Privacy Notice – GDPR

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information may be used and how we keep it safe and confidential.

Why we collect information about you

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.

We collect and hold data for the sole purpose of providing healthcare services to our patients. In carrying out this role we may collect information about you which helps us respond to your queries or secure specialist services. 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.

Data we collect about you

Records which this GP Practice will hold or share about you will include the following:

  • Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
  • Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.
  • Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
  • Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place
  • Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

Details we collect about you

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

Records which this GP Practice may hold about you may 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 those who care for you

How we keep your information confidential and safe

Everyone working for the NHS is subject to the Common Law Duty of Confidentiality. 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 Digital Code of Practice on Confidential Information applies to all our 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 annual training on how to do this.

NHS health records 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 1998
  • Human Rights Act
  • Common Law Duty of Confidentiality
  • NHS Codes of Confidentiality and Information Security
  • Health and Social Care Act 2015

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), 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 the purpose of 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.

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

  • improving the quality and standards of care provided
  • research into the development of new treatments
  • preventing illness and diseases
  • monitoring safety
  • planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in the table below.

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures.

Individuals Rights under the Data Protection Act 2018

Under DPA 2018 the Law provides the following rights for individuals. The NHS upholds these rights in a number of ways.

  • 1. The right to be informed
  • 2. The right of access
  • 3. The right to rectification
  • 4. The right to erasure (not an absolute right) only applies in certain circumstances
  • 5. The right to restrict processing
  • 6. The right to data portability
  • 7. The right to object
  • 8. Rights in relation to automated decision making and profiling.

Your right to opt out of data sharing and processing

The NHS Constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’.

Type 1 Opt Out

This is an objection that prevents an individual’s personal confidential information from being shared outside of the general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to apply a Type 1 Opt Out to your record please make your wishes known to the Practice Manager.

National data opt-out

The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.

By 2020 all health and care organisations are required to apply national data opt-outs where confidential patient information is used for research and planning purposes. NHS Digital has been applying national data opt-outs since 25 May 2018. Public Health England has been applying national data opt-outs since September 2018.

The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to: www.digital.nhs.uk/national-data-opt-out

To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters

On this web page you will:

  • See what is meant by confidential patient information
  • Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
  • Find out more about the benefits of sharing data
  • Understand more about who uses the data
  • Find out how your data is protected
  • Be able to access the system to view, set or change your opt-out setting
  • Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
  • See the situations where the opt-out will not apply

Right of Access to your information (Subject Access Request)

Under Data Protection Legislation everybody has the right to have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access and you may find information has been redacted or removed for the following reasons;

  • Does not cause harm to the patient
  • That legal confidentiality obligations for the non-disclosure of third-party information are adhered to

You do not need to give a reason to see your data. And requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require.

Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the extra copies.

You will need to provide proof of identity to receive this information.

Change of Details

It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.

Mobile telephone number

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

Email address

Where you have provided us with your email address we may use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email please let us know.

Notification

Data Protection Legislation 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: www.ico.org.uk/register-of-fee-payers

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

What is the right to know?

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However you can request this under a right of access request – see section above ‘Right of Access to your information’.

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:

The Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

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

Further Information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found here:

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 1998.
www.systems.digital.nhs.uk/nhscrg.pdf

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.

www.gov.uk/the-nhs-constitution-for-england

NHS Digital

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

www.content.digital.nhs.uk/What-we-collect

Reviews of and Changes to our Fair Processing Notice

We will keep our Fair Processing Notice under regular review. This notice was last reviewed in May 2018.

The Practice will share your information with these organisations where there is a legal basis to do so:

 

Activity

Details

CCG Purpose – Anonymous data is used by the CCG for planning and performance as directed in the practices contract.

Legal Basis – Contractual

Processor – Gloucestershire Clinical Commissioning Group

JUYI – Joining Up Your Information Purpose – JUYI is the secure online system for sharing information in Gloucestershire, giving local health and social care professionals directly involved in your care instant access to your health and social care records.

