patient Demographics Service

·      e-Referral Service

·      Electronic Prescription Service

·      GP2GP

·      Summary Care Record

Spine supports the IT infrastructure for health and social care in England, joining together over 23,000 healthcare IT systems in 20,500 organisations.

It hosts 5 key services to support the delivery of your care. They enable healthcare professionals, authorised with an NHS smartcard, to view relevant information about you as follows:

Patient Demographics Service – The Personal Demographics Service (PDS) is the national electronic database of NHS patient details such as name, address, date of birth and NHS Number (known as demographic information). It helps healthcare professionals to identify patients and match them to their health records. It also allows them to contact and communicate with patients.

Summary Care Record (SCR) – is an electronic record of important patient information, created from GP medical records. It can be seen and used by authorised staff in other areas of the health and care system involved in the patient's direct care.

When your personal health records on your GP Record is uploaded to the spine, NHS Digital becomes the data controller for the uploaded information.

The source of the information shared in this way is your electronic GP record.

At a minimum, the SCR holds important information about;

·         current medication

·         allergies and details of any previous bad reactions to medicines

·         the name, address, date of birth and NHS number of the patient

Additional information, such as details of long-term conditions, significant medical history, or specific communications needs are in the SCR unless you have specifically stated that you do not want these included..

e-Referral Service - The NHS e-Referral Service (e-RS) combines electronic booking with a choice of place, date and time for first hospital or clinic appointments. Patients can choose their initial hospital or clinic appointment, book it in the GP surgery at the point of referral, or later at home on the phone or online.

Electronic Prescription Service - The Electronic Prescription Service (EPS) sends electronic prescriptions from GP surgeries to pharmacies. Eventually EPS will remove the need for most paper prescriptions.

GP2GP - GP2GP allows patients' electronic health records to be transferred directly, securely, and quickly between their old and new practices, when they change GPs. This improves patient care by making full and detailed medical records available to practices, for a new patient's first and later consultations.

The source of the information shared in all of the instances above in this way is your electronic GP record.

All records held by the Practice and the EMIS Local Record Sharing system are be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object or opt-out: You have the right to raise an objection or opt-out of out of having a Summary Care Record (SCR) by returning a completed opt-out form to their GP practice. Although we will first need to explain how this may affect the care you receive.

Note that the London Shared Care Record (LCR) has a separate opt-out, noted above.

You cannot opt-out of other Spine services as these services are essential to the management of the NHS.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Open Exeter

Open Exeter is a web-enabled viewer which provides the facility for healthcare professionals to share/access patient data held on the National Health Application and Infrastructure Services (NHAIS) systems, including cervical screening, breast screening, organ donor, blood donor and home oxygen. 

Access to Open Exeter is only possible on the N3 network, and via authorised logons/passwords provided by NHS Digital.

The source of the information shared in this way is your electronic GP record.

Data is viewed on screen.
If printed, it is destroyed when no longer required (usually within 24 hrs).

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared in Open Exeter.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

f.       Data Processors

AccuRx

AccuRx supply a number of systems to practices including text (SMS) messaging and remote consultations.

Your personal data is passed to them solely for these purposes and not used further.

Processing is carried out by AccuRx under instruction held as a processing agreement with your GP.

Data is not retained in this system once processed, but transferred to the clinical record system.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Amazon Web Services (AWS)

Amazon web services are used as a sub-processor by some NHS organisations and suppliers, including EMIS and NHS Digital.

Processing is carried out by AWS as a sub-processor to controllers such as Egton and EMIS Health.

These organisation are responsible under their contract for the management of the sub-processor.

Your GP does not have a direct relationship with AWS.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Please see the main system entry for details.

Clinical Coding, Medical Summarisation and other administrative services

Data Vitality

The practice uses the listed processor(s) as a service for coding letters received from others, filing, medical summarisation and letter creation.

The source of this data as a patient is your electronic patient record.

All records held in the Practice EMIS system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Patient contacts for call / recall for routine tests, particularly where area uptake is low. These providers provide additional language and assistance services to patients to enable them to attend or participate

Community Links

The practice uses the listed processor(s) as a service for contacting patients to contacting patients to arrange call / recall for routine tests. Some providers also provide assistance in translation to patients, and helping to attend or participate.

The source of this data as a patient is your electronic patient record.

