Policies

Privacy Notice

Read our policy here or below.

Your information, what you need to know

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

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

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

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. from Hospitals, GP Surgeries, A&E, etc.).
These records help to provide you with the best possible healthcare.
Records which this GP Practice may hold about you include the following:
 Details about you, such as your address and next of kin
 Any contact the surgery has had with you, such as appointments, clinic visits,
emergency appointments, etc.
 Notes and reports about your health
 Details about your treatment and care
 Results of investigations, such as laboratory tests, x-rays, etc.
 Relevant information from other health professionals, relatives or your carers
How we keep your information confidential and safe
Everyone working for our organisation is subject to the Common Law Duty of Confidence.
Information provided in confidence will only be used for the purposes advised with consent given
by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of
Practice on Confidential Information applies to all NHS staff and they are required to protect your
information, inform you of how your information will be used, and allow you to decide if and how
your information can be shared. All our staff are expected to make sure information is kept
confidential and receive regular training on how to do this.

St Johns Wood Medical Practice
The health records we use may be electronic, on paper or a mixture of both, and we use a
combination of working practices and technology to ensure that your information is kept
confidential and secure. Your records are backed up securely in line with NHS standard
procedures. We ensure that the information we hold is kept in secure locations, is
protected by appropriate security and access is restricted to authorised personnel.
We also make sure external data processors that support us are legally and contractually bound to
operate and prove security arrangements are in place where data that could or does identify a
person are processed.

We are committed to protecting your privacy and will only use information collected lawfully in
accordance with:
 Data Protection Act 2018
 Human Rights Act
 Common Law Duty of Confidentiality
 NHS Codes of Confidentiality and Information Security
 Health and Social Care Act 2015
 And all applicable legislation
We maintain our duty of confidentiality to you at all times. We will only ever use or pass on
information about you if we reasonably believe that others involved in your care have a genuine
need for it. We will not disclose your information to any third party without your permission
unless there are exceptional circumstances (such as a risk of serious harm to yourself or others) or
where the law requires information to be passed on.
How we use your information
Improvements in information technology are also making it possible for us to share data with
other healthcare organisations for providing you, your family and your community with better
care. For example, it is possible for healthcare professionals in other services to access your record
with your permission when the practice is closed. This is explained further in the Local Information
Sharing section below.
Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal
confidential data from GP Practices without seeking patient consent for a number of specific
purposes, which are set out in law. These purposes are explained below.
You may choose to withdraw your consent to personal data being shared for these purposes.
When we are about to participate in a new data-sharing project we aim to display prominent
notices in the Practice and on our website four weeks before the scheme is due to start.
Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme.
Please be aware that it may not be possible to opt out of one scheme and not others, so you may
have to opt out of all the schemes if you do not wish your data to be shared.
You can object to your personal information being shared with other healthcare providers but
should be aware that this may, in some instances, affect your care as important information about
your health might not be available to healthcare staff in other organisations. If this limits the
treatment that you can receive then the practice staff will explain this to you at the time you
object.

To ensure you receive the best possible care, your records are used to facilitate the care you
receive. Information held about you may be used to help protect the health of the public and to
help us manage the NHS.
Child Health Information
We wish to make sure that your child has the opportunity to have immunisations and health checks
when they are due. We share information about childhood immunisations, the 6-8 week new baby
check and breast-feeding status with NHS CLCH health visitors and school nurses, and with NWL
Commissioning Support Unit, who provide the Child Health Information Service on behalf of NHS
England.
Clinical audit
Information may be used by the CCG for clinical audit to monitor the quality of the service provided to
patients with long terms conditions. Some of this information may be held centrally and used for
statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to
ensure that individual patients cannot be identified from the data.
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.
Improving Diabetes Care and long-term condition management
Information that does not identify individual patients is used to enable focussed discussions to take
place at practice-led local diabetes and long term condition management review meetings between
health care professionals. This enables the professionals to improve the management and support
of these patients.
Individual Funding Request
An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for
funding of specialised healthcare which falls outside the range of services and treatments that CCG has
agreed to commission for the local population. An Individual Funding Request is taken under
consideration when a case can be set out by a patient’s clinician that there are exceptional clinical
circumstances which make the patient’s case different from other patients with the same condition
who are at the same stage of their disease, or when the request is for a treatment that is regarded as
new or experimental and where there are no other similar patients who would benefit from this
treatment. A detailed response, including the criteria considered in arriving at the decision, will be
provided to the patient’s clinician.
Invoice Validation
Invoice validation is an important process. It involves using your NHS number to check which CCG is
responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal
basis to process data for invoice validation purposes. We can also use your NHS number to check
whether your care has been funded through specialist commissioning, which NHS England will pay for.
The process makes sure that the organisations providing your care are paid correctly.