Sharing your electronic records with the people who look after you gives them the most up-to-date information about you and makes your care safer and more efficient and cost effective.

For information about the county’s JUYI shared care record and fair processing notice: www.juyigloucestershire.org

Legal Basis – Direct Care

Summary Care Record (SCR) Purpose – 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.

Legal Basis – Direct Care

Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, phone. If you wish to opt-out of having an SCR please return a completed opt-out form to the practice.

Processor – NHS England and NHS Digital

Research Purpose – We manly share personal confidential or anonymous information with research companies. Where you have opted out of having your identifiable information shared for this purpose your information will be removed.

Legal Basis – consent is required to share confidential patient information for research, unless there is have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales

Processor – Various organisations may be involved in Research

Individual Funding Requests Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our contracts.

Legal Basis – The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time

Data processor – Healthcare Professionals

Child Health Information Service Purpose – 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 health visitors and school nurses.

Legal Basis – Direct Care

Data Processor – Health Intelligence, on behalf of NHS England

Safeguarding Adults Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns.

Legal Basis – Because of public Interest issues, e.g. to protect the safety and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.

Data Processor – Gloucestershire Safeguarding Adults Board (GSAB

Safeguarding Children Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns.

Legal Basis – Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.

Data Processor – Gloucestershire Safeguarding Children Board (GSCB

Risk Stratification – Preventative Care Purpose – ‘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.

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.

Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data

Legal Basis

GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2020 NHS England Risk Stratification which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.

Processors – Healthcare Professionals

Public Health

Screening programmes (identifiable)

Notifiable disease information (identifiable)

Smoking cessation (anonymous)

Sexual health (anonymous)

Purpose – Personal identifiable and anonymous data is shared.

The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.

More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes [Or insert relevant link] or speak to the practice

Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

Processors – Gloucestershire Hospitals NHS Foundation Trust; Gloucestershire Care Services NHS Trust; 2gether NHS Foundation Trust; South Western Ambulance Service NHS Foundation Trust

NHS Trusts Purpose – Personal information is shared with other secondary care trusts in order to provide you with direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.

Legal Basis – The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions as stated below:

Processors – Gloucestershire Hospitals NHS Foundation Trust; Gloucestershire Care Services NHS Trust; 2gether NHS Foundation Trust; South Western Ambulance Service NHS Foundation Trust

Care Quality Commission Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.

More detail on how they ensure compliance with data protection law (including GDPR) and their privacy statement is available on our website: www.cqc.org.uk/privacy-statement

Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below

Processors – Care Quality Commission

Payments, Invoice Validation Purpose – Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non-patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.

Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below

Data Processors – NHS England, CCG, Public Health

Patient Record data base Purpose – Your medical record will be shared, in order that a data base can be maintained and managed in a secure way

Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

Processor – TPP SystmOne

iGPR Purpose – Your medical record will be shared in order that a report can be provided to agencies such as insurance companies or solicitors

Legal Basis – Your consent will be required to share your record for this purpose

Processor – iGPR

AccurRX Purpose – AccuRX will process data about patients to allow the GP practice to provide a service to patients. It can be used to send advice, notify a patient of normal results, remind them to book appointments, leave a message if the practice fails to get through.  Provide two way texting, with patients having the ability to reply once. Video Conferencing between Clinician and Patient.

Legal Basis: For processing Personal Data: GDPR 6(1)(e) ‘processing is necessary for the performance of a task carried out in the exercise of official authority vested in the controller.’

For processing Special Category Data (e.g. health): GDPR 9(2)(h) ‘processing is necessary for the purposes of preventive medicine, the provision of health care, and the management of health or social care systems.’

Common law duty of confidentiality:  The use of patients’ confidential information will be for providing care and will be on the basis of implied consent.

Processor: AccuRX

eConsult Purpose – eConsult enables NHS based GP practices to offer online consultations to their patients. This allows patients to submit their symptoms or requests to their own GP electronically, and offers around the clock NHS self-help information, signposting to services, and a symptom checker.

eConsult will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Legal Basis – For processing Personal Data: GDPR 6(1)(e) ‘processing is necessary for the performance of a task carried out in the exercise of official authority vested in the controller.’

