Privacy Policy

This is the privacy notice of Dundonald Medical Centre. In this document, “we”, “our”, or “us” refers to Dundonald Medical Centre,16 Church Street, Dundonald, BT16 2LN.

Telephone number: 028 9048 3100

This website collects some personal data from users, as stated in our website provider’s Privacy Policy.

The General Data Protection Regulation (GDPR) came in to force on May 2018, superseding the current Data Protection Act (1998).

Our Practice aims to ensure the highest standard of medical care for our patients, and we are committed to protecting and respecting your privacy. To do this we keep records about you, your health and the care we have provided, or plan to provide, to you. This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure. If you have any questions regarding this Privacy Policy please contact us at the address shown above.

Introduction

• This is a notice to inform you of our Policy concerning all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (personal information) and information that could not. In the context of the Law and this notice, ‘process’ means collect, store, transfer, use or otherwise act on information
• We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately
• We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party
• We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate
• Our Policy complies with UK Law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
• The Law requires us to tell you about your rights and our obligations to you with regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
• Except as set out below, we do not share, sell or disclose to a third party, any information collected through our website.

Registering for NHS care

• All patients who receive NHS care are registered on a national database
• This database holds your name, address, date of birth and NHS Number but it does not hold information about the care you receive 
• The database is held by Business Services Organisation (BSO) Northern Ireland organisation which has legal responsibilities to collect NHS data
• The BSO is responsible for providing data processing services to General Practice which they know to be secure.

More information can be found at: HSC Business or the phone number for general enquires at Business Services Organisation (BSO) Headquarters, 2 Franklin Street, Belfast BT2 8DQ. Telephone 030 0555 0113.

Data Protection Officer (DPO)

The Data Protection Officer is responsible for ensuring the Practice remains compliant at all times with Data Protection, Privacy & Electronic Communications Regulations, Freedom of Information Act and the Environmental Information Regulations. The Data Protection Officer shall:

• Lead on the provision of expert advice to the Practice on all matters concerning the Data Protection Act, compliance, best practice and setting and maintaining standards
• Inform and advise the organisation and its employees of their data protection obligations under the GDPR.
• Monitor the organisation’s compliance with the GDPR and internal data protection policies and procedures. This will include monitoring the assignment of responsibilities, awareness training, and training of staff involved in processing operations and related audits
• Advise on the necessity of data protection impact assessments (DPIAs), the manner of their implementation and outcomes
• Serve as the contact point to the data protection authorities for all data protection issues, including data breach reporting.

The DPO will be independent and an expert in data protection. The DPO will be the Practice’s point of contact with the Information Commissioner’s Office. The DPO can be contacted via the contact details at the top of this notice. Please address any requests for the attention of the Data Protection Officer (DPO).

Please contact the Data Protection Officer if:

• You have any questions about how your information is being held
• If you require access to your information or if you wish to make a change to your
• information
• If you wish to make a complaint about anything to do with the personal and healthcare
• information we hold about you
• Or any other query relating to this Policy and your rights as a patient.

Data Controller

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 the data controller and our registration can be viewed online in the public register at: Register of fee payers.

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

Lawful basis for processing

The legal basis will be

Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.”

And

Article 9(2)(h) “processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;”

Screening Programs

The NHS provides several national health screening programs to detect diseases or conditions earlier such as; cervical, bowel and breast cancer, aortic aneurysm. More information can be found at Public Health Services Screening. The information is shared so as to ensure only those who should be called for screening are called and/or those at highest risk are prioritised. 

Right to Object

You have the right to object to this processing of your data and to some or all of the information being shared with the recipients. For national screening programmes: you can opt so that you no longer receive an invitation to a screening programme by contacting the central screening office on 028 9063 1828. 

Retention periods

In accordance with the Health & Personal Social Services (General Medical Services Contracts) Regulations (NI) 2004, your GP medical records will be returned to the HSCB when you die or when you are no longer a patient of the Practice.The HSCB will retain records for 10 years after you die or if you emigrate.

How long do we keep patient data?

We will only retain your 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.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve these purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Complete medical records are returned to the Business Services Organisation (BSO) when a patient leaves the Practice or dies. At present digital records remain on our clinical system indefinitely.

