Privacy Notice

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information may be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

Patients

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received within any NHS organisation. These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we may collect information about you which helps us respond to your queries or secure specialist services.

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments. We may keep your information in written form and/or in digital form.

The records may include basic details about you, such as your name and address.  They may also contain more sensitive information about your health and also information such as outcomes of needs assessments.

Staff

As employers we are required to keep records about your employment to ensure we meet our legal responsibilities for example to ensure all employees have the right to work in the UK and to enable the development of a comprehensive understanding our workforce and how it is deployed to support our business functions.

We collect and hold data to:

• Inform the development of HR policies
• Support workforce planning
• Make recruitment decisions
• Enable staff to be paid and have the correct pension contributions deducted
• Monitor timekeeping and attendance
• Assess training needs and maintain training records
• Implement disciplinary and grievance processes
• Maintain up to date records to ensure effective correspondence and ensure that we can contact you or your next of kin in an emergency.  For example, your details are shared with the payroll company for calculation of salary and production of payslip and the bank to pay you.

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and disciplinary matters. We may keep your information in written form and/or in digital form.

Details we collect about you

Patients

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

Records which this GP practice may hold about you include the following:

• Details about you, such as your address and next of kin
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
• Notes and reports about your health
• Details about your treatment and care
• Results of investigations, such as laboratory tests, x-rays, etc.
• Relevant information from other health professionals, relatives or your carers
• The practice may receive emails and letters about your care (most frequently from hospitals and community services).  These are scanned into your medical record and the originals are shredded using a confidential waste company.

How we keep your information confidential and safe

Everyone working for our organisation is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS England  Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this.

The health records we use may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

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

• Data Protection Act 2018
• UK General Data Protection Regulation
• Human Rights Act
• Common Law Duty of Confidentiality
• NHS Codes of Confidentiality and Information Security
• UK GDPR
• And all applicable legislation

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for providing you, your family and your community with better care. For example, it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing section below.

Under the powers of the UK GDPR , NHS England  can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.

You may choose to opt-out to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start.

Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.

You can object to your personal information being shared with other healthcare providers which will not affect your entitlement to care, but you should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS.

Practice Website (www.gordonhouse.nhs.uk)

Passive information collection and use

As you navigate through our website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, internet tags and navigational data collection.

Please read the section on Cookies below and review the Cookie Settings for detailed information about Cookies and other tracking technologies used on our site. In this policy you will also find information on how to disable cookies and tracking technologies if you do not agree to their use as well as the consequence(s), if any, of disabling each specific cookie/tracking technology. If you do not disable any cookies or tracking technologies, we will infer your consent to their use.

We and our third party service providers may passively collect and use information in a variety of ways, including:

• Through your browser – Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.
• IP Address – Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
• Using pixel tags, web beacons, clear GIFs, or other similar technologies –  These may be used in connection with some site pages and HTML-formatted e-mail messages to, among other things, track the actions of site users and e-mail recipients, and compile statistics about Site usage and response rates.
• Device Information – We may collect information about your mobile device, such as a unique device identifier.

Cookies and IP addresses

A cookie is a small text file that is downloaded onto a computer or smartphone when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions. We use these to monitor access to our website and tailor any developments based on usage and pages visited.

We use Google Analytics software on this site to anonymously track how visitors interact with this website. This includes identifying:

• The pages visited on this site
• How long the visitor spends on each page on this site
• How visitors got to the site
• What visitors click on while visiting the site

We do this to help make sure the site is meeting the needs of visitors and help us make improvements, for instance improving site search.

We don’t use cookies to track the identity of visitors or the information they have entered into the site.

You give us consent to using cookies for analytic purposes if you continue to use our website. Alternatively, you can switch off cookies in your browser and the site will still work normally.

Third Party Sites and Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any App) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us.

Security

We use reasonable organisational, technical and administrative measure to protect personal information under our control and in accordance with this privacy policy.

Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk.

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section.

Cross Border Transfers

Personal information other than medical data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms to send communication emails to our users.

Patients and staff

CCTV

Images are recorded to protect staff and practice property. It will not be used for any other purpose. Images from the CCTV system are securely stored and only authorised personnel may access them. The recorded images will only be retained long enough for any incident to come to light (e.g. for a theft to be noticed) and the incident to be investigated. Except for law enforcement bodies, images will not be provided to third parties.

Telephone Recording

All calls are recorded for training and quality purposes.  There is an announcement on the telephone system to alert anyone calling the surgery that calls may be recorded. Telephone calls are stored securely and only accessed by authorised personnel.

