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HIGHLANDS PRACTICE - Privacy Notice
We understand how important it is to keep your personal information safe and secure and we take this very seriously. We have taken steps to make sure your personal information is looked after in the best possible way and we review this regularly.
Please read this privacy notice carefully, as it contains important information about how we use the personal and healthcare information we collect on your behalf.
1. WHY WE ARE PROVIDING THIS PRIVACY NOTICE
We are required to provide you with this Privacy Notice by Law. It explains how we use the personal and healthcare information we collect, store and hold about you. If you are unclear about how we process or use your information. Please read this Privacy Notice carefully, as it contains important information about how we use the personal and healthcare information we collect on your behalf,or you have any questions about this Privacy Notice or any other issue regarding your personal and healthcare information, then please contact our Data Protection Officer (details below).
The Law says:
We must let you know why we collect personal and healthcare information about you
We must let you know how we use any personal and/or healthcare information we hold on you
We need to inform you in respect of what we do with it
We need to tell you about who we share it with or pass it on to, and why
We need to let you know how long we can keep the information for.
2. THE DATA PROTECTION OFFICER
The Data Protection Officer at Highlands Practice is Anya Haynes. You can contact her at the Surgery on 020 8360 9044 if:
You have any questions about how your information is being held
If you require access to your information or it 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.
3. ABOUT US
We at Highlands Practice (‘the Surgery’) situated at 3 Florey Square, N21 1UJ, are a Data Controller of your information. This means we are responsible for collecting, storing and handling your personal and healthcare information when you register with us as a patient.
There may be times where we also process your information. That means we use it for a particular purpose and therefore, on those occasions, we may also be Data Processors. The purposes for which we use your information are set out in this Privacy Notice.
4. INFORMATION WE COLLECT FROM YOU
The information we collect from you will include:
5. INFORMATION ABOUT YOU FROM OTHERS
We also collect personal information about you when it is sent to us from the following:
6. YOUR SUMMARY CARE RECORD
Your Summary Care Record is an electronic record of your healthcare history (and other relevant personal information) held on a national healthcare records database provided and facilitated by NHS England.
This record may be shared with other healthcare professionals and additions to this record may also be made by relevant healthcare professionals and organisations involved in your direct healthcare.
You may have the right to demand that this record is not shared with anyone who is not involved in the provision of your direct healthcare. If you wish to enquire further as to your rights in respect of not sharing information on this record then please contact our Data Protection Officer.
To find out more about the wider use of confidential personal information and to register your choice to opt out if you do not want your data to be used in this way please visit www.nhs.uk/my-data-choice.
Note: If you do choose to opt out, you can still consent to your data being used for specific purposes. However, if you are happy with this use of information you do not need to do anything. You may however change your choice at any time.
7. WHO WE MAY PROVIDE YOUR PERSONAL INFORMATION TO, AND WHY
Whenever you use a health or care service such as attending Accident & Emergency or using Community Care Services, important information about you is collected to help ensure you get the best possible care and treatment. This information may be passed to other approved organisations where there is a legal basis, to help with planning services, improving care, research into developing new treatments and preventing illness. All of this helps in providing better care to you and your family and future generations. However, as explained in this Privacy Notice, confidential information about your health and care is only used in this way where allowed by Law and would never be used for any other purpose without your clear and explicit consent.
We may pass on your personal information to the following people or organisations because these organisations may require your information to assist them in the provision of your direct healthcare needs. It therefore may be important for them to be able to access your information in order to ensure that they may properly deliver their services to you:
Hospital professionals (such as consultants, doctors, nurses etc.)
Nurses and other healthcare professionals
Any other personal that is involved in providing services related to your general healthcare, including mental health professionals.
8. OTHER PEOPLE WHO WE PROVIDE YOUR INFORMATION TO
Clinical Commissioning Groups (CCG)
Community health services
For the purposes of complying with the Law (i.e Police, Solicitors, Insurance Companies)
Anyone you have given your consent to, to view or receive your medical record, or part of your medical record. Please note, if you give another person or organisation consent to access your medical record we will need to contact you to verify your consent has been given before we release that record, or part of that record. It is also important that you are clear and understand how much and what aspects of your medical record you are giving consent to be disclosed.
Extended Access is provided to our patients which means you can access medical services outside of our normal working hours. In order to provide you with this service, we have formal arrangements in place with the CCG (Clinical Commissioning Group) and with other GP Practices whereby certain “hub” sites offer this service on our behalf to you as a patient to access medical services outside of our opening hours. This means those key “hub” sites will have to have access to your medical record to be able to offer you the service. Please note, to ensure that those practices comply with the Law and to protect the use of your information, we have very robust data sharing agreements and other clear arrangements in place to ensure your data is always protected and used for those purposes only.
The Hub Sites are as follows:
The Woodberry Practice
Carlton House Surgery
Eagle House Surgery.
Data Extraction by the CCG – the Clinical Commissioning Group at times extracts medical information about you, but the information we pass to them via our computer systems cannot identify you to them. This information only refers to you by way of a code that only your practice can use to identify you (it is pseudo-anonymised). This therefore protects you from anyone who may have access to this information at the CCG from ever identifying you as a result of seeing the medical information, and we will never give them the information that would enable them to do so.
There are good reasons why the CCG may require this pseudo-anonymised information, these are as follows:-
To ensure that:
Locally Commissioned Services are being offered to patients by all the practices within the area
Programmes that are running within the locality are making the health improvements for our patients that they have been commissioned to provide.
9. ANONYMISED INFORMATION
Sometimes we may provide information about you in any anonymised form. If we do so, then none of the information we provide to any other party will identify you as an individual and cannot be traced back to you.