Keeping your records up to date

GDPR requires that the information we hold about you is accurate and current. We rely on our patients to tell us if they have moved house, or had medical treatment abroad. For our part, we will update your medical records at each consultation with a doctor or a nurse (either face to face, or by telephone), and with any relevant information we receive from hospital, community or social services providers (e.g. new diagnoses, change in circumstances).

These are the ways we collect health data

New babies being registered with the Practice – a form from the Registrar of Births, Deaths and Marriages signed by a parent or legal guardian.

Other patients joining the Practice – medical records forwarded to us by the BSO from previous GPs or other healthcare providers.

Existing patients

• Letters received from other health service providers, eg hospitals, private consultants, community services etc which are scanned into patient records
• Computerised medical records added to by GP during consultations
• Patient notes added to patient records as a means of internal communication e.g. passing on requests for medications
• Medical notes added to by administrative staff, pharmacists, nursing staff following consultations or telephone calls  
• Reports written by GPs including reports written for solicitors, insurance companies, government departments etc.
• Copies of referral letters sent to other providers of medical services, e.g. hospitals, private consultants, community services etc.

Therefore it is important to keep us informed of your personal data changes during your relationship with us, and make its aware of any such changes.

The basis on which we process information about you

The Law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then, if required by Law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the GDPR.

Information we process because we have a contractual obligation with you

When you join our Practice, receive medical services from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes
• provide you with our services
• provide you with suggestions and advice about how to obtain the most from using our website.

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

About the personal information we use

We use personal information on different groups of individuals including: 
 

• Patients
   Staff
• 
   Contractors
• 
   Suppliers
• 
   Complainants, enquirers
• 
   Survey respondents
• 
   Professional experts and consultants
• Individual captured by CCTV.

The personal information we use includes information that identifies you like your name, address, date of birth and postcode.We also use more sensitive types of personal information, including information about racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic and biometric data, health; sex life or sexual orientation.The information we use can relate to personal and family details; education, training and employment details; financial details; lifestyle and social circumstances; goods and services; visual images; details held in the patient record; responses to surveys.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including job opportunities and our services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us in writing. However, if you do so, you may not be able to use our website or our services further.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do so after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our business or profession
• responding to unsolicited communication from you to which we believe you would expect a response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage business or professional risk
• protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

We are subject to the Law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Information we process may be categorised as special category data

Special category data is personal data which the GDPR says is more sensitive, and so needs more protection. For example information about an individuals:

• race
• ethnic origin
• health
• sex life or
• sexual orientation

Local information sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a local Healthcare Professional outside of your usual practice services, such as in an evening and weekend GP Out Of Hours Service, 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.

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 parts of your GP electronic patient record, or a secure system that enables them to view your full GP electronic patient record (e.g. EMIS remote consulting system).

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. 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).

Access to your own information

Access to your personal information

• At any time you may request to review or update personally identifiable information that we hold about you
• To obtain a copy of any information you may send us a request by email
• After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you

Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Who else may ask to access your Information

• The Court can insist that we disclose medical records to them
• Solicitors often ask for medical reports. These will always be accompanied by your signed consent for us to disclose information. We will not normally release details about other people that are contained in your records (e.g. wife, children parents etc.) unless we also have their consent
• Social Services – The Benefits Agency and others may require medical reports on you from time to time. These will often be accompanied by your signed consent to disclose information. Failure to cooperate with these agencies can lead to loss of benefit or other support. However, if we have not received your signed consent we will not normally disclose information about you
• Insurance Companies frequently ask for medical reports on prospective clients. These are always accompanied by your signed Consent Form. We will only disclose the relevant medical information as per your consent. You have the right, should you request it, to see reports prepared for Insurance Companies or employers before they are sent. We may contact you on receipt of a third party request to discuss your consent and clarify what will be shared
• If you have any questions about the above points please contact the Practice

Anyone who receives information from us also has a legal duty to keep it confidential and secure.

Specific uses of information you provide to us

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

NHS healthcare 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. Records we hold about you may include the following information:

• Details about you, such as your name, address, carers, legal representatives and emergency contact details
• 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 Healthcare Professionals, relatives or those who care for you

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP Practice for clinical audit to monitor the quality of the service provided. Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified.

Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose.

Disclosure and sharing of your information

Information we obtain from third parties

We sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.

Information provided on the understanding that it will be shared with a third party

We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the new information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that Health and Social Care Professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.

