The Jubilee Street Practice Ltd is part of NHS North East London who are responsible for planning, designing, buying and paying for certain NHS services. These services include planned and emergency hospital care, mental health, rehabilitation, and community services. Patients have the right to have information about them processed fairly and lawfully, and to access any personal information held by the NHS. Patients also have the right to privacy, and expect the NHS to keep information confidential and secure. Patients have the right to request that their confidential information is not used for purposes other than their own care and treatment, and to have their objections considered. These rights are set out in the NHS Constitution.
Health care professionals, who provide your 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 are used to help to provide you with the best possible healthcare.
What information do we hold and how is this stored?
NHS health care 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 this GP Practice hold about you may include the following information:
- Details about you, such as your name, address, carer’s, legal representative 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 health professionals, relatives or those who care for you
- All incoming and outgoing telephone call recordings (unless you ask us to stop recording at any point during the call)
How long do we hold patient records for and what we do when you leave our practice.
A patient’s medical record usually goes with them from practice to practice, and is held indefinitely whilst still registered at that practice. When you register with a new practice, the practice will send a notification to the previous practice’s medical system to securely transfer the electronic records to the new practice.
At the same time, a notification is sent to NHS England of this. NHS England manages the safe collection of any paper records the patient might have from the previous practice, and transfers them to the new practice. Any sensitive patient data, such as documents that have been digitised or are duplicates, are destroyed using a GDPR compliant data shredding company.
When is my information shared and how do we maintain the confidentiality of your data?
Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. 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.
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection Act 2018 and General Data Protection Regulation 2018
- Human Rights Act 1998 • Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality, Information Security and Records Management
- Information: To Share or Not to Share Review
We will only use or pass on information about you to other health professionals if they have a genuine need for it to support your care. 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 Caldicotts' 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 Caldecott principles. They should be supported by the policies of their employers, regulators and professional bodies.
For example, your information may be shared in the following circumstances:
- To provide further medical treatment for you e.g. from district nurses and hospital services
- To help you get support from other services e.g. from social care or voluntary organisations
- When we have a duty to others e.g. in child protection cases
- Where we are required by law to share certain information such as the birth of a new baby, infectious diseases that may put you or others at risk or where a Court has decided we must.
Which other organisation’s may see my information?
We may also share your information, subject to strict agreements on how it will be used, with the following organisations:
- NHS Trusts / Foundation Trusts
- GPs
- NHS Commissioning Support Units
- Independent Contractors such as dentists, opticians, pharmacists
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services
- Health and Social Care Information Centre (HSCIC)
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Voluntary Sector Providers
- Private Sector Providers
You will be informed who your data will be shared with and in some cases asked for explicit consent for this happen when this is required. Some of your records are held centrally in what is called the Summary Care Record. You see online what information is held in your individual SCR. For more information on SCRs, you can visit https://digital.nhs.uk/services/summary-care-records-scr.
Access to personal information
You have a right under the Data Protection Act 2018 and General Data Protection Regulation 2018 to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. In order to request this, you need to do the following:
- Make your request in writing, via email (nelondonicb.jubileestreetpractice@nhs.net) or via post, to your registered GP – for information from the hospital you should write direct to them
- Give adequate information (full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located
We are required to respond to you within 30 days.
A copy of our complete Data Subject Access Request Policy is available here.
Change of Details
It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.
Notification
The Data Protection Act 2018 requires organisation’s to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information. This information is publicly available on the Information Commissioners Office website www.ico.org.uk
The practice is registered with the Information Commissioners Office (ICO).
Who is the Data Protection Officer?
The Data Protection Officer for the Practice is Ernest Attah via the NEL ICB commissioned IG support service.
Who is the Data Controller?
The Data Controller, responsible for keeping your information secure and confidential is:
The Jubilee Street Practice LTD, 368-374 Commercial Road, London E1 0LS.
Objections / Complaints
Should you have any concerns about how your information is managed at the GP, please contact the practice in writing. If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) via their website www.ico.gov.uk, casework@ico.org.uk , telephone: 0303 123 1113 (local rate) or 01625 545 745.