All records held in the Practice EMIS system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Microsoft Azure and Office 365

including Teams, Sharepoint, Onedrive

The practice uses Microsoft Office 365 supplied by NHS England for internal information management. As such, it contains a mix of staff and patient personal data.

The practice uses Microsoft Office 365 in line with guidance from NHS Digital.

The source of this data as a patient is your electronic patient record.

Microsoft are also used as a processor by some NHS organisations and suppliers, including Optum, GP federations, most acute providers and others.

All records held in the Practice EMIS system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Where Microsoft (particularly Azure) is a sub-processor, for example to Optum, your GP does not have a direct relationship and the contracting organisation is responsible under their contract for the management of the sub-processor

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

CCTV and security monitoring

Securico

We use closed circuit television and security monitoring systems for the purposes of ensuring security of our patients, staff and premises.

All records held are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

For CCTV images, this is normally 30 days.

Article 6(1) (e) - public interest or in the exercise of official authority.

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

EMIS Health and Egton

EMIS Health and Egton are responsible for the provision of a clinical system, software and IT services used by the Practice to securely store and process your medical record.

All information about your personal health records are stored in your GP electronic record. This information is then available to practice staff & external bodies as outlined in this document.

This data can includes video, audio and photographic evidence from remote consultations.

All records held in the Practice EMIS system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

NHSMail

The practice uses NHSMail to process and manage email and calendar appointments for staff. As such, it contains a mix of staff and patient personal data.

The practice uses NHSMail in line with guidance from NHS Digital.

Rights and policies in respect of staff personal data are held by NHS Digital as the controller and available at the link below

NHSMail Transparency Information

The source of this data as a patient is your electronic patient record.

Note that NHSMail is now provided by Microsoft.

The NHSMail data retention and Information Management policy is available at the link below:

NHSMail Data Retention and Information Management Policy

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

North Central London Integrated Care Board

(formerly North Central London CCG)

NHS North Central London ICB is responsible for securing, planning, designing and paying for your NHS services, including planned and emergency hospital care, mental health, rehabilitation, community and primary medical care (GP) services, Information Communication Technology (ICT), providing risk stratification and secondary use services.

The ICB act as the Data Processor for EMIS Systems Local Record Sharing and, process personal data from your GP record in accordance with instructions from the Practice.

Some services provided by the ICB are shared across London and provided to the ICB by other areas. These are detailed in this document.

The source of the information shared in this way is your electronic GP record.

All records held in the Practice EMIS system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

South West London Integrated Care Board - GP Practice Data Extraction Services

The GP Practice Data Extraction Services is shared across London, with South West London performing the service. This enables SWL to, on behalf of the NCL area, extract personal data from GP Practice covering all currently registered patients and those ever registered since April 2009 except where patients have explicitly dissented from their information being extracted, for the provision of services back to the practice which may include:

Risk stratification; linking data to other data sets;

financial reporting;

business intelligence;

statistical analysis and;

information to support delivery of patient care.

The source of the information shared in this way is your electronic GP record.

All records held in the Practice EMIS system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared, which will restrict your patient record from being shared with anyone outside your GP.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

Docman

And

Docmail

Docman Limited act as a data processor and provides cloud-based storage software for electronic patient document. This includes letters that we receive, scan and upload to the patient record, as well as letters that we receive in an electronic format.

Generally, Docman enables primary health care organisations capture, file, workflow, view and manage primary care documents efficiently.

Docmail enables primary health care organisations send letters, invoices and documents directly from computers and other portable devices.

The source of the information shared in this way is your electronic GP record for the purposes of direct administrative patient care.

All records held in the Practice EMIS system and the Docman vault are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner (ICO), whose contact details are given at section 8.

iPlato

iPlato is cloud-based text messaging service used by GPs to communicate with their patients.

The source of the information shared in this way is your electronic GP record for the purposes of direct administrative patient care.

All personal health records held in the Practice EMIS system and the iPlato system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: In line with the UK GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

INhealth Intelligence

InHealth (formerly QMS-UK) are commissioned by NHS England to provide secure data processing solutions for two services:

Child Health Information Service – information relating to children’s vaccinations is shared with North East London Foundation Trust who run one of 4 Child Health Information Services across London.

Additionally, they are an approved NHS provider for services such as diabetic retinopathy screening, ultrasound scans and other tests. Generally for these purposes they are a separate data controller.