For processing Special Category Data (e.g. health): GDPR 9(2)(h) ‘processing is necessary for the purposes of preventive medicine, the provision of health care, and the management of health or social care systems.’

Common law duty of confidentiality:  The use of patients’ confidential information will be for providing care and will be on the basis of implied consent.

Processor – Electronic consultations are run by eConsult Health Limited

Medicines Management Team Purpose – your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes can be implemented.

Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

Processor – Gloucester Inner City Primary Care Network; Partners in Health, Gloucester City Health Centre, Kingsholm Surgery, Gloucester Health Access Centre.

Mental Health provider Purpose – For the provision of mental health services

Legal Basis – Direct Care

Processor – 2gether NHS Foundation Trust

Clinical Audit (including Primary Care Data Extraction Process (PCDES)) Purpose – Information will be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long terms conditions. When required, information will 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.

Legal Basis – 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…’

Processor – Gloucestershire Clinical Commissioning Group; Sollis

Department for Work and Pensions Purpose – Our practice is legally required to provide limited data to the Department for Work and Pensions for the management of the social care system and fraud prevention.

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

Processor – Department for Work & Pensions

National Fraud Initiative – Cabinet Office Purpose – The use of data by the Cabinet Office for data matching is carried out with statutory authority. It does not require the consent of the individuals concerned under Data Protection legislation. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see: https://www.gov.uk/government/publications/code-of-data-matching-practice-for-national-fraud-initiative

Legal Basis – Part 6 of the Local Audit and Accountability Act 2014

National Registries Purpose – 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.

Legal Basis – Section 251 of the NHS Act 2006

Supporting Medicines Management Purpose – CCGs operate 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 CCG medicines optimisation team may order medications on behalf of your GP Practice to support your care.

Legal Basis – Direct Care

Processor – Healthcare Professionals

Supporting Locally Commissioned Services Purpose – CCGs 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.

Legal Basis – Anonymised Data

Police Purpose – The police may request information in relation to on-going enquiries, all requests are reviewed and only appropriate information will be shared under legislation.

Legal Basis – 9(2) (c) Vital Interests

9(2) (f) Legal claims or judicial acts

9(2) (g) Reasons of substantial public interest (with a basis in law)

Processor – Police

Coroners Purpose – A Coroner’s office may request copies of information in relation to a deceased individual. The practice will share relevant information in relation to the request

Legal Basis – Coroners and Justice Act 2009

Processor – Coroner

Subject Access Requests Purpose – Personal information will be shared with the person or their representative at their request

Legal Basis – Contractual agreement with the patient – and consented

Processor – Patients and or their representatives – e.g. family members, solicitors, insurance companies

Medical Reports Purpose – Personal information will be shared with Insurance companies, or potential or active employers at the patients request

Legal Basis – Consented

Processor – Patients and or their representatives – e.g. Insurance companies, RAF, Navy

Private Healthcare Providers As an example Nuffield Health, Winfield Ramsay
Away From My Desk Purpose – As part of COVID-19 planning, a Remote Access Solution will be deployed to enable staff working at GP Practices to remotely access their desktop PCs, negating the need to enter the premises. They will be able to access their business and clinical applications as if they were on-site, enabling staff who may have to work from home, because of self-isolation protocols or surgery lockdown, to remain productive and continue with business / clinical operations during the COVID-19 emergency.

Legal Basis: For processing Personal Data: GDPR 6(1)(e) ‘processing is necessary for the performance of a task carried out in the exercise of official authority vested in the controller.’

For processing Special Category Data (e.g. health): GDPR 9(2)(h) ‘processing is necessary for the purposes of preventive medicine, the provision of health care, and the management of health or social care systems.’

Common law duty of confidentiality:  The use of patients’ confidential information will be for providing care and will be on the basis of implied consent.

Processor – GP Practice via end to end connectivity from the ‘Away from My desk’ browser which is encrypted. No data from applications on the target machine is processed by ‘Away from my Desk’.