Local Information Sharing
Your GP electronic patient record is held securely and confidentially on an electronic system managed
by your registered GP practice. If you require attention from a local health or care professional outside
of your usual practice services, such as in an Evening and Weekend GP HUB services, Emergency
Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able
to give you safe and effective care if some of the information from your GP record is available to them.
If those services use a TPP clinical system your full SystmOne medical record will only be shared with
your express consent.
Where available, this information can be shared electronically with other local healthcare providers via a
secure system designed for this purpose. Depending on the service you are using and your health needs, this
may involve the healthcare professional accessing a secure system that enables them to
view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system
that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or 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).
National Fraud Initiative – Cabinet Office
The use of data by the Cabinet Office for data matching is carried out with statutory authority under
Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals
concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a
Code of Practice. For further information see:
https://www.gov.uk/government/publications/code-of-data-matching-practice-for-national-fraudinitiative
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.
Risk Stratification
‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may
be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services
(such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of
suffering a particular condition and enable us to focus on preventing ill health before it develops.
Information about you is collected from a number of sources including NHS Trusts, GP Federations and
your GP Practice. A risk score is then arrived at through an analysis of your de-identified information.
This can help us identify and offer you additional services to improve your health.
Risk-stratification data may also be used to improve local services and commission new services,
where there is an identified need. In this area, risk stratification may be commissioned by the NWL
Clinical Commissioning Groups. Section 251 of the NHS Act 2006 provides a statutory legal basis to
process data for risk stratification purposes. Further information about risk stratification is
available from: https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification /

If you do not wish information about you to be included in any risk stratification programmes, please
let us know. We can add a code to your records that will stop your information from being used for
this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if
you have or are at risk of developing certain serious health conditions.
Safeguarding
To ensure that adult and children’s safeguarding matters are managed appropriately, access to
identifiable information will be shared in some limited circumstances where it’s legally required for the
safety of the individuals concerned.
Summary Care Record (SCR)
The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support
patient care. It contains key information from your GP record. Your SCR provides authorised healthcare
staff with faster, secure access to essential information about you in an emergency or when you need
unplanned care, where such information would otherwise be unavailable.
Summary Care Records are there to improve the safety and quality of your care. SCR core information
comprises your allergies, adverse reactions and medications. An SCR with additional information can
also include reason for medication, vaccinations, significant diagnoses / problems, significant
procedures, anticipatory care information and end of life care information. Additional information can
only be added to your SCR with your agreement.
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, fax or phone. If you wish to optout of having an SCR please return a completed opt-out form to the practice.
Supporting Medicines Management
NWL CCGs use 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 management team may provide
relating to obtaining medications on behalf of your GP Practice to support your care.
Supporting Locally Commissioned Services
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.
Suspected Cancer
Data may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal
Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital
NHS Foundation Trust, London North West Healthcare NHS Trust and University College London
Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of
illness. Measures are taken to ensure the data for analysis does not identify individual patients.

Data Retention
We manage patient records in line with the Records Management NHS Code of Practice for Health
and Social Care which sets the required standards of practice in the management of records for
those who work within or under contract to NHS organisations in England, based on current legal
requirements and professional best practice.
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:
 NHS Trusts
 Specialist Trusts
 GP Federations
 Independent Contractors such as dentists, opticians, pharmacists
 Private Sector Providers
 Voluntary Sector Providers
 Ambulance Trusts
 Clinical Commissioning Groups
 Social Care Services
 Local Authorities
 Education Services
 Fire and Rescue Services
 Police
 Other ‘data processors’
Specific details of the organisations with whom we share your data can be seen here:
Central London – http://www.centrallondonccg.nhs.uk/what-we-do/your-patient-record.aspx
We will never share your information outside of health partner organisations without your explicit
consent unless there are exceptional circumstances such as when the health or safety of others is
at risk, where the law requires it or to carry out a statutory function.
Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above
mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management,
Summary Care Record – we will assume you are happy to for your information to be shared unless
you choose to opt-out (see below).
This means you will need to express an explicit wish to not have your information shared with the
other organisations; otherwise it will be automatically shared. We are required by law to report
certain information to the appropriate authorities. This is only provided after formal permission has
been given by a qualified health professional. There are occasions when we must pass on
information, such as notification of new births, where we encounter infectious diseases which may
endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a
formal court order has been issued. Our guiding principle is that we are holding your records in
strictest confidence.