Digital systems and approved third party processors

Abtrace (Patient Monitoring and Recall System)

Use of Abtrace

The Practice uses Abtrace, a proactive patient monitoring and recall system designed specifically for primary care. The system helps the Practice identify patients who may be due reviews, monitoring, tests, vaccinations or other routine healthcare interventions and supports the Practice in contacting patients when follow-up care is required.

Abtrace integrates with the Practice’s clinical system and supports the delivery of safe, proactive and preventative healthcare by helping ensure that important monitoring and reviews are not missed.

How Your Information Is Used

Abtrace processes information held within the Practice’s clinical system to:

• Identify patients who are due clinical reviews, screening, monitoring, tests or vaccinations.
• Support disease management and preventative healthcare.
• Assist the Practice in contacting patients when follow-up care is required.
• Improve the quality, safety and effectiveness of patient care.
• Support delivery of NHS contractual and clinical quality requirements.

Information processed through Abtrace remains part of your confidential medical record and is only used for purposes connected with the provision of healthcare and management of NHS services.

Lawful Basis for Processing

The Practice processes personal information using Abtrace under:

• UK GDPR Article 6(1)(e) – processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
• UK GDPR Article 9(2)(h) – processing necessary for the provision of health or social care and the management of health and care services.

Healthcare professionals remain bound by the Common Law Duty of Confidentiality and their professional obligations.

Data Security and Confidentiality

The Practice has appropriate contractual and information governance arrangements in place with Abtrace.

The supplier states that:

• The platform is designed specifically for NHS primary care.
• It is UKCA-marked as a medical device.
• It is certified to ISO 27001 (Information Security Management) and ISO 13485 (Medical Device Quality Management).
• It operates within NHS information governance and data security requirements.

Access to patient information is restricted to authorised users who require access as part of their role in providing healthcare services.

Data Processor

Abtrace acts as a data processor on behalf of the Practice and processes personal information only in accordance with the Practice’s instructions and applicable data protection legislation.

Further Information

If you have questions about how your information is used by Abtrace or wish to obtain further information about the Practice’s use of this system, please contact the Practice Manager.

Accurx

Use of Accurx

The Practice uses Accurx, a secure NHS-approved communication platform that supports communication between healthcare professionals and patients. Accurx helps the Practice provide timely care and improve access to services by enabling secure digital communication.

The Practice may use Accurx to:

• Send appointment reminders and healthcare communications.
• Send questionnaires, forms and health information.
• Receive information, photographs, documents and updates from patients where appropriate.
• Support administrative and clinical communications.
• Enable remote consultations and patient triage services where these are offered by the Practice.

How Your Information Is Used

When you communicate with the Practice using Accurx, personal information may be processed to:

• Provide healthcare services and treatment.
• Assess, monitor and manage your healthcare needs.
• Manage appointments and referrals.
• Respond to enquiries and requests.
• Maintain accurate clinical records.

Information received through Accurx may be added to your medical record where it is relevant to your ongoing care and treatment.

Lawful Basis for Processing

The Practice processes personal information through Accurx under:

• UK GDPR Article 6(1)(e) – processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
• UK GDPR Article 9(2)(h) – processing necessary for the provision of health or social care and the management of health and care services.

Healthcare professionals remain subject to the Common Law Duty of Confidentiality and their professional obligations.

Security and Confidentiality

Accurx is used under strict NHS information governance requirements and appropriate contractual arrangements.

Appropriate technical and organisational measures are in place to protect personal information against unauthorised access, loss, misuse or disclosure. Access to information is restricted to authorised staff who require access as part of their role.

The Practice will only use information obtained through Accurx for legitimate healthcare and administrative purposes connected with the delivery of NHS services.

Data Processor

Accurx acts as a data processor on behalf of the Practice and processes personal information in accordance with contractual requirements, UK data protection legislation and NHS information governance standards.

Your Choices

Where appropriate, you may choose not to respond via Accurx and can contact the Practice using alternative methods. However, some services may operate more efficiently through digital communication channels.

Further Information

If you would like further information about how your personal information is processed through Accurx, please contact the Practice Manager

Ambient Voice Technology (Heidi Health)

Use of Ambient Voice Technology

The Practice uses Heidi Health to support clinicians during consultations. Heidi is an ambient voice technology and clinical documentation tool that assists healthcare professionals by securely recording and transcribing conversations during consultations and generating clinical notes for review by the clinician.