All records held in the Practice EMIS system and the QMS database are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared in QMS.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

Better Ltd Urgent Care Plan

Better Ltd are commissioned by South West London on behalf of all parts of London to provide secure data processing solutions for:

Urgent Care Plans – The NHS aims to provide personalised care based on what matters to you. Care planning enables your wishes and individual care and support needs to be communicated digitally with your healthcare professionals across London.

·         A care plan can be created following a conversation between you and your healthcare professional (such as a doctor or nurse). Your healthcare professional will listen to you, understand your needs and make notes about:

·         What is important to you in your day-to-day life

·         Your preferences or wishes about your care, such as where you prefer to be cared for

·         What support you need and who is best placed to provide this

·         Information about others who may be involved in your care, such as relatives

·         Based on your conversation, your healthcare professional can document this information using a digital system. Your care plan can be continuously updated throughout your life, depending on your needs and wishes.

For details, see https://ucp.onelondon.online/patients/

Your healthcare professional will document a clinical recommendation, should you need emergency care. Information on your care plan is visible to all health and care services who are involved in your care.

This may include the London Ambulance Service, 111 and Out of Hours GP services who may see you in an emergency.

All records held in the are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Since the Urgent Care Plan is created voluntarily by patients, patients can withdraw it at any time, in which case it will be deleted.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

Medicines Management and Prescribing Optimisation

Optum Scriptswitch

ScriptSwitch prompts prescribers with potentially better choices for medication when they are prescribing, based on NICE guidance and guidance from the NCL Medicines Management Team.

No identifiable personal data is shared or processed outside of the prescriber’s computer, the app processes your data locally as an add-on to the EMIS system. Your prescriber is free to accept or reject its suggestions based on their professional judgement.

The app records anonymised data on the prescribing which is then provided as an aggregate (totals only) to the NCL Medicines Management Team for review.

Scriptswitch does not create any identifiable records. Please refer to the entry for EMIS for details of your medical record.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

See Entry for EMIS

GP Connect

GP Connect allows authorised clinical staff to share and view GP practice clinical information and data between IT systems, quickly and efficiently. It is run and managed by NHS England

It provides full record sharing to other partners in health and care and is used for a many of the linkages noted elsewhere in this notice.

For more details, please visit:

https://digital.nhs.uk/services/gp-connect

All records held in the Practice EMIS system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the UK.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared in QMS.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

NHSE Approved Suppliers

The Practice performs computerised searches of some or all of our records to identify individuals who may be at increased risk of certain conditions or diagnoses i.e. Diabetes, heart disease, risk of falling). Your records may be amongst those searched. This is often called “risk stratification” or “case finding”. These searches are sometimes carried out by Data Processors who link our records to other records that they access, such as hospital attendance records. The results of these searches and assessment may then be shared with other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.

Risk stratification can be grouped into two purposes namely:

Direct Care – ‘Case Finding’ where carried out by a health professional (e.g. GPs and Provider) involved in an individual’s care or by a data processor acting under contract with such a provider, it is treated as direct care.

Indirect Care - understand the local population needs and plan for future requirement.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:

Section 251 NHS Act 2006

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

To enable healthcare professionals working for the Practice to provide information, derived from GP records, about individuals to accredited research organisations.

This covers research situations where the data controller (the Practice) is approached by research organisations, directly, to recruit patients for studies.

Any research proposal will only be agreed with a clearly defined protocol, consent mechanisms, and relevant research ethics committee approval, and in line with the principles of Article 89(1) of the UK GDPR.

Research organisations do not approach patients directly, rather the Practice will invite appropriate patients directly seeking their wish to take part.

This Privacy Notice does not cover situations where the Practice has been approached by an organisation seeking special category personal data to be disclosed in the absence of consent, i.e. via Related Legislation: Section 251 NHS Act 2006 / Health Research Authority (HRA) approval.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (j) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on domestic law

Related Legislation:

Section 251 NHS Act 2006

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

Iron Mountain

To provides solutions for records management, data backup and recovery, document management, secure storage, and accredited data destruction.

The source of the information shared in this way is your electronic GP record.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (j) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on domestic law

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

The supplier [insert name] offer a wide range of business assurance services, from internal audit, counter fraud and forensic investigations, risk management and governance.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6(1) (e) - public interest or in the exercise of official authority.

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

Fairway Trainings

The HR supplier, Practice Index provides practices with a software solution to enable the recording of Human Resources related information of its employees’ personal data, in particular for the purposes of the recruitment, obligations performance contract of employment, rights and benefits management planning, health and safety, equality and diversity in the workplace, health and safety at work.