Right to withdraw consent to share personal information (Opt- Out)
If you are happy for your data to be extracted and used for the purposes described in this privacy
notice then you do not need to do anything. If you do not want your information to be used for
any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please
let us know so we can code your record appropriately. We will respect your decision if you do not
wish your information to be used for any purpose other than your care but in some circumstances
we may still be legally required to disclose your data.
There are two main types of opt-out.
Type 1 Opt-Out
If you do not want information that identifies you to be shared outside the practice, for purposes
beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal
confidential information from being used other than in particular circumstances required by law,
such as a public health emergency like an outbreak of a pandemic disease.
Type 2 Opt-Out
NHS Digital collects information from a range of places where people receive care, such as
hospitals and community services. If you do not want your personal confidential information to be
shared outside of NHS Digital, for purposes other than for your direct care, you can register a ‘Type
2 Opt-Out’. For further information about Type 2 Opt-Outs, please contact NHS Digital Contact
Centre at enquiries@hscic.gov.uk referencing ‘Type 2 Opt-Outs – Data Requests’ in the subject line;
or call NHS Digital on (0300) 303 5678; or visit the website
http://content.digital.nhs.uk/article/7092/Information-on-type-2-opt-outs
If you wish to discuss or change your opt-out preferences at any time please contact the Practice
Manager.
NHS Digital is developing a new system to give you more control over how your identifiable
information is used. Details on the national data opt-out may be found at
https://digital.nhs.uk/services/national-data-opt-out-programme
Access to your information
Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we
hold that can identify you, with some exceptions. You do not need to give a reason to see your
data. If you want to access your data you must make the request in writing. Under special
circumstances, some information may be withheld.
If you wish to have a copy of the information we hold about you, please contact the Practice
Manager.
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 are incorrect in order for this to be amended. Please
inform us of any changes so our records for you are accurate and up to date.

Mobile telephone number
If you provide us with your mobile phone number we may use this to send you reminders about
your appointments or other health screening information. Please let us know if you do not wish to
receive reminders on your mobile.
Notification
The Data Protection Act 2018 requires organisations to register a notification with the Information
Commissioner to describe the purposes for which they process personal and sensitive information.
We are registered as a data controller and our registration can be viewed online in the public
register at: http://ico.org.uk/what_we_cover/register_of_data_controllers
Any changes to this notice will be published on our website and in a prominent area at the
Practice.
Complaints
If you have concerns or are unhappy about any of our services, please contact the Practice
Manager: Sharon Ryan
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
Information we are required to provide you
Data Controller contact
details
St Johns Wood Medical Practice:
Dr. Steven Charkin
Sharon Ryan – Practice Manager
Data Protection Officer
contact details NWLDPOService – nwl.infogovernance@nhs.net
Purpose of the
processing for the
provision of your
healthcare
 To give direct health or social care to individual patients.
 For example, when a patient agrees to a referral for direct care, such as to a hospital,
relevant information about the patient will be shared with the other healthcare staff
to enable them to give appropriate advice, investigations, treatments and/or care.
 To check and review the quality of care. (This is called audit and clinical governance).
Lawful basis for
processing
for the provision of
your healthcare
These purposes are supported under the following sections of the GDPR:
Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public
interest or in the exercise of official authority…’; and
Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
for the assessment of the working capacity of the employee, medical diagnosis, the
provision of health or social care or treatment or the management of health or social
care systems and services…”
Healthcare staff will also respect and comply with their obligations under the common law
duty of confidence.
Purpose of the
processing for medical
Medical research and to check the quality of care which is given to patients (this is called
national clinical audit).
Phone: 0303 123 1113
Website: www.ico.gov.uk
Interim-privacy-notice V1.3 July 2020 9
St Johns Wood Medical Practice
research and to
measure quality of care
Lawful basis for
processing for medical
research and to
measure the quality of
care
The following sections of the GDPR mean that we can use medical records for research and to
check the quality of care (national clinical audits)
Article 6(1)(e) – ‘processing is necessary for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the controller’.
For medical research: there are two possible conditions.
Either:
Article 9(2)(a) – ‘the data subject has given explicit consent…’
Or:
Article 9(2)(j) – ‘processing is necessary for… scientific or historical research purposes or
statistical purposes in accordance with Article 89(1) based on Union or Member States law
which shall be proportionate to the aim pursued, respect the essence of the right to data
protection and provide for suitable and specific measures to safeguard the fundamental rights
and interests of the data subject’.
To check the quality of care (clinical audit):
Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the
provision of health or social care or treatment or the management of health or social care
systems and services…’
Purpose of the
processing to meet
legal requirements
Compliance with legal obligations or court order.
Lawful basis for
processing to meet
legal requirements
These purposes are supported under the following sections of the GDPR:
Article 6(1)(c) – ‘processing is necessary for compliance with a legal obligation to which the
controller is subject…’
Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the
provision of health or social care or treatment or the management of health or social care
systems and services…’
Purpose of the
processing for National
screening programmes
 The NHS provides several national health screening programmes to detect diseases
or conditions early such as cervical and breast cancer, aortic aneurysm and diabetes.
 The information is shared so that the correct people are invited for screening. This
means those who are most at risk can be offered treatment.
Lawful basis for
processing
for National screening
programmes
The following sections of the GDPR allow us to contact patients for screening.
Article 6(1)(e) – ‘processing is necessary…in the exercise of official authority vested in the
controller…’’
Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the
provision of health or social care or treatment or the management of health or social care
systems and services…’
Rights to object
 You have the right to object to information being shared between those who are
providing you with direct care.
 This may affect the care you receive – please speak to the practice.
 You are not able to object to your name, address and other demographic information
being sent to NHS Digital.
 This is necessary if you wish to be registered to receive NHS care.
 You are not able to object when information is legitimately shared for safeguarding
reasons.
 In appropriate circumstances it is a legal and professional requirement to share
information for safeguarding reasons. This is to protect people from harm.
 The information will be shared with the local safeguarding service.
Right to access and
correct
 You have the right to access your medical record and have any errors or mistakes
corrected. Please speak to a member of staff or look at our ‘subject access request’
policy on the practice website.
 We are not aware of any circumstances in which you will have the right to delete
correct information from your medical record; although you are free to obtain your
own legal advice if you believe there is no lawful purpose for which we hold the
information and contact us if you hold a different view.
Retention period GP medical records will be kept in line with the law and national guidance. Information on
how long records are kept can be found at: https://digital.nhs.uk/article/1202/RecordsManagement-Code-of-Practice-for-Health-and-Social-Care-2016
Interim-privacy-notice V1.3 July 2020 10
St Johns Wood Medical Practice
or speak to the practice.
Right to complain You have the right to complain to the Information Commissioner’s Office. You may follow this
link https://ico.org.uk/global/contact-us/ or call the helpline 0303 123 1113
Data we get from other
organisations
We receive information about your health from other organisations who are involved in
providing you with health and social care. For example, if you go to hospital for treatment or
an operation the hospital will send us a letter to let us know what happens. This means your
GP medical record is kept up-to date when you receive care from other parts of the health
service.
Further Information
Further information about the way in which the NHS uses personal information and your rights in
that respect can be found 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
2018.
http://systems.digital.nhs.uk/infogov/links/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.
https://www.gov.uk/government/publications/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.
http://content.digital.nhs.uk/article/4963/What-we-we-collect
Reviews of and Changes to our Privacy Notice
We will keep our Privacy Notice under regular review. This notice was last reviewed in May
2018

