Privacy Notice – Direct Care and Referrals
This document explains how Innovations in Primary Care Ltd accesses and processes data about you.
Plain English Explanation
When you are referred to our clinic, Innovations in Primary Care Ltd (IPC) accesses your General Practice data in order to provide you with the best possible care. This may include data relating to who you are, where you live, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in your practice who are appropriately involved in your health care. We also keep data on you gathered as a result of our consultations with you, which can include all of the above. Data gathered as part of our consultations will also be available to your usual GP Practice and other healthcare providers to view.
When we are providing direct care, we ask your consent to view your information from other organisations and to share information we generate about you with other organisations relevant to your direct care (e.g. your GP, or a hospital specialist).
When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS data.
If your health needs require care from others elsewhere outside of IPC, we will exchange with them whatever information about you that is necessary for them to provide that care. When you make contact with healthcare providers outside of IPC but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all of those reports. Normally we will receive equivalent reports of contacts you have with non-NHS services but this is not always the case.
Your consent to this sharing of data, within IPC and with those others outside IPC is assumed and is allowed by the English law.
People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments, the nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst the GP you see or speak to will normally have access to everything in your record.
All staff working in health care have a duty of confidentiality regarding information about you in addition to the legal requirements for handling your personal data.
You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests. Please see below.
We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patient care, leading to improvements in both care and outcomes.
GP Connect is not used for any purpose other than direct care.
Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS Digital service called GP connect.
The NHS 111 service (and other services determined locally e.g. Other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services. Further information about GP Connect is available at: GP Connect privacy notice - NHS Digital
General Data Protection Regulations (GDPR)
1) Data Controller contact details
Innovations in Primary Care Ltd.
10-12, Units 6-11 Orchard Industrial Estate
2) Data Protection Officer
Dr Michael Twitchen contactable via email@example.com
3) Purpose of the processing
Direct Care is care delivered to the individual alone, most of which is provided by IPC. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care. Information collected as part of the patient’s consultation with IPC will also be made accessible to the patient’s referring practice.
4) Lawful basis for processing
The processing of personal data in the delivery of direct care and for providers’ administrative purposes in IPC and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions 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…'.
- 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...'
We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”*
5) Recipient or categories of recipients of the processed data
The data will be shared with health and care professionals and support staff in IPC, within your practice and at hospitals, diagnostic and treatment centres who contribute to your personal care.
6) Rights to object
You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or IPC. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.
7) Right to access and correct
You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.
8) Retention period
The data will be retained in line with the law and national guidance. Speak to the IPC data controller to find out more.
9) Right to Complain
You have the right to complain to the Information Commissioner’s Office website or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website).
* "Common Law Duty of Confidentiality", common law is not written out in one document like an Act of Parliament. It is a form of law based on previous court cases decided by judges; hence, it is also referred to as 'judge-made' or case law. The law is applied by reference to those previous cases, so common law is also said to be based on precedent.
The general position is that if information is given in circumstances where it is expected that a duty of confidence applies, that information cannot normally be disclosed without the information provider's consent.
In practice, this means that all patient information, whether held on paper, computer, visually or audio recorded, or held in the memory of the professional, must not normally be disclosed without the consent of the patient. It is irrelevant how old the patient is or what the state of their mental health is; the duty still applies.
Three circumstances making disclosure of confidential information lawful are:
- where the individual to whom the information relates has consented;
- where disclosure is in the public interest; and
- where there is a legal duty to do so, for example a court order.
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