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.
We are the guardians of patient data, making sure it is protected and handled securely. We make sure data is only used for the good of health and care, and that patient data is always protected. We comply with the national data opt-out policy. We also provide advice to the health and care sector on keeping data safe.
Place section content here.The Jubilee Street Practice Ltd (the practice) needs to have a Data Protection Policy to demonstrate compliance with the General Data Protection Regulation (GDPR) and UK Data Protection Legislation. This policy sets out the general arrangements by which we will be compliant under the various Articles of GDPR and UK Data Protection Act 2018.
Lawful bases
Our lawful bases for processing your personal information are:
- UK GDPR Article 6(1)(c) - where processing is necessary for compliance with a legal obligation to which we are subject i.e. Health & Safety at Work etc. Act 1974 – to comply with our duty of care to protect our employees from harm;
UK GDPR Article 6(1)(f) - for the purposes of our legitimate interest (we can use ‘legitimate interests’ if we can demonstrate that the processing is for purposes other than for performing our tasks as a GP practice). In this context, our objectives include:
- Ensuring you receive a quality service from us
- To investigate and resolve a complaint
- Protecting our staff’s personal safety and welfare e.g. from abusive callers
- For the detection, investigation and prevention of crime (including fraud)
These objectives constitute our legitimate interests for call recording. A third party could reasonably expect and conclude to be subject to call monitoring in these specific situations. We have a Legitimate Interests Policy that sets out how this information will be handled.
Note that we may process your personal information on more than one lawful basis depending on the specific purpose for which we are using your information
We may process the following personal information:
- Special Category Personal Data as defined by UK GDPR Article 9(1) e.g. health, pursuant to UK GDPR Article 10 and Data Protection Act 2018, section 10(5), Schedule 1, Part 2 paragraph 6(1) and 2(a) – processing is necessary for reasons of substantial public interest; and
- Criminal Offence Data as defined by UK GDPR Article 10 and supplemented by the Data Protection Act 2018, section 11(2), Schedule 1, Part 2 paragraph10(1) (preventing or detecting unlawful acts).
We have a Data Protection Policy, which sets out how this information will be handled.
Data sharing - your information will be shared with the relevant staff members and if you have requested and/or complained about our service, may also be shared with our external service provider (where we have outsourced the service). We may also share your information with a number of other organisations for example Tower Hamlets Council’s social services where we have concerns about your and/or another individual’s well- being.
We rely on a number of exemptions, which allow us to share information without needing to comply with all the rights and obligations under the Data Protection Act 2018. Please refer to the Information Agreement for further details on our sharing arrangements.
Retention period - we keep your personal information for the minimum period necessary. The information outlined in this Privacy Notice will be kept in accordance with the retention period(s) referred to in our Information Asset Registers unless exceptional circumstances require longer retention e.g. a pending court case. All information will be held securely and disposed of confidentially.
Anonymisation - your personal information may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Aggregated data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports such as showing the number of complaints we receive and/or equalities monitoring, but not in a form which identifies anyone.
Right to object - where processing your personal information is required for the purposes of our legitimate interests (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.
You may request that your call is not recorded. In this situation, you will be advised to contact us by letter or email.
Changes to this Privacy Notice - we review this Privacy Notice regularly and will place updates on our website.
Please refer to our Corporate Privacy Notice for further details of how we process your personal information and for details on your additional rights.
If you wish to read any of the policies or notices that have been mentioned in this section, please see the the Policies and Notices section where you can download and read these documents.
If you have any questions about this article, please email nelondonicb.jubileestreetpractice@nhs.net or visit the practice, where a member of staff can answer any questions.
To help GP practices to become compliant with the national data opt-out, the four principal GP system suppliers have been commissioned to develop and embed the service into their clinical systems. Patients are able to submit their preference by completing a form on the government website : https://www.nhs.uk/using-the-nhs/about-the-nhs/opt-out-of-sharing-your-health-records/. Once we receive notification we code this in our patients records.