The Payroll supplier, Fairway Training provides practices with a software solution to enable the management and payment for employment of staff, contractors and others, including management of tax payments, pension payments, expenses and deductions. All processing is carried out in accordance with UK law relating to employment and taxation.

The Practice ensures that personal data it collects from employees are used only for employment related purposes or where there is a statutory obligation to share the personal information with to regulatory bodies (e.g. courts, police or NHS England).

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6 1(e) (public interest or in the exercise of official authority).

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

Employees have the right to:

·      To access, view or request copies of their personal information held by the Practice;

·      request rectification of any inaccuracy to their personal information;

·      restrict the processing of their personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: Employees have a general right to raise an objection to the sharing personal data.

If an employee wishes to exercise his/her rights they can contact the Practice (data controller) or the DPO and their request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

Surgery Connect

The Surgery Connect provides practices with a software solution to enable the delivery and recording of telephone calls/video calls for the purposes of care delivery.

The Practice ensures that personal data it collects in this way is only used for the purposes of delivery of service, fact checking and quality assurance.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6 1(e) (public interest or in the exercise of official authority).

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

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Persons involved in telephone/video calls have the   right to:

·      To access, view or request copies of their personal information held by the Practice;

·      request rectification of any inaccuracy to their personal information;

·      restrict the processing of their personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: Users have a general right to raise an objection to the sharing personal data.

If a user wishes to exercise his/her rights they can contact the Practice (data controller) or the DPO and their request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

My Surgery Website

The provides practices with a software solution to provide a website, including online patient interactions the purposes of care delivery.

The Practice ensures that personal data it collects in this way is only used for the purposes of delivery of service, fact checking and quality assurance.

All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Article 6 1(e) (public interest or in the exercise of official authority).

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

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Persons involved in telephone/video calls have the right to:

·      To access, view or request copies of their personal information held by the Practice;

·      request rectification of any inaccuracy to their personal information;

·      restrict the processing of their personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object: Users have a general right to raise an objection to the sharing personal data.

If you wish to exercise your rights you can contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

Consultant Connect

Surgery Connect provides a national network of consultants for GPs to access in order to assist with your direct care. Telephone advice and guidance, photo-messaging advice and guidance are the key services provided.

All records held by the Practice and the Consultant Connect Sharing system are be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object or opt-out: You have the right to raise an objection or opt-out of out of having an SCR by returning a completed opt-out form to their GP practice. Although we will first need to explain how this may affect the care you receive.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

WHZAN provides care homes with monitoring devices to help perform medical checks. These devices can share data directly with the Practice and we can respond to the medical tests via the system, this providing better integrated care for care home residents.

All records held by the Practice and the Consultant Connect Sharing system are be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object or opt-out: You have the right to raise an objection or opt-out of out of having an SCR by returning a completed opt-out form to their GP practice. Although we will first need to explain how this may affect the care you receive.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

IGPR

[Delete as needed]

We use the [iGPR system provided by Niche Health | Medi2Data system provided by Medidata Exchange ] for the purposes of providing you with medical reports and subject access request responses that are correctly mananged in respect of the rights of others.

These providers work as a processor on our behalf. They do not retain or use your medical records for any purpose other than fulfilling your requests.

All records held by the Practice and the Consultant Connect Sharing system are be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Article 6(1) (e) - public interest or in the exercise of official authority.

Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

You have the right to:

·      To access, view or request copies of your personal information;

·      request rectification of any inaccuracy in your personal information;

·      restrict the processing of your personal information where:

ü  accuracy of the data is contested,

ü  the processing is unlawful or,

ü  where we no longer need the data for the purposes of the processing.

Right to object or opt-out: You have the right to raise an objection or opt-out of out of having an SCR by returning a completed opt-out form to their GP practice. Although we will first need to explain how this may affect the care you receive.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice processes your data, you have the right to appeal/complain. You may raise the issue with the Practice’s Data Protection Officer, contact details are given at section 6, or if not satisfied, with the Information Commissioner, contact details are given at section 8

Tel: 0303 123 1113 or 01625 545 745

Website: https://ico.org.uk  

Social Media Channels: Facebook,

Via Redmore

We use these channels to provide general information and respond to general queries. We are not the data controller for your information here.