Who are our partner organisations?

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

• Other NHS Hospitals
• GPs
• Out of Hours Medical Services
• Independent Contractors such as Dentists, Opticians & Pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Northern Health & Social Care Trust Social Care Services
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Voluntary Sector Providers
• Private Sector Providers
• Other ‘data processors’ which you will be informed of

You will be informed who your data will be shared with, and in some cases asked for explicit consent for this to happen.

What to do if you don’t want your information shared

Please tell us if you don’t want your information to be shared – either in some or all circumstances. We can make a note on your record that will ensure that your records can only be accessed by a health professional in the Practice (i.e. no administrative staff will be able to look at your records) or we can block your health data so that it can’t be accessed by other health service bodies e.g. Electronic Care Record

Patient Rights (as the Data Subject)The right to erasure

The right to erasure is also known as “the right to be forgotten” and in general refers to an individual’s right to request the deletion or removal of personal information where there is no compelling reason for the Practice to continue using it.

As with other rights, there are particular conditions around this right and it does not provide individuals with an absolute right to be forgotten.

Individuals have the right to have their personal information deleted or removed in the following circumstances:

• When it is no longer necessary for the purpose for which it was collected.
• When the Practice no longer have a legal basis for using you your personal information, for example if you gave us consent to use your personal information in a specific way, and you withdraw your consent, we would need to stop using your information and erase it unless we had an overriding reason to continue to use it.
• When you object to the Practice using your personal information and there is no overriding legitimate interest for us to continue using it.
• If we have used your personal information unlawfully.
• If there is a legal obligation to erase your personal information for example by court order.

The Practice can refuse to deal with your request for erasure when we use your personal information for the following reasons:

• to comply with a legal obligation for the performance of a public interest task or exercise of official authority
• for public health purposes in the public interest
• archiving purposes in the public interest, scientific research historical researchor statistical purpose
• the exercise or defence of legal claims

The right to restrict processing

You have the right to control how we use your personal information in some circumstances. This is known as the right to restriction. When processing is restricted, the Practice is permitted to store your personal information, but not further use it until an agreement is reached with you about further processing. We can retain enough information about you to ensure that your request for restriction is respected in the future.

Examples of ways you can restrict our processing would be:

• If you challenge the accuracy of your personal information, stop using it until we check its accuracy
• If you object to processing which is necessary for the performance of our tasks in the public interest or for the purpose of legitimate interests, we will restrict our processing while we consider whether our legitimate grounds override your individual interests, rights and freedoms
• If our use of your personal information is found to be unlawful and you ask for restriction instead of full erasure we will restrict our processing
• If we no longer need your personal information but you need it to establish, exercise or defend a legal claim, we will restrict our processing.

If we have shared your personal information with any individuals or organisations, if we restrict our processing, we will tell those individuals or organisations about our restriction if it is possible and not an unreasonable amount of effort.
Whenever we decide to lift a restriction on processing we will tell you.

The right of access

Individuals have the right to access their personal data and a request can be made verbally or in writing. We have one month to respond to a request and in most circumstances we cannot charge a fee. Please refer to our Subject Access Request section for further information.

The right to rectification

The GDPR includes a right for individuals to have inaccurate personal data rectified or completed if it is incomplete. We have one month to respond to a request and in some circumstances, we may refuse this request.

The right to data portability

The right to data portability allows individuals to obtain and re-use their personal information for their own purposes across different services. It allows them to move, copy or transfer personal information easily from one IT environment to another in a safe and secure way. For example: it enables consumers to take advantage or applications and services which can use their information to find them a better deal.The right to data portability only applies when the individual has submitted their personal information directly, through electronic means to our Practice.This means that in most circumstances the right to data portability does not apply within the Practice.

Rights related to automated decision making and profiling

You have the right to object to any instances where a decision is made about you solely by automated means without any human involvement, including profiling.

The Practice does not undertake any decision-making about you using wholly automated means.

Invoking your rights

If you wish to invoke any of the data subject rights then please write to The Practice Manager, at the above address.

Confidentiality

All staff in the Practice sign a Confidentiality Agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty.

