1. WHY WE PROVIDE 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 protect about you.
The Law states we must inform you about:
a. Why we collect your personal and healthcare information.
b. How we use any of your personal and healthcare information.
c. What we do with your personal information.
d. Who and why we share it with or pass it on to.
e. How long we can keep your information.
2. OUR DATA PROTECTION OFFICER (DPO)
Our registered DPO is Anna Morton. The DPO contact details are at Para 18 if you have any questions or requests about:
a. How your information is being held, used and protected.
b. Access to your information including any recordings held on our CCTV system. More details at Para 4.
c. If you are unclear or have any queries relating to this Policy and your rights as a patient. More details of your rights are at Para 17.
d. Opting In or Out of Risk Stratification – Details at Para 9i.
e. Opting In or Out of sharing anonymised or pseudoanonymised data – Details at Para 10.
f. Sharing your Summary Care Record (SCR) – Details at Para 7.
g. Translation of this Privacy Notice if English is not your first language.
i. If you wish to make a complaint about anything to do with your personal and healthcare information. Details at Para 19.
3. ABOUT US
We, at Salisbury Walk in Centre (‘the organisation’) situated at Millstream Medical Centre, Avon Approach, Salisbury, SP1 3SL is a Data Controller and in some instances Data Processors of your information. This means we are responsible for collecting, storing, handling and protecting your personal and healthcare information when you register with us as a patient.
Our organisation is registered with the Information Commissioner’s Office (ICO) as a data controller under the Data Protection Act 2018. Our registration number is ZA372045 and can be viewed online in the ICO public register at: Click Me To Check The Register
4. CLOSED CIRCUIT TELEVISION (CCTV)
We use CCTV covering the internal entrance, waiting room, corridors and reception. It is used solely to keep people and property safe. We do not use CCTV to collect evidence to inform other decisions. The organisation follows the ICO code of Practice which can be read here: Click Me To Read The ICO Code of Practice
We retain footage or store data from our CCTV system for a maximum of five days.
5. INFORMATION WE COLLECT FROM YOU
The information we collect from you includes:
a. Your contact details (such as your name, address and email address, including place of work and work contact details, legal representative).
b. Proof of identity.
c. Details and contact numbers of your next of kin / emergency contacts.
d. Your age, gender and ethnicity.
e. Details in relation to your medical and social history.
f. Any contact the organisation has had with you, e.g. reasons for appointments, visits, telephone calls.
g. Medical notes and details of investigations, diagnosis, treatment, management planning and consultations with our GPs and other health professionals within the organisation involved in your direct healthcare.
6. INFORMATION ABOUT YOU FROM OTHERS
We also collect personal information about you when it is sent to us to facilitate provision of healthcare services from the following:
a. A hospital, a consultant or any other medical or healthcare professional, or any other person involved with your general healthcare and welfare or those you may be caring for.
b. Notes and details of investigations, diagnosis, treatment, management planning and consultations about your health.
c. Relevant information from other health professionals, relatives or those who care for you.
d. Social Care Services.
e. Police, Court Orders and Fire and Rescue.
7. YOUR SUMMARY CARE RECORD (SCR)
Your SCR 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. In its basic form, referred to as the Core SCR, only medications, allergies and adverse reactions are included.
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 DPO.
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: Click Me To Find Out More About SCR.
You can enrich your SCR by giving consent to your registered GP Practice to include the following additional information:
- Significant past and present medical history.
- Reason for medication.
- Anticipatory care information (such as information about the management of long – term conditions).
- End of life care.
Giving consent to your registered GP Practice to create a SCR with additional information means that more relevant information is available wherever you are receiving treatment in the NHS. This will:
- Improve the flow of information across the health and care system.
- Increase safety and efficiency.
- Improve care.
It is particularly useful if you have complex or long-term conditions or are reaching end of life. If you 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 can change your choice at any time. More details on SCR are on your registered GP Practice website.