We do not accept appointment requests, perform medical diagnosis or use personal data in any other way than as noted above; if you message us using these channels, we will ask you to contact us directly.

Not applicable – we are not the data controller.

Article 6 1(e) (public interest or in the exercise of official authority).

There is no processing of special category data here.

Please refer to the social media company’s privacy notice.

National Data Opt-Out for Confidential Patient Data for Research and Planning

Not direct care, it is research and planning. By opting out you restrict your confidential patient data from this use

It is available to researchers/planners anywhere who have demonstrated a research and planning need for identifiable data and been through the approval process which includes data protection and ethics reviews.

NHS Digital have stated they will never sell your personal information.

This differs from the Type 1 opt-out (see below) in that it applies to all your data. Note that NHS Digital have stated that the GP Data for Research and Planning is only restricted by the Type 1 opt-out. NHS Digital have stated that the National Data Opt-Out does not apply to confidential data used within the NHS.

For you

If critical issues are discovered via research that could have identified you as someone at risk, you will not be included and hence not informed early.

For care in my area

No impact

For the NHS

The NHS will be less able to plan.

Research may be affected by not having information.

There is a detailed information page at https://www.nhs.uk/your-nhs-data-matters/

You can opt in or out via the page above.

If you wish to exercise your choice by post, a form is available at the Surgery.

Note that if you opt out, data that does not identify you can still be used, e.g. number of patients in an area.

[EMIS Codes are not used as the data is held centrally]

London Care Record

(Local Shared Care Record – HIE/HEI)

Yes, direct care only. All uses are direct care and restricted to the London area.

It is available to health and care practitioners involved in your direct care in the London area.

Because it is direct care only, we will never sell your personal information

For you

People providing care to you may not have the latest information. You will probably have to answer repeated questions, and there is a risk of harm to you because local information (e.g. at a hospital) may be out of date. You may be at risk if treated in an emergency situation and are unable to provide information.

For care in my area

We will be less able to join up your services and it will make it more difficult, and expensive, to provide some care to you. Where health and care initiatives are taking place outside your GP, you may not be included as your record will not be visible.

For the NHS

The extra cost may impact the wider NHS.

There is a detailed information page at

https://nclhealthandcare.org.uk/our-working-areas/using-digital-technology-to-improve-health-and-care/london-care-record-and-healtheintent-systems-privacy-notice/

Your GP surgery also has copies of the information in multiple languages.

The form to exercise your choice is provided as part of the detailed information.

Note that if you opt out data that does not identify you can still be used, e.g. number of patients in an area.

[EMIS Codes are not used as the data is held centrally]

North Central London Integrated Care System Secondary Data Use

Not direct care; this is use for planning of services, review of deliveries and other purposes involving population health.

For you

You won’t be represented in statistics and planning. This is unlikely to impact you individually, but if enough people with similar needs to yours opt-out, services may not represent your needs.

For care in my area

We will be less able plan services in a way that meets all the needs in the area.

For the NHS

The extra cost may impact the wider NHS.

There is a detailed information page and opt-out form at

https://nclhealthandcare.org.uk/your-health-and-care-data-can-help-improve-services/

Summary Care Record

(National Shared Care Record - SCR)

Yes, direct care only. All uses are direct care. You will be asked for consent before the record is accessed, if this is possible.

It is available to health and care practitioners involved in your direct care anywhere in England where you are treated.

Because it is direct care only, we will never sell your personal information

For you

People providing care to you away from the London area will have little information about you. You will probably have to answer repeated questions. You may be at risk if treated in an emergency situation and are unable to provide information. You can choose to have no summary record, a basic summary record containing data for your safety and a more detailed record including additional clinical data.

For care in my area

This record is not generally used locally as the HIE record is used.

For the NHS

It affects the ability of health and care practitioners to treat you safely.

Full details of the Shared Care Record (SCR) are available at

https://digital.nhs.uk/services/summary-care-records-scr/summary-care-records-scr-information-for-patients

Your GP surgery will also have a national leaflet available explaining the Shared Care Record.

The national leaflet is available to download from the page above, or available at your GP and contains details of how to exercise your options.

Note that during the pandemic, NHSE updated to include additional SCR for all persons who had not expressly dissented – see the page above.

[EMIS Codes: 9Ndm – Express consent for core SCR

9Ndn –Express consent for core and additional SCR

9Ndo – Express dissent for SCR (blank summary would be uploaded to the Spine)]

GP Connect Record Sharing

Yes, direct care only. All uses are direct care. You will be asked for consent before the record is accessed, if this is possible.