The purpose of using this technology is to:

• Reduce administrative burden on clinicians.
• Allow clinicians to focus more fully on patients during consultations.
• Improve the efficiency and accuracy of clinical record keeping.
• Support high-quality patient care and continuity of care.

How Your Information Is Used

When Heidi is used during a consultation, the conversation between you and the clinician may be securely processed to create a draft clinical note or consultation summary.

All clinical information generated by Heidi is reviewed by the clinician before being added to your medical record. The clinician remains responsible for ensuring the accuracy, completeness and appropriateness of the final clinical record.

Lawful Basis for Processing

The Practice processes personal information through the use of ambient voice technology under:

• UK GDPR Article 6(1)(e) – processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
• UK GDPR Article 9(2)(h) – processing necessary for the provision of health or social care and the management of health and social care systems and services.

In addition, healthcare professionals remain subject to their professional duty of confidentiality and the Common Law Duty of Confidentiality.

Security and Confidentiality

Any information processed through Heidi is handled in accordance with UK data protection legislation, NHS information governance requirements and contractual security standards.

The Practice has undertaken appropriate due diligence before implementing the technology, including consideration of information governance, data protection and security requirements.

Only authorised personnel involved in your care will have access to information generated during your consultation.

Patient Choice

If you do not wish Heidi to be used during your consultation, please tell the clinician. Your care will not be affected if you choose not to have this technology used and the clinician will continue to record consultation information using alternative methods.

Data Processing

Heidi acts as a data processor on behalf of the Practice and processes information only in accordance with the Practice’s instructions and applicable contractual arrangements.

Further information about how Heidi processes personal information can be found in Heidi’s privacy information and data protection documentation.

Further Information

If you have any questions about the Practice’s use of ambient voice technology or how your information is processed, please contact the Practice Manager

NHS App and Online Services

The NHS App enables patients to access a range of NHS services through their smartphone, tablet or computer. Depending on the services made available by the practice, patients may be able to:

• View parts of their GP health record.
• Order repeat prescriptions.
• Book and manage appointments.
• View test results.
• Access NHS correspondence and messages.
• Update contact details.
• Access NHS services provided by other healthcare organisations.

When you register for and use the NHS App, information from your GP record may be made available to you through secure NHS systems. Information is only shared where appropriate access controls and security measures are in place.

The NHS App is provided by NHS England and operates using secure national NHS infrastructure. When using the NHS App, your personal information may be processed by NHS England and other authorised NHS organisations involved in providing and supporting the service.

Lawful Basis for Processing

The Practice processes personal information in connection with the NHS App under:

• UK GDPR Article 6(1)(e) – Performance of a task carried out in the public interest or in the exercise of official authority.
• UK GDPR Article 9(2)(h) – Provision of health or social care and the management of health and social care systems and services.

Access to Medical Records

Patients who request online access to their medical records through the NHS App may be required to verify their identity before access is granted.

The Practice may restrict access to certain information where required by law or where disclosure could result in serious harm to the physical or mental health of the patient or another person.

Security of Your Information

The NHS App uses secure systems to protect personal information. Patients are responsible for keeping their login credentials secure and should not share their account details with others.

If you believe somebody has gained unauthorised access to your NHS App account, you should contact NHS App support and inform the Practice where appropriate.

Proxy Access

Patients may choose to give another person permission to act on their behalf through authorised proxy access arrangements. This may allow a parent, carer or other authorised individual to access certain online services in accordance with NHS guidance and the Practice’s procedures.

Proxy access will only be granted following appropriate verification and authorisation checks.

Further Information

Further information about the NHS App, including how your information is used, is available at:

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

You can also speak to the Practice if you have any questions about accessing your health information through the NHS App.

Automated Decision Making

The Practice does not make decisions about patients solely by automated means where those decisions would have a legal or similarly significant effect on an individual.

Organisations Processing Information on Our Behalf

We use the following suppliers and these suppliers process information under contract and under UK GDPR requirements

Child Health Information – CHIS

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS health visitors and school nurses, with the Commissioning Support Unit, who provide the Child Health Information Service (CHIS) on behalf of NHS England. 

Information for Children and Young People

How We Use Information About Children and Young People

The Practice provides healthcare services to patients of all ages and holds personal information relating to children and young people registered with the Practice.

We use this information to:

• Provide safe and effective healthcare.
• Maintain accurate medical records.
• Arrange appointments, referrals and follow-up care.
• Support vaccination and screening programmes.
• Protect the health and wellbeing of children and young people.
• Meet our legal and regulatory responsibilities.

Confidentiality for Children and Young People

Children and young people have the same rights to confidentiality as adult patients.