8. WHO WE MAY PROVIDE YOUR PERSONAL INFORMATION TO AND WHY
How your data is used is protected by law and we only use your data where we have an acceptable reason for doing so. The reasons we process your data are:
a. Whenever you use a health or care service, such as attending Accident & Emergency (A&E) 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 also pass your personal information on to the following people or organisations, because they may require it to assist in the provision of your direct healthcare.
b. Hospitals, healthcare professionals and urgent care professionals (such as doctors, consultants, nurses, etc.).
c. Pharmacists, Opticians and Dentists.
9. OTHER PEOPLE WHO WE PROVIDE YOUR INFORMATION TO
b. Clinical Commissioning Groups (CCG) including referral management services to process referrals to other NHS organisations and associated services and medicine management.
c. Local authorities including Social Care and Education.
d. Community health services.
f. For the purposes of complying with the law e.g. Care Quality Commission (CQC), Public Health England, Police, Fire and Rescue, Solicitors and Insurance Companies.
g. Anyone you have given your consent to view or receive your record, or part of your record. Please note, if you give another person or organisation consent to access your record we will need to contact you to verify your consent before we release that record. It is important that you are clear and understand how much and what aspects of your record you give consent to be disclosed.
h. At times CCG 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 we can identify because it is pseudoanonymised. This 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 this. There are good reasons why the CCG may require this pseudoanonymised information as follows:
- To evaluate service provision, patient outcomes and key performance indicators to determine quality of care and value for money.
- To evaluate the appropriateness and cost effectiveness of prescribing.
- To calculate service costs.
- To identify need/opportunity for improvement.
i. Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from several sources including NHS Trusts and from your registered GP Practice. A risk score is then arrived at through an analysis of your de-identified information and is only provided back to your registered GP Practice as Data Controller in an identifiable form. Risk stratification enables your registered GP Practice to focus on preventing ill health and not just the treatment of sickness. If necessary, the Practice may be able to offer you additional services. Further information about risk stratification is available from: Click Me For More Information
10. ANONYMISED OR PSEUDOANOYMISED INFORMATION
Sometimes we provide information about you in an anonymised or pseudoanonymised form. All personal information we use and transmit is fully compliant with the ICO Anonymisation Code of Practice which can be read here: Click Me To Read The Code of Practice
11. THIRD PARTIES MENTIONED ON YOUR MEDICAL RECORD
Sometimes we record information about third parties mentioned by you to us during any 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 redacted before we send any information to any other party including yourself. Third parties can include: spouses, partners, and other family members.
12. LEGAL JUSTIFICATION FOR COLLECTING AND USING YOUR INFORMATION
The Law states we need a legal basis to collect and handle your personal and healthcare information. These are as follows:
a. 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.
b. 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.
c. 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 to be able to consent.
13. 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:
a. Where we may need to handle your personal information when it is considered in the public interest. For example, when there is an outbreak of a specific disease and we need to contact you for treatment, or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment.
b. When you have given us consent.
c. If you are incapable of giving consent, and we must use your information to protect your vital interests (e.g. if you have had an accident and you need emergency treatment).
d. If we need your information to defend a legal claim against us by you, or by another party.
e. Where we need your information to provide you with medical and healthcare services.
14. 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.
15. 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/healthcare professional or organisation during your diagnosis or treatment or ongoing healthcare.
b. When we are required by Law to hand over your information to any other organisation, such as the police, by court order, solicitors, or immigration enforcement.
c. In accordance with the Law mainly:
- The Data Protection Act (DPA)2018. Click Me To Read The DPA
- General Data Protection Regulation (GDPR) 2018. Click Me To Read The ICO Information On GDPR
- Freedom of Information Act (FOIA) 2000. Click Me To Read ICO Information On The FOIA
- Privacy and Electronic Communications (EC Directive) Regulations (PECR) 2003. Click Me To Read These Regulations.
We will never pass on your personal information to anyone else who does not need it, or has no right to it, unless you give us clear consent to do so.