The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:

• Have a publication scheme in place
• Allow public access to information held by public authorities.

The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.

Public authorities include government departments, local authorities, the NHS, state schools and police forces.

The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.

The Surgery publication scheme

A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:

• who we are and what we do
• what we spend and how we spend it
• what our priorities are and how we are doing it
• how we make decisions
• our policies and procedures
• lists and registers
• the services we offer

You can request our publication scheme leaflet at the surgery.

Who can request information?

Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use. 

How should requests be made?

Requests must:

• be made in writing (this can be electronically e.g. email/fax)
• state the name of the applicant and an address for correspondence
• describe the information requested.

What cannot be requested?

Personal data about staff and patients covered under Data Protection Act.

For more information see these websites:

• Legislation GOV.UK
• Information Commissioners Office

St Johns Wood Medical Practice complies with the Data Protection Act.  All information about patients is confidential: from the most sensitive diagnosis, to the fact of having visited the surgery or being registered at the Practice. All patients can expect that their personal information will not be disclosed without their permission except in the most exceptional of circumstances, when someone is at grave risk of serious harm.

All members of the primary health care team (from reception to doctors) in the course of their duties will have access to your medical records. They all adhere to the highest standards of maintaining confidentiality.

As our reception area is a little public, if you wish to discuss something of a confidential nature please mention it to one of the receptionists who will make arrangements for you to have the necessary privacy.

Under 16s

The duty of confidentiality owed to a person under 16 is as great as the duty owed to any other person. Young people aged under 16 years can choose to see health professionals, without informing their parents or carers. If a GP considers that the young person is competent to make decisions about their health, then the GP can give advice, prescribe and treat the young person without seeking further consent.

However, in terms of good practice, health professionals will encourage young people to discuss issues with a parent or carer. As with older people, sometimes the law requires us to report information to appropriate authorities in order to protect young people or members of the public.

Useful Websites

• Confidentiality NHS Code of Practice
• Confidentiality and Mental Health
• Confidentiality Guidance

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information may be used, how we keep it safe and confidential and what your rights are in relation to this. Practice Fair Processing Privacy Notice – V1.3

Patient Leaflet A5 – V1.0

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 and help us to protect your safety.

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

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. from Hospitals, GP Surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

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

• Details about you, such as your address and next of kin
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments,
• Notes and reports about your health
• Details about your treatment and care
• Results of investigations, such as laboratory tests, x-rays,
• Relevant information from other health professionals, relatives or your carers

How we keep your information confidential and safe

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

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

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

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

• Data Protection Act 2018
• Human Rights Act
• Common Law Duty of Confidentiality
• NHS Codes of Confidentiality and Information Security
• Health and Social Care Act 2015
• And all applicable legislation

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

How we use your information

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

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.