As children grow older and are able to understand and make decisions about their own healthcare, they may be entitled to make decisions about how their personal information is used and shared.

Healthcare professionals have a duty to keep information confidential unless there is a lawful reason to share it, such as where there are concerns about the safety or welfare of a child or another person.

Parents, Guardians and People with Parental Responsibility

Parents, guardians and others with parental responsibility may be able to access a child’s information where this is appropriate and lawful.

However, access is not automatic. Decisions will take account of:

• The child’s age and level of understanding.
• Whether the child can make decisions about their own healthcare information.
• The child’s wishes and best interests.
• Legal and professional guidance regarding confidentiality.

Where a young person is considered capable of understanding their rights and making decisions about their healthcare information, the Practice will normally seek to respect their confidentiality.

Online Services and Proxy Access

Parents and carers may request proxy access to online services on behalf of a child where appropriate.

As children mature, online access arrangements will be reviewed to ensure that confidentiality rights are properly protected and that access remains appropriate.

The Practice may limit, modify or remove proxy access where necessary to protect patient confidentiality or comply with legal requirements.

Subject Access Requests

Children and young people may request access to their own personal information.

A parent or person with parental responsibility may also request access on behalf of a child where permitted by law and where this is considered appropriate.

Each request will be assessed individually to ensure the rights, best interests and confidentiality of the child or young person are protected.

Safeguarding

The Practice is committed to safeguarding and promoting the welfare of children and young people.

Where we have concerns that a child or young person may be at risk of harm, we may share relevant information with appropriate organisations, including health services, social care services, education providers and law enforcement agencies, where permitted or required by law.

Further Information

If you have any questions about how information relating to children and young people is used, please contact the Practice Manager.

Clinical audit

Information may be used by the ICB for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

Electronic Prescribing Service (EPS)

We share information about your medications with your pharmacy when you inform us of your usual pharmacy.  This allows your repeat medication prescription to be sent securely to your preferred pharmacy so that you do not need to attend the surgery to collect your prescription.

Enhanced Data Sharing Module

Gordon House Surgery uses TPP SystmOne and this allows you to choose whether other health and care providers can access your information to help provide you with care. We have drawn up an “allowed list” of local organisations with whom we can share your data (when you register for their services and give them verbal permission to provide your care through a TPP clinical system). See the link below under who are our partner organisations.

Organisations outside of this allowed group who use the same software will require formal documented permission to see your records. Your GP system will send you an SMS or email which you can give to the organisation asking for access which will formally validate your consent. It is possible for you to set your own specific permissions (as distinct from the allowed list we have provided).

GP Connect

We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.
GP Connect is not used for any purpose other than direct care.

Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS England  service called GP connect. 

The NHS 111 service (and other services determined locally e.g. Other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services. 

Further information can be found here: https://digital.nhs.uk/services/gp-connect

Improving Diabetes Care and long-term condition management

We share information about patients with diabetes with the Diabetic Retinopathy Screening Service (DRSS) to ensure that all diabetic patients receive annual screening.

Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.

Individual Funding Request

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for funding of specialised healthcare which falls outside the range of services and treatments that ICB has agreed to commission for the local population. An Individual Funding Request is taken under consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to check which ICB is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

Local Information Sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. In order to provide you with health and social care services your GP practice works in close collaboration with neighbouring practices as part of a Primacy Care Network (PCN).  Our practice is part of The Ealing Network PCN. The organisational boundary within which professionally trained staff can access your health record without consent has extended from your GP practice to this Primary Care Network and staff employed on its behalf. Staff are trained to understand their legal and professional responsibilities of confidence to their patients and will only access your records when they are required to do so to support you care. They will identify themselves and their role using a smart card and access to your PCN record is recorded, monitored, and audited.

If you require attention from a local health or care professional outside of your usual PCN services, such as in an Evening and Weekend GP Hub services, Emergency Department, Minor Injury Unit or Out of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent.

Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record. The practice uses TPP systmOne

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Aside from your registered health care provider, your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).

MISL

We use a secure storage service to store our patient records off site.

National Fraud Initiative – Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice.

National Institute for Health and Care Research (NIHR)

Our practice supports health and care research through the National Institute for Health and Care Research (NIHR) and may participate in approved research studies from time to time. The NIHR is funded by the Department of Health and Social Care (DHSC) and works with NHS organisations, universities and researchers to improve healthcare through research.

How your information may be used

If the practice is involved in a research study, your personal information may be used in one or more of the following ways:

• To identify patients who may be suitable to be informed about a research study.
• To contact you about a research opportunity where appropriate.
• To support the safe and effective delivery of an approved research project.
• To collect and analyse information if you choose to take part in a study.