16. TEXT MESSAGING, EMAILING AND CONTACTING YOU
Because we are obliged to protect any confidential information, we hold about you, which we take this very seriously, it is imperative that you let us know immediately if you change any of your contact details.
We may contact you using emailing or SMS texting to your mobile phone in the event that we need to notify you about the appointment that 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 sure we are contacting you and not another person.
17. NHS NATIONAL DATA OPT OUT
The national data opt-out is a service that enables the public to register to opt out of their confidential patient information being used for purposes beyond their individual care and treatment. It was introduced for the health and social care system in England on 25th May 2018. We are working in accordance with the NHS Data Opt Out Policy.
You can change your national data opt-out choice at any time by calling NHS Digital contact centre on 0300 3035678, via the NHS App or visiting the NHS website:
Click Me To Opt Out
18. YOUR RIGHTS AS A PATIENT
In addition to the questions and requests outlined in Para 2 the Law also gives you certain rights to your personal and healthcare information that we hold, as set out below:
a. To see what information we hold about you and to request a copy of this information by raising a Subject Access Request (SAR).
b. Request online access to your medical record from your registered GP Practice. However, there will be certain protocols that they have to follow in order to give you online access, including written consent and production of documents that prove your identity.
Please note that when your registered GP Practice gives you online access the responsibility is yours to make sure that you keep your information safe and secure if you do not wish any third party to gain access.
c. To correct any information you think is inaccurate.
d. To ask for your information to be removed, however, if we require this information to assist us in providing you with appropriate medical services and diagnosis for your healthcare, then removal may not be possible.
e. We cannot share your information with anyone else for a purpose that is not directly related to your health, e.g. medical research, educational purposes, etc. We would ask you for your consent in order to do this, however, you have the right to request that your personal and healthcare information is not shared by the organisation in this way. Please note the anonymised and pseudoanonymised information at Para 10.
You can choose whether your health records are shared for research or planning here:
Click Me To Opt In Or Out Of Sharing
f. The right to request that your personal and/or healthcare information is transferred in an electronic form (or other form) to another organisation we will require your clear consent to be able to do this.
19. CONTACT DETAILS FOR THE DPO
If you wish to exercise any of your privacy rights or on other matters outlined in Para 2 please submit a Subject Access Request (SAR) to the DPO.
The ICO has excellent advice on the submission of a SAR which we recommend reading before any submission to us. Details here:
The DPO can be contacted using any of the following methods:
a. By email to: Salisbury.email@example.com
Please use “SAR Request. For the attention of the DPO” as the subject header.
b. By letter addressed to: The DPO, Salisbury Walk In Centre c/o Millstream Medical Centre, Avon Approach, Salisbury, SP1 3SL
c. By telephoning 01722 331191 giving clear details of your requirement.
d. By verbally giving the receptionist/clinician details of your requirement.
By Law we will provide any SAR information requests free of charge however, we are allowed in some limited and exceptional circumstances to make an administrative charge for any extra copies if the information requested is excessive, complex or repetitive.
20. COMPLAINTS ON OUR HANDLING OF A SAR
We have 30 days to reply to any SAR received. If you wish to challenge our reply you can complain and if necessary, request a deadlock letter from us if you remain dissatisfied. This ICO information may help you to raise a complaint to us.
As a last resort, which we hope will never be necessary, you have the right to contact the ICO to make a complaint about us. More details are here: Click Me For More Details On Making A Complaint To The ICO
21. UNDER 16?
Please read our privacy notice for children aged 15 and under here:
22. OUR WEBSITE
This website Privacy Notice only applies to Salisbury Walk in Centre at: Click Me To Go To Our Website
If you use any of the courtesy hyperlinks provided on our website including this Privacy Notice, you will need to read the individual website privacy policies. We take no responsibility for the content or security of other websites.
24. WHERE TO FIND OUR PRIVACY NOTICE
A copy of this Privacy Notice is held at reception, on our website or a copy will be provided on request. You can also download from our website.