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

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

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

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

Our Duties

As part of our legal duties, this practice is required to;

• Maintain full and accurate records of the care and services we provide you
• Keep records about you confidential and secure

Information Includes;

• Basic details such as address, date of birth and next of kin
• Contact we have had with you
• Notes and reports about your health
• Details and records about your treatment and care

Others may also need to use records about you to:

• Check the quality of care you are receiving
• Protect the health of the general public  
• Keep track of NHS spending
• Help investigate any concerns or complaints you ask us to
• Teach students or staff
• Support health and social care research

Sometimes we share your information with third parties to support your care such as:

• Hospitals
• Social care
• Community Health
• Clinical Commissioning Groups
• Mental Health Providers
• NHS Digital

When we are sharing information to support third parties in providing your care, we will work hard to ensure it is the minimum necessary and that it is done so securely and lawfully. We aim to ensure that we only use your personal information in a way that you would reasonably expect.

When we share information that is used for healthcare management or planning, this does not allow for you to be identified.

Sometimes we will be required to share information for other reasons;

• When required to by law
• We have special permission for health or research purposes (e.g. if you have agreed to take part in a research trial)
• There is a strong public interest (e.g. there is a risk of serious harm or crime)

Objections

You can choose not to have information that could identify you shared beyond your GP practice.  You can also choose to prevent information that does not identify you from being shared for planning and research.

Simply contact your GP either to register an opt-out or end an opt-out you have already registered and they will update your medical record.  Your GP practice will also be able to confirm whether or not you have registered an opt-out in the past.

If you have previously told your GP practice that you don’t want NHS Digital to share your personal confidential information for purposes other than your own care and treatment, your opt-out will have been implemented by NHS Digital from 29th April 2016 as instructed in a direction from the Secretary of State.  It will remain in place unless you change it.

As the Secretary of State’s direction; this included the policy on how to apply opt-outs was not available before April 2016 it was not possible for NHS Digital to honour opt-outs made before this date.  This means that information may have been shared without respecting these opt-outs between January 2014 and April 2016.

You can find more information on NHS Digital’s website:

See how NHS Digital uses your information.

Read about how NHS Digital handles your information and your choices.

Your Rights

Under Data Protection law, you have a right to;

• object to certain uses of your data
• to be provided with a copy information held about you
• that your information will not be used for direct marketing purposes
• have any incorrect information amended or erased

Please contact your surgery for any requests made in connection with these rights.

For a copy of your information;

• Your request must be made in writing to your surgery
• The surgery is required to respond to your request in writing within 40 days (a month from May 2018)
• You will need to give the surgery your full name, address, date of birth and NHS number
• You will be required to provide personal identification such as a driving licence or passport

Use of the Website

Generally, our website will not require you to enter personal information. When it does, for example; online appointment booking, we will apply the same confidentiality principles as those described above.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should be aware that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites.

Data Security

We intend to protect the confidentiality, quality and integrity of your personal information and we have implemented appropriate technical and organisational measures to do so. These include staff training, up to date policies and procedures and working to align with national cyber security guidelines.

Cardiovascular Disease Prevention Audit

The CVDPREVENT Audit is a new national primary care audit being commissioned by NHS England to support the implementation of the NHS Long Term Plan, the annually negotiated General Medical Services contract and the national CVD Prevention programme. Six high- risk conditions for CVD are included in the audit: atrial fibrillation, high blood pressure, high cholesterol, diabetes, pre-diabetes, and chronic kidney disease. These conditions are major causes of CVD.

CVDPREVENT Audit will utilise an initial extract containing historical information and then rolling three monthly extracts of routinely recorded General Practice data, providing detailed insight into the diagnosis, investigation, and management of patients at risk of cardiovascular events. The data will be extracted for three cohorts: patients who have one of the six high-risk conditions, patients who have established CVD, and patients not in the first two cohorts but whose records contain entries indicating that they may have an undiagnosed high-risk condition. The extracts will include diagnostic codes, recording of risk factors such as smoking and alcohol, physical measurements such as blood pressure and body mass index (BMI), blood tests such as kidney function and cholesterol, as well as drug treatment and lifestyle interventions. To find out more and the benefits of CVD: CVD Audit 1.1

Data Provision Notice

Physical Health Checks for people with Severe Mental Illness (PHSMI)

NHS England has directed NHS Digital to collect and analyse data in connection with Physical Health Checks for people with Severe Mental Illness (referred hereafter to as “PHSMI”).
In 2016, the Five Year Forward View for Mental Health (MHFYFV) set out NHS England and NHS Improvement’s (NHSE/I) approach to reducing the stark levels of premature mortality for people living with severe mental illness (SMI) who die 15-20 years earlier than the rest of the population, largely due to preventable or treatable physical health problems.To ensure monitoring drives the right clinical behaviour, it is crucial that NHSE/I is able to monitor delivery of the full comprehensive SMI health check and to collect benchmarking information on the uptake of the corresponding relevant follow-up interventions and access to national cancer screening programmes.  For farther information please visit: Physical Health Checks- V 1.0

We aim to keep our surgery clean and tidy and offer a safe environment to our patients and staff. We are proud of our modern, purpose built Practice and endeavour to keep it clean and well maintained at all times.

If you have any concerns about cleanliness or infection control, please report these to our Reception staff.