10. YOUR RIGHTS AS A PATIENT
The Law gives you certain rights to your personal and healthcare information that we hold, as set out below:
A. Access and Subject Access Requests
You have the right to see what information we hold about you and to request a copy of this information.
If you would like a copy of the information we hold about you please write to our Data Protection Officer. We will provide this information free of charge however, we may in some limited and exceptional circumstances have to make an administrative charge for any extra copies if the information requested is excessive, complex or repetitive.
We have one month to reply to your request and give you the information that you require. We would ask, therefore, that any requests you make are in writing and that it is made clear to us what and how much information you require.
B. On-line Access
You may ask us if you wish to have on-line access to your medical record. However, there will be certain protocols that we have to follow in order to give you on-line access, including written consent and production of documents that prove your identity.
Please note that when we give you on-line access, the responsibility is yours to make sure that you keep your information safe and secure, if you do not wish any unauthorised third party to gain access.
We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct any information you think is inaccurate. It is very important that you make sure you tell us if your contact details, including your mobile phone number, have changed.
You have the right to ask for your information to be removed. However, if we require this information in order to assist us in providing you with the appropriate medical services and diagnosis for your healthcare, then removal may not be possible.
We cannot share your information with anyone else for a purpose that is not directly related to your health, i.e. for medical research, educational purposes etc. We would ask you for your consent in order to do this. You do however have the right to request that your personal and healthcare information is not shared by the Surgery in this way, (please note the Anonymised Information section in this Privacy Notice).
You have the right to request that your personal and/or healthcare information is transferred in an electronic form (or other form), to another organisation, but we will require your clear consent to be able to do this.
11. THIRD PARTIES MENTIONED ON YOUR MEDICAL RECORD
Sometimes we record information about third parties mentioned by you to us during a consultation. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them which may breach their rights to confidentiality are removed before we send any information to any other party including you yourself. Third parties can include spouses, partners and other family members.
12. HOW WE USE THE INFORMATION ABOUT YOU
We use your personal and healthcare information in the following ways:
A. When we need to speak to, or contact other doctors, consultants, nurses or any other medical or healthcare professional or organisation during the course of your diagnosis or treatment or on-going healthcare
B. When we are required by Law to hand over your information to any other organisation such as the Police, by Court Order, to Solicitors or Immigration Enforcement.
We will never pass on your personal information to anyone else who does not need it, or who has no right to it, unless you give us clear consent to do so.
13. LEGAL JUSTIFICATION FOR COLLECTING AND USING YOUR INFORMATION
The Law says we need a Legal basis to handle your personal and healthcare information.
Contract: We have a contract with NHS England to deliver healthcare services to you. This contract provides that we are under a legal obligation to ensure that we deliver medical and healthcare services to the public.
Consent: Sometimes we also rely on the fact that you give us consent to use your personal and healthcare information so that we can take care of your healthcare needs.
Please note that you have the right to withdraw consent at any time if you no longer wish to receive services from us.
Necessary care: Providing you with the appropriate healthcare, where necessary. The Law refers to this as “protecting your vital interests” where you may be in a position not be able to consent.
Law: Sometimes the Law obliges us to provide your information to an organisation (see above).
14. SPECIAL CATEGORIES
The Law states that personal information about your health falls into a special category of information because it is very sensitive. Reasons that may entitle us to use and process your information may be as follows:
Public Interest: Where we may need to handle your personal information when it is considered to be in the public interest. For example, when there is an outbreak of a specific disease and we need t contact you for treatment or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment.
Consent: When you have given us consent.
Vital Interest: If you are incapable of giving consent, and we have to use your information to protect your vital interest (ie. If you have had an accident and you need emergency treatment).
Defending A Claim: If we need your information to defend a legal claim against us by you or by another party.
Providing you with Medical Care: Where we need your information to provide you with medical and healthcare services.
15. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We carefully consider any personal information that we store about you and we will not keep your information for longer than is necessary for the purposes as set out in this Privacy Notice.
16. UNDER 16's
There is a separate privacy notice for patients under the age of 16, a copy of which may be obtained on request.
17. IF ENGLISH IS NOT YOUR FIRST LANGUAGE
If English is not your first language you can request a translation of this privacy notice. Please contact our Data Protection Officer.
If you have a concern about the way we handle your personal data or you have a complaint about what we are doing or how we have used or handled your personal and/or healthcare information then please contact our Data Protection Officer.
However, you have a right to raise any concern or complaint with the UK Information Regulator at the Information Commissioners’ Office https://icp.org.uk/
19. OUR WEBSITE
The only website this privacy notice applies to is Highlands Practice website. If you use a link to any other website from the Surgery’s website then you will need to read their respective privacy notice. We take no responsibility (legal or otherwise) for the content of other websites.
We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secure. We regularly update our processes and systems and we also ensure that our staff are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that we provide any other services we carry out proper assessments and security reviews.
22. TEXT MESSAGING AND CONTACTING YOU
Because we are obliged to protect any confidential information we hold about you and we take this very seriously it is important that you let us know immediately if you change any of your contact details.
We may contact you using SMS texting to your mobile phone to notify you about appointments and other service we provide to you involving your direct care therefore you must ensure that we have your up-to-date details. This is to ensure we are certain we are actually contacting you and not another person.
23. WHERE TO FIND OUR PRIVACY NOTICE
You may find a copy of this Notice in the Surgery Reception, on our website or a copy may be provided on request.
24. CHANGES TO OUR PRIVACY NOTICE
We regularly review and update our Privacy Notice. This was last updated on 22/05/2018.