Will I be included automatically?

No. Taking part in research is entirely voluntary. If a study requires your participation, you will normally be provided with information about the study and asked for your consent before any research-specific information is collected or shared, unless another lawful basis applies under data protection legislation and research regulations.

Who may receive my information?

Where necessary, information may be shared with approved research organisations, NHS organisations, universities or other organisations responsible for conducting the research. Any sharing will be carried out in accordance with UK data protection legislation, confidentiality requirements and the approvals governing the research project.

Your choices

You are under no obligation to take part in any research study. Deciding not to participate will not affect the care or treatment you receive from the practice. If you are approached about a research study, you can decline or withdraw in accordance with the study information provided to you.

Further information

For more information about health and care research and opportunities to take part, please visit the NIHR’s Be Part of Research service:

https://bepartofresearch.nihr.ac.uk

Optional addition for research-active practices:

The practice may from time to time search its clinical records to identify patients who may be eligible for ethically approved research studies. Where appropriate, patients may be contacted with information about a study and invited to consider participation. Receiving information about a study does not mean you are required to take part. Participation is always voluntary.

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

NHS England

NHS England receives information from GP practices under legal powers to support planning, commissioning, public health, service improvement and approved research activities.

The full privacy notice can be found here: NHS England  Privacy Notice

NHS England has a legal duty to keep a list of all patients registered with GP Practices in England. This list is held in the National Health Application and Infrastructure Services (NHAIS) systems. These systems also hold data about patients registered with GPs in Wales and the Isle of Man. NHS England , and other service agencies around the country manage these systems on behalf of NHS England.

The data are used to provide Primary Care Support Services. NHS England has a contract with Capita Business Services Ltd, operating as Primary Care Support England (PCSE), to provide these services which include:

• Moving paper patient records between practices and into storage when patients leave or move practices.
• Storing paper records of unregistered and deceased patients
• Sending letters to patient to inform them of their NHS number when one is first allocated.
• Providing the cervical cytology call and recall administrative service on behalf of Public Health England
• delivering prior notification lists of patients eligible for screening to GPs.
• processing new patient registrations and de-registrations at GP practices to maintain accurate lists of numbers of patients at GP Practices
• Making payments to NHS Ophthalmic practitioners for NHS services provided
• Making payments to GP practices based on lists of registered patients, and specific payments for childhood vaccinations and immunisations.
• Writing to patients on behalf of Primary Care commissioners with regards to provision of primary care services or assignment to a GP Practice list.
• Writing to patients when they have been removed from their GP Practice list.
• Conducting audits and reconciliations of GP Practice lists to ensure list sizes are accurate.

The data from the National Health Application and Infrastructure Services( NHAIS) list, is used to update the Personal Demographics Service (PDS). This provides information for hospitals, Public Health England Cancer Screening Programmes, Child Health systems and other health providers making sure that they know their patients’ current GP Practice and can access other essential information such as the Summary Care Record.

NHS England Regional Local Teams (RLTs) and Integrated Care Board (ICB), (where delegated) may also undertake necessary processing of a limited subset of these data (e.g. patient name, address, postcode, and NHS number) for example when managing practice closures and list dispersals (the process used to allocate patients to neighbouring GP Practices). This processing is necessary to inform patients of their reregistration options and ‘Choice’ as required under the NHS Constitution.

Sources of the data: The data are transferred automatically from GP practice systems into the NHAIS systems. The data is also updated by Primary Care Support England after notifications from data subjects themselves.

The categories of personal data held on the systems are:

• Name – including any previous names, unless name changes are the result of adoption, gender reassignment or witness protection schemes.
• Current and historic addresses and whether the address is a registered nursing home
• Dates of Birth
• Gender
• Place of Birth
• NHS number
• Cervical Screening history
• Special allocation scheme status
• Current and Previous GP practice details
• GPs Banking details

Categories of recipients: Statistical information (numbers) produced from NHAIS systems is shared with other organisations to enable them to fulfil their statutory obligations, for example the Office of National Statistics, Public Health England, and local authorities for their public health purposes. Personal data may also be shared with the approval of NHS England’s Caldicott Guardian when he is assured that confidentiality is respected, for example when hospitals need to update their records for direct care purposes or to support specific research projects with ethical and or Health Research Authority approval.