Medicines Optimisation in Care Homes (MOCH) Purpose – The MOCH project is being undertaken as part of the NHS England MOCH programme initiative, details of which are available on the NHSE website at: www.england.nhs.uk/medicines-optimisation-in-care-homes-programme-overview

The project aims to spread the successful work of pilot sites across care home nationally from the provision of an additional level of resource and expertise for the purpose of maximising the benefits that patients obtain from their medicines, including minimising the risk of adverse effects.

For Gloucestershire Integrated Care System (ICS) the project involves the NHSE funded provision of 2.2 wte clinical pharmacists (provided by 5 pharmacists) and 0.7 wte pharmacy technicians (provided by 2 technicians) for the purposes of:

  • Undertaking reviews of the efficiency of medicines ordering and supplying processes in care homes across Gloucestershire and
  • Undertaking individual medication reviews of care home patients aimed at optimising patient care.

Legal Basis: For processing Personal Data: GDPR 6(1)(e):  “processing is necessary for the performance of a task carried out in the exercise of official authority vested in the controller.”

For processing Special Category Data (e.g. health):  GDPR 9(2)(h) “processing is necessary for the purposes of preventive medicine, the provision of health care, and the management of health or social care systems.”

Confidentiality:

The provision of direct care by the MOCH pharmacists to patients is on the basis of implied consent.

Processor: CCG Employed MOCH pharmacists and technicians

Transfer of Risk Factor Data between GP systems in Gloucestershire and the Gloucestershire Diabetic Eye Screening Programme based at GHNHSFT Purpose: Professor Scanlon is the Clinical Director for the Gloucestershire Diabetic Eye Screening Programme.  There are approximately 50,000 patients of Gloucestershire GP practices on his list to invite for screening. The practices provide his team with the NHS numbers and demographic data of all of these patients so that they can invite them for screening via the GPES extraction service for GP2DRS.

Professor Scanlon has requested to have access to risk factor data held in the primary care record to work out a risk stratified approach to invitations for screening. He wants to know what priority to call them in for appointments based on certain criteria.

Legal Basis: The personal data will be processed for the purpose of providing health care to individual patients. The location where Customer Data will be processed within the AWS Network will be hosted within the eu-west-2 region (London).

Duty of confidentiality is satisfied by patients having a reasonable expectation that their relevant health information will be shared with the appropriate health providers.

Specific Article 6 GDPR Condition(s) satisfied:

Art. 6 (1) (e) For the performance of a task carried out in the public interest or in the exercise of official authority (for health or social care purposes)

For processing Special Category Data (e.g. health):  GDPR 9(2)(h) ‘the provision of health or social care’

Processor:

GPs, GHFT and GCCG are joint controllers for the risk stratification purpose.

AWS will be the Processor.

Anti Coagulation Data Base

 

Purpose: Personal confidential data is shared with the INR database in order to provide certain patients who meet the criteria with an anticoagulation service. Data is held on the data base and can be accessed by the practice.

Legal Basis: Under UK GDPR Article 6 1 (e) Public Task

And Article 9 2 (h) Health data

Processor: LumiraDx

ACR project for patients with diabetes

 

The data is being processed for the purpose of delivery of a programme, sponsored by NHS Digital, to monitor urine for indications of chronic kidney disease (CKD) which is recommended to be undertaken annually for patients at risk of chronic kidney disease e.g., patients living with diabetes. The programme enables patients to test their kidney function from home. We will share your contact details with Healthy.io to enable them to contact you and confirm that you wish them to send you a test kit. This will help identify patients at risk of kidney disease and help us agree any early interventions that can be put in place for the benefit of your care. Healthy.io will only use your data for the purposes of delivering their service to you. If you do not wish to receive a home test kit from Healthy.io we will continue to manage your care within the Practice. Healthy.io are required to hold data we send them in line with retention periods outlined in the Records Management code of Practice for Health and Social Care. Further information about this is available at http://bit.ly/uACRtest.