Please be aware that your information will be accessed by non-clinical Practice staff in order to perform tasks enabling the functioning of the Practice. These include, but are not limited to:

• typing referral letters to Hospital Consultants or allied Healthcare Professionals
• opening letters from Hospitals and Consultants
• scanning clinical letters, radiology reports and any other documents not available in electronic format
• photocopying or printing documents for referral to Consultants
• handling, printing, photocopying and postage of medical legal and insurance reports and of associated documents.

Public health

Public health encompasses everything from national smoking and alcohol policies, the management of epidemics such as flu, the control of large scale infections such as TB and Hepatitis B to local outbreaks of food poisoning or Measles. Certain illnesses are also notifiable; the doctors treating the patient are required by law to inform the Public Health Authorities, for instance Scarlet Fever.

This will necessarily mean the subjects personal and health information being shared with the Public Health organisations.

Some of the relevant legislation includes: the Health Protection (Notification) Regulations 2010 (SI 2010/659), the Health Protection (Local Authority Powers) Regulations 2010 (SI 2010/657), the Health Protection (Part 2A Orders) Regulations 2010 (SI 2010/658), Public Health (Control of Disease) Act 1984, Public Health (Infectious Diseases) Regulations 1988 and The Health Service (Control of Patient Information) Regulations 2002.

Processing of prescriptions

We process prescription requests on a daily basis. This involves our staff accessing information held about you on our computer database, to produce prescription(s) that you, your carer, nominated person or Pharmacy has requested. Prescriptions can be requested using various methods: by telephone, online via our computer system, by post, in writing, via fax (if available) or in person. Please refer to our Prescription Procedure for further information. If using the postal service always allow extra time so you do not run out of your medication.

Collection/uplift of prescriptions

We will always ask for your details when a prescription uplift request is received; this could be your name, date of birth and address, medication you requested, or Community Health Index Number (which uniquely identifies you). This ensures that we can produce your prescription(s) efficiently, and reduces the risk of an incorrect prescription being given to you or your nominated person/carer/Pharmacy.

Please allow the allotted time before uplifting your prescription. Prescriptions can be collected/sent via the following methods:

• In person
• Via your nominated choice of person/organisation, this could be your carer, pharmacy, family member or friend (please be aware that if you are not uplifting your own prescription we may ask for proof of identification from that person before we issue your prescription, and we may also require a signature for our own records)
• Post – if using the postal service, please always allow extra time when ordering your medication, as we cannot guarantee postal delivery schedules
• Home delivery service – some Pharmacies may deliver your prescription directly to your home; please check with your local Pharmacist to see if they can provide this service for you

Data Sharing

Data sharing schemes are active locally, enabling healthcare professionals outside of the Practice to view limited information from your GP record, with your explicit consent, should that need arise. These schemes include:

• The NI Electronic Care Record (NIECR) – is a computer system that health and social care staff can use to get information about your medical history. When treating or looking after you they will need to know about any allergies, long term health conditions or medicine you take. NIECR can only be accessed over the HSC secure network and patient data can only be accessed by authorised HSC staff who need to see it to support your care but there is no access to your GP consultation records.
• The Business Services Organisation (BSO) provides a broad range of regional business support functions and specialist professional services to the health and social care sector in Northern Ireland. This includes the management of patient registrations for General Practice. Changes to patient data are sent through the secure HSC network. Complete records are returned to BSO when a patient leaves the Practice or dies.
• Clinical Computer System supplier e.g,(EMIS) provides IT support and are authorised to access the clinical system to resolve any technical issues relating to patient data.
• BSO Probity Unit carry out regular inspections in General Practice and part of their role is to check the legitimacy of patient specific data in relation to claims made to the NHS by the Practice.
• Northern Ireland Medical and Dental Training Agency (NIMDTA) – medical representatives check the standard of clinical record keeping as part of their regular visits to us as a training Practice.
• Medical students may be working in the Practice and as part of their educational experience will have access to patient’s medical records. Patients will always be asked to consent to medical students attending consultations.
• You will be asked to consent before any information is shared with Community Pharmacies, for example, if you have registered for chemist collection of your prescriptions. Your consent will be required if you wish the Practice to provide prescriptions to a third party i.e. stoma care products.

Northern Ireland Electronic Care Record (NIECR)

• Healthcare staff working in A&E and out of hours care will also have access to your information. For example, it is important that staff who are treating you in an emergency know if you have any allergic reactions.This will involve the use of your Northern Ireland Electronic Care Record (NIECR). For more information see: Health and Care HSCNI or alternatively speak to your practice.