Legal basis for processing: For GDPR purposes NHS England’s basis for lawful processing is Article 6(1)(e) – ‘…exercise of official authority…’. For special categories (health) data the basis is Article 9(2)(h) – ‘…health or social care…’

For more details relating to patient information available to NHSE see their privacy notice: www.england.nhs.uk/nhs-england-privacy-notice

Patient Participation Group (PPG)

We invite all patients at point of registration and opportunistically thereafter if they would like to be part of our Patient Participation Group.  Email addresses and contact details are kept securely for the purpose of communicating with the group about meetings and any other events or issues we would like the PPG’s opinion on.

Public Health

We share information about patients with Public Health England in relation to notifiable diseases (e.g. measles, salmonella), screening programmes (cervical cytology) and childhood immunisations.

Shred it

The practice uses shred it a document shredding service to securely dispose of confidential material

Risk Stratification

‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.

Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health.

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the W&NL Integrated Care Board. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from:

NHS England » Risk Stratification

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.  Please see below for more information on how to withdraw consent.

Safeguarding

To ensure that adult and child safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.

Summary Care Record (SCR)

The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reasons for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.

During the height of the pandemic changes were made to the Summary Care Record (SCR) to make additional patient information available to all appropriate clinicians when and where they needed it, to support direct patients care, leading to improvements in both care and outcomes.

These changes to the SCR will remain in place, unless you decide otherwise.

Regardless of your past decisions about your Summary Care Record preferences, you will still have the same options that you currently have in place to opt out of having a Summary Care Record, including the opportunity to opt-back in to having a Summary Care Record or opt back in to allow sharing of Additional Information.

You can exercise these choices by doing the following:

1.   Choose to have a Summary Care Record with all information shared. This means that any authorised, registered and regulated health and care professionals will be able to see a detailed Summary Care Record, including Core and Additional Information, if they need to provide you with direct care.

2.   Choose to have a Summary Care Record with Core information only. This means that any authorised, registered and regulated health and care professionals will be able to see limited information about allergies and medications in your Summary Care Record if they need to provide you with direct care.

3.   Choose to opt-out of having a Summary Care Record altogether. This means that you do not want any information shared with other authorised, registered and regulated health and care professionals involved in your direct care. You will not be able to change this preference at the time if you require direct care away from your GP practice. This means that no authorised, registered and regulated health and care professionals will be able to see information held in your GP records if they need to provide you with direct care, including in an emergency.

To make these changes, you should inform your GP practice or complete this form and return it to your GP practice.

Supporting Medicines Management

W&NL ICB uses pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the ICB medicines management team may provide support relating to obtaining medications on behalf of your GP Practice to support your care.

Supporting Locally Commissioned Services

ICBs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality. The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

Suspected Cancer

Data may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital NHS Foundation Trust, London North West Healthcare NHS Trust and University College London Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual patients.

Universal Care Plan (UCP – formerly CMC)

UCP is a platform which gives patients an opportunity to express their wishes about how and where they are treated. It enables all healthcare professionals to offer more personalised medical care, with full respect to each patient’s preferences.

Data Retention

We manage patient records in line with the Records Management Code of Practice which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.

Our partner organisations

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

• NHS Trusts
• Specialist Trusts
• GP Federations
• Independent Contractors such as dentists, opticians, pharmacists
• Private Health Sector Providers e.g. Bupa
• Voluntary Sector Providers e.g. carers centre
• Ambulance Trusts
• Integrated Care Boards
• Local Authorities e.g. social services
• Education Services e.g. school nurses
• Fire and Rescue Services
• Police
• Other ‘data processors’

We will not share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function. No information will ever be shared where we do not have a lawful basis to do so.

Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below).

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence.

 

Right to withdraw consent to share personal information (Opt- Out)

Patients

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.

There are two main types of opt-out.

Type 1 Opt-Out

A Type 1 Opt-Out allows you to object to your confidential patient information being shared by your GP practice outside the practice for purposes other than your individual care, such as certain research and planning activities. This does not affect the sharing of information needed for your direct care and treatment.

If you register a Type 1 Opt-Out:

·         Your GP practice will not share your confidential patient information for purposes where the Type 1 Opt-Out applies.

·         Information may still be shared where there is a legal requirement to do so or where another lawful exemption applies.

·         Your decision will not affect the care and treatment you receive from the NHS.

·         You can change your choice at any time by contacting the practice.

If you would like to register, review or withdraw a Type 1 Opt-Out, please contact the practice for further information

National Data Opt-Out

The NHS uses health and care information to improve services, support research, improve patient outcomes and plan future healthcare provision. Patients have the right to choose whether their confidential patient information is used for purposes beyond their individual care and treatment.