Our GPs and nursing staff follow our Infection Control Policy to ensure the care we deliver and the equipment we use is safe.

We take additional measures to ensure we maintain the highest standards:

• Encourage staff and patients to raise any issues or report any incidents relating to cleanliness and infection control.  We can discuss these and identify improvements we can make to avoid any future problems.
• Carry out an annual infection control audit to make sure our infection control procedures are working.
• Provide annual staff updates and training on cleanliness and infection control
• Review our policies and procedures to make sure they are adequate and meet national guidance.
• Maintain the premises and equipment to a high standard within the available financial resources and ensure that all reasonable steps are taken to reduce or remove all infection risk.
• Use washable or disposable materials for items such as couch rolls, modesty curtains, floor coverings, towels etc., and ensure that these are laundered, cleaned or changed frequently to minimise risk of infection.
• Make Alcohol Hand Rub Gel available throughout the building

Where it is clinically appropriate and practical to register, we now accept new registration from patients who work in the local area but reside outside of our registration area. Patients registered this way would not be entitled to home visit from the practice, however they will be able to contact NHS 111 in order to be seen by a practice closer to where they live.

For further information about this type of registration, please contact us on 020 3657 9449 or feel free to come into the practice.

The practice fully supports the NHS Zero Tolerance Policy. The aim of this policy is to tackle the increasing problem of violence against staff working in the NHS and ensures that doctors and their staff have a right to care for others without fear of being attacked or abused.

We understand that ill patients do not always act in a reasonable manner and will take this into consideration when trying to deal with a misunderstanding or complaint. We ask you to treat your doctors and their staff courteously and act reasonably.

All incidents will be followed up and you will be sent a formal warning after a second incident or removed from the practice list after a third incident if your behaviour has been unreasonable.

However, aggressive behaviour, be it violent or verbal abusive, will not be tolerated and may result in you being removed from the Practice list and, in extreme cases, the Police will be contacted if an incident is taking place and the patient is posing a threat to staff or other patients.

Removal from the Practice List

A good patient-doctor relationship, based on mutual respect and trust, is the cornerstone of good patient care. The removal of patients from our list is an exceptional and rare event and is a last resort in an impaired patient-practice relationship. When trust has irretrievably broken down, it is in the patient’s interest, just as much as that of The Surgery, that they should find a new practice. An exception to this is on immediate removal on the grounds of violence e.g. when the Police are involved.

Removing other members of the household

In rare cases, however, because of the possible need to visit patients at home it may be necessary to terminate responsibility for other members of the family or the entire household. The prospect of visiting patients where a relative who is no longer a patient of the practice by virtue of their unacceptable behaviour resides, or being regularly confronted by the removed patient, may make it too difficult for the practice to continue to look after the whole family. This is particularly likely where the patient has been removed because of violence or threatening behaviour and keeping the other family members could put doctors or their staff at risk.

Patient’s Rights

We are committed to giving you the best possible service. This will be achieved by working together. Help us to help you. You have a right to, and the practice will try to ensure that:

• You will be treated with courtesy and respect
• You will be treated as a partner in the care and attention that you receive
• All aspects of your visit will be dealt with in privacy and confidence
• You will be seen by a doctor of your choice subject to availability
• In an emergency, out of normal opening hours, if you telephone the practice you will be given the number to receive assistance, which will require no more than one further call
• You can bring someone with you, however you may be asked to be seen on your own during the consultation
• Repeat prescriptions will normally be available for collection within two working days of your request
• Information about our services on offer will be made available to you by way of posters, notice boards and newsletters
• You have the right to see your medical records or have a copy subject to certain laws.

Patient’s Responsibilities

With these rights come responsibilities and for patients we would respectfully request that you:

• Treat practice staff and doctors with the same consideration and courtesy that you would like yourself. Remember that they are trying to help you
• Please ensure that you order your repeat medication in plenty of time allowing 48 working hours.
• Please ensure that you have a basic first aid kit at home and initiate minor illness and self-care for you and your family.
• Please attend any specialist appointments that have been arranged for you or cancel them if your condition has resolved or you no longer wish to attend
• Please follow up any test or investigations done for you with the person who has requested the investigation
• Attend appointments on time and check in with Reception
• Patients who are more than 20 minutes late for their appointment may not be seen.
• If you are unable to make your appointment or no longer need it, please give the practice adequate notice that you wish to cancel. Appointments are heavily in demand and missed appointments waste time and delay more urgent patients receiving the treatment they need
• An appointment is for one person only. Where another family member needs to be seen or discussed, another appointment should be made
• Patients should make every effort to present at the surgery to ensure the best use of nursing and medical time. Home visits should be medically justifiable and not requested for social convenience
• Please inform us when you move home, change your name or telephone number, so that we can keep our records correct and up to date
• Read the practice leaflets and other information that we give you. They are there to help you use our services. If you do not understand their content please tell us
• Let us have your views. Your ideas and suggestions whether complimentary or critical are important in helping us to provide a first class, safe, friendly service in pleasant surroundings.

NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. For more information see these websites:

• GOV.UK – The NHS Constitution for England
• NHS Choices – NHS Constitution

The Surgery prides itself on maintaining professional standards. For certain examinations during consultations an impartial observer (a “Chaperone”) will be required.

This impartial observer will be a practice Nurse or Health Care Assistant who is familiar with the procedure and be available to reassure and raise any concerns on your behalf. If a nurse in unavailable at the time of your consultation then your examination may be re-scheduled for another time.

You are free to decline any examination or chose an alternative examiner or chaperone. You may also request a chaperone for any examination or consultation if one is not offered to you. The GP may not undertake an examination if a chaperone is declined.

The role of a Chaperone:

• Maintains professional boundaries during intimate examinations.
• Acknowledges a patient’s vulnerability.
• Provides emotional comfort and reassurance.
• Assists in the examination.
• Assists with undressing patients, if required.

What is non-NHS work and why is there a fee?

The National Health Service provides most health care to most people free of charge, but there are exceptions: prescription charges have existed since 1951 and there are a number of other services for which fees are charged.

Sometimes the charge is because the service is not covered by the NHS, for example, providing copies of health records or producing medical reports for insurance companies, solicitors or employers.

The Government’s contract with GPs covers medical services to NHS patients but not non-NHS work. It is important to understand that many GPs are not employed by the NHS; they are self-employed and they have to cover their costs – staff, buildings, heating, lighting, etc. – in the same way as any small business.

In recent years, however, more and more organisations have been involving doctors in a whole range of non-medical work. Sometimes the only reason that GPs are asked is because they are in a position of trust in the community, or because an insurance company or employer wants to ensure that information provided to them is true and accurate.

Examples of non-NHS services for which GPs can charge their own NHS patients are:

• accident/sickness certificates for insurance purposes
• school fee and holiday insurance certificates
• reports for health clubs to certify that patients are fit to exercise
• private prescriptions for travel purposes

Examples of non-NHS services for which GPs can charge other institutions are:

• life assurance and income protection reports for insurance companies
• reports for the Department for Work and Pensions (DWP) in connection with
• disability living allowance and attendance allowance
• medical reports for local authorities in connection with adoption and fostering
• copies of records for solicitors

Do GPs have to do non-NHS work for their patients?

With certain limited exceptions, for example a GP confirming that one of their patients is not fit for jury service, GPs do not have to carry out non-NHS work on behalf of their patients. Whilst GPs will always attempt to assist their patients with the completion of forms, they are not required to do such non-NHS work.  Attached is a list of Fees for Non-NHS Services: Fees for Non-NHS Services & Vaccines

Is it true that the BMA sets fees for non-NHS work?

The British Medical Association (BMA) suggest fees that GPs may charge their patients for non-NHS work (i.e. work not covered under their contract with the NHS) in order to help GPs set their own professional fees. However, the fees suggested by them are intended for guidance only; they are not recommendations and a doctor is not obliged to charge the rates they suggest.

Why does it sometimes take my GP a long time to complete my form?

Time spent completing forms and preparing reports takes the GP away from the medical care of his or her patients. Most GPs have a very heavy workload and paperwork takes up an increasing amount of their time. Our GPs do non-NHS work out of NHS time at evenings or weekends so that NHS patient care does suffer.

I only need the doctor’s signature – what is the problem?

When a doctor signs a certificate or completes a report, it is a condition of remaining on the Medical Register that they only sign what they know to be true. In order to complete even the simplest of forms, therefore, the doctor might have to check the patient’s ENTIRE medical record. Carelessness or an inaccurate report can have serious consequences for the doctor with the General Medical Council (the doctors’ regulatory body) or even the Police.

If you are a new patient we may not have your medical records so the doctor must wait for these before completing the form.

What will I be charged?

It is recommended that GPs tell patients in advance if they will be charged, and what the fee will be. It is up to individual doctors to decide how much they will charge. The surgery has a list of fees based on these suggested fees which is available on request.

What can I do to help?

• Not all documents need a signature by a doctor, for example passport applications. You can ask another person in a position of trust to sign such documents free of charge. Read the information that comes with these types of forms carefully before requesting your GP to complete them.
• If you have several forms requiring completion, present them all at once and ask your GP if he or she is prepared to complete them at the same time to speed up the process.
• Do not expect your GP to process forms overnight: urgent requests may mean that a doctor has to make special arrangements to process the form quickly, and this may cost more. Usually non-NHS work will take 2 weeks.