Emergency Care Summary Record

Information about your medicine and any allergies will be shared by your GP through the Emergency Care Summary, these will also be in your record on the NIECR. (Northern Ireland Electronic Care Record).

To read more information about the Emergency Care Summary system, go to:

• Emergency Care Summary Record

Only the staff caring for you will be able to look at your information on the NIECR and you will be asked for your permission first. An audit trail will check this. Please contact the Practice if you wish to opt out of the ECSR please let us know.

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.

Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Sending a message to our Practice Team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our Practice. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

CCTV

CCTV- if in use at this Practice, complies with the Information Commissioner’s Office CCTV Code of Practice. 

Call recording

Call recording if used by the Practice is for quality and training purposes. Calls are recorded to protect the interests of one or more participants, and for safety. We comply with GDPR requirements, for further information on our polices regarding call recording please write to the Practice.

Safeguarding

The Practice is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently and conscientiously applied with the wellbeing of all, at the heart of what we do. 

Our legal basis for processing For the General Data Protection Regulation (GDPR) purposes is: –

            Article 6(1)(e) ‘…exercise of official authority…’. 

For the processing of special categories data, the basis is: –

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

Complaining

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Use of information we collect through automated systems when you visit our website

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience, and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any cookies you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use our website
• to record whether you have seen specific messages we display on our website
• to keep you signed in our site
• to record your answers to Surveys and Questionnaires on our site while you complete them

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Clinical research

Sometimes your information may be requested to be used for research purposes – we will always ask your permission before releasing your information for this purpose.

We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.

Department for Work and Pensions

Our practice is legally required to provide anonymised data on patients who have been issued with a fit note under the Fit for Work scheme. The purpose is to provide the Department for Work and Pensions with information from Fit Notes to improve the monitoring of public health and commissioning and quality of health services.

Data may be processed outside the European Union

Our website is hosted in the United Kingdom.

We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the European Union.

For example online patient forms on our website are encrypted and delivered securely to the NHS system by an email service provider based in the United States of America. Their systems comply with provisions certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, a mechanism for cross border transfer of personal data.

Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

Use of our website by children

• If you are under 18, you may use our website only with consent from a parent or guardian
• We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children
• Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site information they find, wherever they visit

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

How you can complain

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything.  If you have any concerns about how your data is shared then please contact the Practice.

• If you are not happy with our Privacy Policy or if have any complaint then you should tell by writing to us
• If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration
• If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office, you can use this link : Contact ICO or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)The Information Commissioner’s Office – Northern Ireland
  3rd Floor
  14 Cromac Place,
  Belfast
  BT7 2JB
• Telephone: 028 9027 8757 / 0303 123 1114
  Email: [email protected]

Caldicott Guardian

The Caldicott Guardian/IG Lead is responsible for;

• Ensuring implementation of the Caldicott Principles and Data Security Standards with respect to Patient Confidential Data
• Ensuring that the Practice processes satisfy the highest practical standards for handling patient information and provide advice and support to Practice staff as required
• Ensuring that patient identifiable information is shared appropriately and in a secure manner. The Caldicott Guardian will liaise where there are reported incidents of person identifiable data loss or identified threats and vulnerabilities in Practice information systems to mitigate the risk.

The aim of the Caldicott Guardian is to ensure the organisation implements the Caldicott principles and data security standards; there is no need to appoint a Caldicott Guardian, but there is a need to have an Information Governance lead (sometimes referred to as a Caldicott lead) who, if they are not a clinician, will need support from a clinically qualified individual.

Opt-outs

You have a right to object to your information being shared. Should you wish to opt out of data collection, please contact a member of staff who will be able to explain how you can opt out and prevent the sharing of your information.

Compliance with the Law

Our privacy policy has been compiled so as to comply with the Law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

Further Information – Understanding patient data

Understanding Patient Data supports better conversations about the uses of health information. Our aim is to explain how and why data can be used for care and research, what’s allowed and what’s not, and how personal information is kept safe. We work with patients, charities and Healthcare Professionals to champion responsible use of data.

Download or view our Notice

Review of this Privacy Policy

We may update this Privacy Notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our Privacy Policy, please contact the Practice.