The National Data Opt-Out is a service that enables patients aged 13 or over to opt out of their confidential patient information being used for research and planning purposes where the National Data Opt-Out applies.

The National Data Opt-Out does not apply to the use of information for:

• Your direct care and treatment.
• Managing NHS services that provide your care.
• Safeguarding children or vulnerable adults.
• Communicable disease control and public health protection.
• Information that must be provided by law or under a court order.
• Information that has been effectively anonymised.

If you choose to opt out, your confidential patient information will still be used where there is an overriding legal requirement or where the National Data Opt-Out does not apply.

You can find further information and set your preference by visiting:

www.nhs.uk/your-nhs-data-matters

or by calling 0300 303 5678.

Gordon House Surgery supports the National Data Opt-Out programme and will apply patient choices in accordance with NHS guidance and legal requirements

Relationship Between Type 1 Opt-Out and National Data Opt-Out

The Type 1 Opt-Out only applies to information shared from GP practices. The National Data Opt-Out is a separate service that allows you to choose whether your confidential patient information held by NHS organisations is used for research and planning purposes where the National Data Opt-Out policy applies.

Type 1 Opt-Outs remain available; however, NHS England’s primary national mechanism for controlling the use of confidential patient information for research and planning purposes is the National Data Opt-Out service. Existing Type 1 Opt-Outs continue to be honoured where applicable.

Access to your information

Staff

You have the following rights in relation to the personal data we hold on you:

• The right to be informed about the data we hold on you and what we do with it
• The right of access to the data we hold on you
• The right for any inaccuracies in the date we hold on you, however they come to light to be corrected.  This is also known as “rectification”
• The right to have data deleted in certain circumstances. This is also known as “erasure”
• The right to restrict the processing of data.
• The right to transfer the data we hold on you to another party. This is also known as “portability”

If you wish to exercise any of these rights please speak to the Practice Manager

Subject Access Requests (Access to Your Personal Information)

Under UK data protection legislation, you have the right to request access to the personal information that we hold about you. This is known as a Subject Access Request (SAR).

You can ask for:

• A copy of your personal information held by the Practice.
• Information about how and why we use your personal information.
• Details of organisations with whom we have shared your information where appropriate.
• Information about the source of information we hold if it was not obtained directly from you.

How to Make a Subject Access Request

You can make a Subject Access Request by contacting the Practice in writing, by email or in person. While requests do not need to be made using a specific form, we may ask you to provide sufficient information to help us locate the records you require.

To protect confidentiality, we may ask for proof of identity before releasing any information.

Timescales

In most circumstances, we will respond to your request within one calendar month of receiving:

• Your request; and
• Any information required to verify your identity.

In certain circumstances, where requests are particularly complex or involve large amounts of information, the response period may be extended by up to a further two months. If this applies, we will inform you and explain the reasons for the extension.

Information That May Not Be Disclosed

In limited circumstances, information may be withheld where disclosure is permitted or required by law. This may include situations where:

• Disclosure would reveal information relating to another individual who has not consented to the disclosure.
• Disclosure would be likely to cause serious harm to the physical or mental health of any individual.
• Information is subject to a legal exemption under data protection legislation.

Where information is withheld, we will explain the reason unless we are legally prevented from doing so.

Access to Medical Records

Most requests for access to GP medical records are provided free of charge. However, a reasonable fee may be charged where requests are manifestly unfounded, excessive, or for multiple copies of the same information.

Where appropriate and technically possible, information may be provided electronically.

Children and Subject Access Requests

A child may make a Subject Access Request where they have sufficient understanding of what is being requested and are considered capable of making that decision. Where a child lacks capacity to make the request themselves, a person with parental responsibility may request access on their behalf, subject to applicable legal and confidentiality considerations.

Further Information

If you wish to make a Subject Access Request or have any questions about accessing your personal information, please contact the Practice using the details provided in this Privacy Notice.

If you are dissatisfied with how your request has been handled, you have the right to raise a concern with the Practice’s Data Protection Officer and, if necessary, lodge a complaint with the Information Commissioner’s Office (ICO)

Change of Details

Patients

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.

Staff

Please let your line manager know if there are any changes to your details so that our records for you are accurate and up to date.

Mobile telephone number

Patients

If you provide us with your mobile phone number, we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.