It is available to health and care practitioners involved in your direct care anywhere in England where you are treated.

Because it is direct care only, we will never sell your personal information

For you

People providing care to you away from the London area will have little information about you. You will probably have to answer repeated questions. You may be at risk if treated in an emergency situation and are unable to provide information. You can choose to have no summary record, a basic summary record containing data for your safety and a more detailed record including additional clinical data.

For care in my area

This record is not generally used locally as the London Care Record record is used.

For the NHS

It affects the ability of health and care practitioners to treat you safely.

Awaiting details; the national data sharing agreement is being finalised; when it is, the details will be part of the agreement.

[EMIS codes will begin 93C]

Type 1 Opt-Out (GP Record sharing for Research and Planning)

Not direct care, it is research and planning. By opting out you restrict your confidential GP patient data from this use.

It is available to researchers/planners anywhere who have demonstrated a research and planning need for identifiable data and been through the approval process which includes data protection and ethics reviews.

NHS Digital have stated they will never sell your personal information. Your GP similarly will never sell your personal information.

This differs from the National Data Opt-Out in that it applies to your GP data only. The National Data Opt-Out also opts out other providers. Note that NHS Digital have stated that the GP Data for Research and Planning is only restricted by this opt-out.

For you

If critical issues are discovered via research that could have identified you as someone at risk, you will not be included and hence not informed early.

For care in my area

No impact

For the NHS

The NHS will be less able to plan.

Research may be affected by not having information.

There is a detailed information page at

https://digital.nhs.uk/data-and-information/data-tools-and-services/data-services/general-practice-data-hub/care-information-choices

[EMIS Codes: 9Nu0 Type 1 Opt-out

9Nu1 Type 1 opt back in.]

No GP electronic care record sharing

Yes and no. This covers ALL electronic sharing so no data will be shared outside of your GP

No record is available outside your GP

Because there is no electronic record there is nothing to sell

For you

Every interaction outside of your GP will require a letter to be sent to share data. This can put you at risk as information will be incomplete.

This option includes the type 1 opt-out, so those issues also apply.

For care in my area

Cost, difficulty and patient risk of care is increased as practitioners do not have access to your information.

This option includes the type 1 opt-out, so those issues also apply.

For the NHS

Increased cost and complexity of care.

This option includes the type 1 option so those issues also apply.

Speak directly to your GP; because of the clinical risk it is recommended that you discuss first.

[EMIS code: 9Nd1 No consent for electronic record sharing

9Nd7 Consent for electronic sharing. Note that these codes are being changed as consent is not the correct legal basis]

Other provider opt-outs (e.g. Mental Health Trusts)

Yes – direct care. This covers ALL electronic sharing at the provider (e.g. if you had received treatment at the hospital it would not be shared electronically back to your GP or other providers).

No record is available outside the provider where you received treatment. Sharing of data to ensure treatment will be by letter/email.

Because there is no electronic record there is nothing to sell

For you

Every interaction outside of your provider will not have the information from that provider; this may create risks for you as your treatment may be incorrect.

For referrals, a letter/email will provide the data. This can put you at risk as information will be incomplete.

For care in my area

Cost, difficulty and patient risk of care is increased as practitioners do not have access to your information.

For the NHS

Increased cost and complexity of care.

Speak to the individual provider.

They will provide opt-out information and how to exercise it.

[Coding varies depending on the care system used]

Objection to use (“Opt-Out”)

Purposes affected

Identifiable Data Restricted

Direct Care London

Direct Care England

Research and Planning

GP Data?

Other NHS Data?

Other Care Data?

National Data Opt-Out for Confidential Patient Data for Research and Planning

ü

ü

ü

ü

London Care Record

(Formerly HIE/HEI)

ü

ü

ü

ü

North Central London Integrated Care System Secondary Data Use

(NCL ICS)

[ü]

ü

ü

ü

Summary Care Record

(National Shared Care Record - SCR)

ü

ü

ü

GP Connect (National Access to your GP record)

(ü)

ü

ü

Type 1 Opt-Out (GP Record sharing for Research and Planning)

ü

ü

No GP electronic care record sharing

ü

ü

ü

ü

Other provider opt-outs (e.g. Mental Health trusts)

ü

ü

ü

ü

ü