The purpose of this document is to detail the process for patients who wish to use online services to book or cancel appointments with a GP or nurse, order repeat prescriptions, view summary information or view clinical correspondence online.
Patient Online was designed to support GP practices in offering and promoting an online service to their patient population. The service is referred to as ‘GP online services’ and is offered to patients in addition to telephone and face-to-face interactions at GP practices. for more information on our Online Acesss please visit: Online Access – Patient Policy – V1.2

New contractual requirements came into force from 1 April 2014 requiring that GP Practices should make available a statement of intent in relation to the following IT developments:

• Summary Care Record (SCR)
• GP to GP Record Transfers
• Patient Online Access to Their GP Record
• Data for commissioning and other secondary care purposes

The same contractual obligations require that we have a statement of intent regarding these developments in place and publicised by 30 September 2014.

Please find below details of the practices stance with regards to these points.

Summary Care Record (SCR)

NHS England require practices to enable successful automated uploads of any changes to patient’s summary information, at least on a daily basis, to the summary care record (SCR) or have published plans in place to achieve this by 31st of March 2015.

Having your Summary Care Record (SCR) available will help anyone treating you without your full medical record. They will have access to information about any medication you may be taking and any drugs that you have a recorded allergy or sensitivity to.

Of course, if you do not want your medical records to be available in this way then you will need to let us know so that we can update your record.

The practice confirms that your SCR is automatically updated on at least a daily basis to ensure that your information is as up to date as it can possibly be.

GP to GP Record Transfers

NHS England require practices to utilise the GP2GP facility for the transfer of patient records between practices, when a patient registers or de-registers (not for temporary registration).
It is very important that you are registered with a doctor at all times. If you leave your GP and register with a new GP, your medical records will be removed from your previous doctor and forwarded on to your new GP via NHS England. It can take your paper records up to two weeks to reach your new surgery.

With GP to GP record transfers your electronic record is transferred to your new practice much sooner.

The practice confirms that GP to GP transfers are already active and we send and receive patient records via this system.

Patient Online Access to Their GP Record

NHS England require practices to promote and offer the facility to enable patients online access to appointments, prescriptions, allergies and adverse reactions or have published plans in place to achieve this by 31st of March 2015.

We currently offer the facility for booking and cancelling appointments and also for ordering your repeat prescriptions and viewing a summary of your medical records on-line. If you do not already have a user name and password for this system – please register your interest with our reception staff.

Data for commissioning and other secondary care purposes

It is already a requirement of the Health and Social Care Act that practices must meet the reasonable data requirements of commissioners and other health and social care organisations through appropriate and safe data sharing for secondary uses, as specified in the technical specification for care data.

At our practice we have specific arrangements in place to allow patients to “opt out” of care.data which allows for the removal of data from the practice. Please see the page about care data on our website

The Practice confirm these arrangements are in place and that we undertake annual training and audits to ensure that all our data is handled correctly and safely via the Information Governance Toolkit.

About your Summary Care Record

Your Summary Care Record contains important information about any medicines you are taking, any allergies you suffer from and any bad reactions to medicines that you have previously experienced.

Allowing authorised healthcare staff to have access to this information will improve decision making by doctors and other healthcare professionals and has prevented mistakes being made when patients are being cared for in an emergency or when their GP practice is closed.

Your Summary Care Record also includes your name, address, date of birth and your unique NHS Number to help identify you correctly.

You may want to add other details about your care to your Summary Care Record. This will only happen if both you and your GP agree to do this. You should discuss your wishes with your GP practice.

Healthcare staff will have access to this information, so that they can provide safer care, whenever or wherever you need it, anywhere in England.

FAQs

Who can see my Summary Care Record?

Healthcare staff who have access to your Summary Care Record:

• need to be directly involved in caring for you
• need to have an NHS Smartcard with a chip and passcode
• will only see the information they need to do their job and
• will have their details recorded every time they look at your record

Healthcare staff will ask for your permission every time they need to look at your Summary Care Record. If they cannot ask you (for example if you are unconscious or otherwise unable to communicate), healthcare staff may look at your record without asking you, because they consider that this is in your best interest.

If they have to do this, this decision will be recorded and checked to ensure that the access was appropriate.

What are my choices?

You can choose to have a Summary Care Record or you can choose to opt out.

If you choose to have a Summary Care Record and are registered with a GP practice, you do not need to do anything as a Summary Care Record is created for you.

If you choose to opt out of having a Summary Care Record and do not want a SCR, you need to let your GP practice know by filling in and returning an opt-out form. Opt-out forms can be downloaded from the website or from your GP practice.

If you are unsure if you have already opted out, you should talk to the staff at your GP practice. You can change your mind at any time by simply informing your GP practice and either filling in an opt-out form or asking your GP practice to create a Summary Care Record for you.

Children and the Summary Care Record

If you are the parent or guardian of a child under 16, you should make this information available to them and support the child to come to a decision as to whether to have a Summary Care Record or not.

If you believe that your child should opt-out of having a Summary Care Record, we strongly recommend that you discuss this with your child’s GP. This will allow your child’s GP to highlight the consequences of opting-out, prior to you finalising your decision.

Where can I get more information?

For more information about Summary Care Records you can

• talk to the staff at your GP practice
• phone the Health and Social Care Information Centre on 0300 303 5678
• Read the Summary Care Record patient information