Notification

The Data Protection Act 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a data controller and our registration can be viewed online in the public register at: https://ico.org.uk/ESDWebPages/Entry/Z6820105

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Complaints

If you have concerns or are unhappy about any of our services, please contact the Practice Manager,

For independent advice about data protection, privacy and data-sharing issues, you can contact:

Phone: 0303 123 1113     Website: www.ico.gov.uk

The Information Commissioner                          

Wycliffe House

Water Lane

Wilmslow Cheshire SK9 5AF

Information we are required to provide you

Data Controller contact details	Gordon House Surgery, 78 Mattock Lane, Ealing, W13 9NZ
Data Protection Officer contact details	ICB-DPO-GP (NHS WEST AND NORTH LONDON INTEGRATED CARE BOARD) <wnlicb.icb-dpo-gp@nhs.net>
Purpose of the processing for the provision of your healthcare	To give direct health or social care to individual patients.   For example, when a patient agrees to a referral for direct care, such as to a hospital, relevant information about the patient will be shared with the other healthcare staff to enable them to give appropriate advice, investigations, treatments and/or care.   To check and review the quality of care. (This is called audit and clinical governance).

Lawful basis for processing for the provision of your healthcare	These purposes are supported under the following sections of the GDPR: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
	Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”
	Healthcare staff will also respect and comply with their obligations under the common law duty of confidence.
Purpose of the processing for medical research and to measure quality of care	Medical research and to check the quality of care which is given to patients (this is called national clinical audit).
Lawful basis for processing for medical research and to measure the quality of care	The following sections of the GDPR mean that we can use medical records for research and to check the quality of care (national clinical audits) Article 6(1)(e) – ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’.
	For medical research: there are two possible conditions.
	Either: Article 9(2)(a) – ‘the data subject has given explicit consent…’ Or: Article 9(2)(j) – ‘processing is necessary for… scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member States law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject’.
	To check the quality of care (clinical audit): Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’

Purpose of the processing to meet legal requirements	Compliance with legal obligations or court order.
Lawful basis for processing to meet legal requirements	These purposes are supported under the following sections of the GDPR: Article 6(1)(c) – ‘processing is necessary for compliance with a legal obligation to which the controller is subject…’ Article 9(2)(g) – ‘processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject; Schedule 1 part 2 of the Data Protection Act 2018 lists the substantial public interest conditions, of which paragraph 2 states data can be processed when the purpose is for the exercise of function conferred on a person by enactment or rule of law.
Purpose of the processing for National screening programmes	The NHS provides several national health screening programmes to detect diseases or conditions early such as cervical and breast cancer, aortic aneurysm and diabetes. The information is shared so that the correct people are invited for screening. This means those who are most at risk can be offered treatment.
Lawful basis for processing for National screening programmes	The following sections of the GDPR allow us to contact patients for screening. Article 6(1)(e) – ‘processing is necessary…in the exercise of official authority vested in the controller…’’ Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’
Lawful basis for processing for employment purposes	The following sections of GDPR allow us to process staff data in an employment capacity Article 6(1)(b) – ‘processing is necessary for compliance with a 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 in the field of employment … law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;’
Rights to object	You have the right to object to information being shared between those who are providing you with direct care. This will not affect your entitlement to care, but this may affect the care you receive – please speak to the practice. Any objection will be reviewed by the Practice and a decision taken on whether to uphold the request. The right to object is not an absolute right. In appropriate circumstances it is a legal and professional requirement to share information for safeguarding reasons. This is to protect people from harm. The information will be shared with the local safeguarding service

Right to access and correct	You have the right to access your medical record and have any errors or mistakes corrected. Please speak to a member of staff.  You have the right to request rectification of your record if you believe information contained within it is wrong. Information will only be deleted in very exceptional circumstances. In most instances the original information will be retained on the record noting the rectified information.
Retention period	GP medical records will be kept in line with the law and national guidance. Information on how long records are kept can be found at: www.digital.nhs.uk/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016 or speak to the practice.
Right to complain	You have the right to complain to the Information Commissioner’s Office. You may follow this link www.ico.org.uk/contact-us or call the helpline 0303 123 1113
Data we get from other organisations	We receive information about your health from other organisations who are involved in providing you with health and social care. For example, if you go to hospital for treatment or an operation the hospital will send us a letter to let us know what happens. This means your GP medical record is kept up-to date when you receive care from other parts of the health service.

Further Information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found at the links below.

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under the Data Protection Act 2018.

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programmes available to you, confidentiality, information and your right to complain if things go wrong. https://www.gov.uk/government/publications/the-nhs-constitution-for-england

Reviews of and Changes to our Privacy Notice

We will keep our Privacy Notice under regular review. This notice was last reviewed in October 2026