A downloadable version of this notice is available here: Practice Privacy Notice for Patients
PRACTICE PRIVACY NOTICE FOR PATIENTS
What is a Privacy Notice?
A Privacy Notice (or ‘Fair Processing Notice’) is an explanation of what information the Practice collects on patients, and how it is used. Being transparent and providing clear information to patients about how a Practice uses their personal data is an essential requirement of the Data Protection Act (DPA) 1998 and new General Data Protection Regulation (GDPR).
Under the DPA and GDPR, the first principle is to process personal data in a fair and lawful manner, and applies to everything that is done with patient’s personal information. In practice, this means that the Practice must:
have legitimate reasons for the use or collection of personal data
not use the data in a way that may cause adverse effects on the individuals (e.g. improper sharing of their information with 3rd parties)
How we use your information
This privacy notice explains why we as a Practice collect information about our patients and how we use that information.
Abertillery Group Practice manages patient information in accordance with existing laws and with guidance from organisations that govern the provision of healthcare in Wales such as the Department of Health and the General Medical Council.
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
As data controllers, GPs have fair processing responsibilities under the Data Protection Act and General Data Protection Regulations. In practice, this means ensuring that your personal confidential data (PCD) is handled clearly and transparently, and in a reasonably expected way.
The Health and Social Care Act 2012 changed the way that personal confidential data is processed, therefore it is important that our patients are aware of and understand these changes, and that you have an opportunity to object and know how to do so.
The health care professionals who provide you with care maintain records about your health and any NHS treatment or care you have received (e.g. NHS Hospital, GP Surgery, Out of hours services etc.). These records help to provide you with the best possible healthcare.
NHS health records may be processed electronically, on paper or a mixture of both; a combination of working practices and technology are used to ensure that your information is kept confidential and secure. Records held by this GP practice may include the following information:
Any contact the practice has had with you, including appointments (emergency or scheduled), clinic visits, etc.
The practice collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that the information is kept confidential. However, we can disclose personal information if:
Some of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict and secure measures to ensure that individual patients cannot be identified.
Information may be used for clinical audit purposes to monitor the quality of service provided, and may be held centrally and used for statistical purposes. Where we do this we ensure that patient records cannot be identified.
Sometimes your information may be requested to be used for clinical research purposes – the practice will always endeavour to gain your consent before releasing the information.
Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.
Patients can choose to withdraw their consent to their data being used in this way. When the practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-out’ of each new scheme.
A patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.
If you provide us with your mobile phone number we may use this to send you reminders about any appointments or other health screening information being carried out.
Risk stratification is a process for identifying and managing patients who are at high risk of requiring emergency or urgent care. Typically this is because patients have a long term condition such as COPD, cancer or other medical condition at risk of sudden worsening. NHS Wales encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to provide care plans and planned care with the aim to prevent avoidable admissions or other emergency care.
Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary your GP may be able to offer you additional services.
Please note that you have the right to opt out of Risk Stratification.
Should you have any concerns about how your information is managed, or wish to opt out of any data collection at the practice, please contact the practice, or your healthcare professional to discuss how the disclosure of your personal information can be limited.
Patients have the right to change their minds and reverse a previous decision. Please contact the practice, if you change your mind regarding any previous choice.
If you have received treatment within the NHS in England your personal information may be shared within a strictly monitored, secure and confidential environment in order to determine which Health Board should pay for the treatment or procedure you have received.
Information such as your name, address and date of treatment may be passed on to enable the billing process - these details are held in a secure environment and kept confidential. This information will only be used to validate invoices, and will not be shared for any further purposes.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with the Data Protection Act 1998 (which is overseen by the Information Commissioner’s Office), General Data Protection Regulations, Human Rights Act, the Common Law Duty of Confidentiality, and the NHS Codes of Confidentiality and Security. Every staff member who works for an NHS organisation has a legal obligation to maintain the confidentiality of patient information.
All of our staff members receive appropriate and regular training to ensure they are aware of their personal responsibilities and have legal and contractual obligations to uphold confidentiality, enforceable through disciplinary procedures. Staff only have access to personal information where it is appropriate to their role and is strictly on a need-to-know basis.
We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if 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 (i.e. life or death situations), or where the law requires information to be passed on.
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:
Access to personal information
You have a right under the Data Protection Act and General Data Protection Regulations to access/view information the practice holds about you, and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject access’. If we do hold information about you we will:
If you would like to make a ‘subject access request’, please contact the practice. You will be required to complete a subject access request form and provide ID to confirm your right to access. Under the General Data Protection Regulation we are no longer able to charge for this work and you can expect your request to be dealt with within four weeks. You will need to collect any copies of medical records in person, or personally authorise a specific individual to collect on your behalf if you are not able to attend in person. You or your representative will need to provide photographic ID (or another mutually agreed form of ID if photographic ID is not available). You will also have to sign a receipt upon collection. These steps are taken to protect your data.
Please be mindful that every subject access request presents the practice with a financial cost in staff time and/or printing costs, and this money could otherwise be put to providing direct patient care.
The practice is registered as a data controller under the Data Protection Act 1998. The registration number is ZA122972 and can be viewed online in the public register at https://ico.org.uk/
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 such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.
The Data Protection Act requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information. This information is publicly available on the Information Commissioners Office website https://ico.org.uk/ the practice is registered with the Information Commissioners Office (ICO).
Who is the Data Controller?
Under the Data Protection Act, the data controller is the person or organisation that will decide the purpose and the manner in which any personal data will be processed – they have overall control of the data they collect, and decide how and why it will be processed.
Abertillery Group Practice is the data controller for the patient information it collects, and has data processing arrangements with third parties (e.g. IT systems providers) to ensure they do not use or access data unlawfully; the data controllers have ultimate responsibility for the Practices’ compliance with the DPA.
The Data Controller responsible for keeping your information secure and confidential The GP Partners at Abertillery Group Practice, Dr Joanne Rudling and Dr Jayendra Chouhan. Any changes to this notice will be published on our website and displayed in prominent notices in the surgery.
The Partnership is registered as a data controller under the Data Protection Act 1998 ZA122972 registration can be viewed on-line in the public register at https://ico.org.uk/
Who is the Data Controller?
Mrs Angela Williams Practice Manager is the nominated Data Protection Officer, if you have any queries or concerns please contact her in the first instance at Abertillery Group Practice, The Bridge Centre, Foundry Bridge, Abertillery NP13 1BQ.
Further information about the way in which the NHS uses personal information and your rights in that respect can be found in:
The Information Commissioner’s Office is the Regulator for the Data Protection Act 1998 and offer independent advice and guidance on the law and personal data, including your rights and how to access your personal information. For further information please visit the https://ico.org.uk/