General Data Protection Regulation
Covid-19 and your information – Updated on 4 June 2020
Please see link below regarding General Practice involvement in pandemic planning and research in relation to COVID 19
This notice describes how we may use your information to protect you and others during the Covid-19 outbreak. It supplements our main Privacy Notice.
The health and social care system is facing significant pressures due to the Covid-19 outbreak. Health and care information is essential to deliver care to individuals, to support health and social care services and to protect public health. Information will also be vital in researching, monitoring, tracking and managing the outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations.
Existing law which allows confidential patient information to be used and shared appropriately and lawfully in a public health emergency is being used during this outbreak. Using this law the Secretary of State has required NHS Digital; NHS England and Improvement; Arms Length Bodies (such as Public Health England); local authorities; health organisations and GPs to share confidential patient information to respond to the Covid-19 outbreak. Any information used or shared during the Covid-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use the data. Further information is available on gov.uk here and some FAQs on this law are available here.
During this period of emergency, opt-outs will not generally apply to the data used to support the Covid-19 outbreak, due to the public interest in sharing information. This includes National Data Opt-outs. However in relation to the Summary Care Record, existing choices will be respected. Where data is used and shared under these laws your right to have personal data erased will also not apply. It may also take us longer to respond to Subject Access requests, Freedom of Information requests and new opt-out requests whilst we focus our efforts on responding to the outbreak.
In order to look after your health and care needs we may share your confidential patient information including health and care records with clinical and non clinical staff in other health and care providers, for example neighbouring GP practices, hospitals and NHS 111. We may also use the details we have to send public health messages to you, either by phone, text or email.
During this period of emergency we may offer you a consultation via telephone or video-conferencing. By accepting the invitation and entering the consultation you are consenting to this. Your personal/confidential patient information will be safeguarded in the same way it would with any other consultation.
If you agree to a remote consultation the GP or healthcare professional may need to receive and store images taken by patients for clinical purposes; this could include images for the purpose of intimate clinical assessment. This will only be done in the interests of the patient where it is necessary for providing health care and with patient consent. The approach to video consulting, image sharing, and storage is the same as it would be for face to face interactions. If we need to store images on your GP record this will be only for as long as necessary. It is a patient’s choice to share an image either of a patient’s own accord or on request of the health professional treating you. Refusal to share an image does not prevent access to care and treatment or result in patients receiving an inferior standard of care. Further details about how remote consultation works can be obtained by contacting the practice.
We will also be required to share personal/confidential patient information with health and care organisations and other bodies engaged in disease surveillance for the purposes of protecting public health, providing healthcare services to the public and monitoring and managing the outbreak. Further information about how health and care data is being used and shared by other NHS and social care organisations in a variety of ways to support the Covid-19 response is here.
NHS England and Improvement and NHSX have developed a single, secure store to gather data from across the health and care system to inform the Covid-19 response. This includes data already collected by NHS England, NHS Improvement, Public Health England and NHS Digital. New data will include 999 call data, data about hospital occupancy and A&E capacity data as well as data provided by patients themselves. All the data held in the platform is subject to strict controls that meet the requirements of data protection legislation.
In such circumstances where you tell us you’re experiencing Covid-19 symptoms we may need to collect specific health data about you. Where we need to do so, we will not collect more information than we require and we will ensure that any information collected is treated with the appropriate safeguards.
We may amend this privacy notice at any time so please review it frequently. The date at the top of this page will be amended each time this notice is updated. How we use your medical records
Important information for patients
- This Practice handles medical records in-line with laws on data protection and confidentiality.
- We share medical records with those who are involved in providing you with care and treatment.
- In some circumstances we will also share medical records for medical research, for example to find out more about why people get ill.
- We share information when the law requires us to do so, for example, to prevent infectious diseases from spreading or to check the care being provided to you is safe.
- You have the right to be given a copy of your medical record.
- You have the right to object to your medical records being shared with those who provide you with care.
- You have the right to object to your information being used for medical research and to plan health services.
- You have the right to have any mistakes corrected and to complain to the Information Commissioner’s Office. Please see the Practice Privacy notice on the website or speak to a member of staff for more information about your rights. There is also a leaflet available GDPR Leaflet
More detailed information for patients can be found in the links below which cover four key themes:
- Provision of Direct Care
- Medical Research and Clinical Audit
- Legal Requirements to Share
- National Screening Programmes
CCTV is installed internally in public areas and externally for security. Recordings are used entirely at the discretion of the NHS Property Services, including provision of images to the police or other official bodies. Image data is held securely at the One Life.
At present we do not record telephone calls however we retain the right to record our telephone calls to protect patients and staff and other health workers. Patients are protected by the Practice having a record on our conversations with you, staff and other health workers are protected from potential abuse.
Recordings may also be used for staff training and quality control.
Fair Processing Notice - NICE
Our practice has been asked to take part in a pilot with NICE. The aim of the pilot is to test potential new general practice quality indicators in a representative group of general practices in England.
The indicators focus on dementia, depression and anxiety and people who are carers. By taking part in the pilot, we will also be sharing the views of some practice staff, based on consent. Consent will be recorded via a form and held for the duration of the pilot. This information will be shared securely, reported to NICE and then deleted at the end of the pilot process.
Piloting is designed to improve the quality of service you receive from your GP, to develop good practices which can be used nationwide.
If you would like further information, or do not wish to take part in the pilot, please inform the practice manager.