Data Protection

We have updated our Privacy Statement to comply with the General Data Protection Regulation (GDPR), which comes into effect across Europe from 25 May 2018.

We take our data privacy responsibilities very seriously at Harbourside Family Practice, and we want you to understand and feel confident about how we collect, use, share and store your personal data.

You have the right to see what information we hold about you and to request a copy of this information.

The below documents explain how we, Harbourside Family Practice, use the data we hold about our patients and sets out the rights you have in relation to your personal data:

Extended Privacy Notice

Fair Processing Notice

Your data and Covid-19 – Supplementary Privacy Notice

Data Protection Officer:

Should you have any data protection questions or concerns, please contact our Data Protection Officer via the surgery: Our DPO function is provided through contract with NHS South, Central & West Commissioning Support Unit. (To contact the DPO, please get in touch with the practice manager)

Subject Access Requests

If you would like a copy of the information that we hold about you, please get in touch with the Practice Manager. 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 you and give you the information that you require. We would ask, therefore, that any requests you make are in writing, using the ‘Subject Access Request Form’ below and that it is made clear to us what and how much information you require.

Subject Access Request Policy

Subject Access Request Form

Summary Privacy Notice

How we use your personal information

This Fair Processing Notice explains in general why Harbourside Family Practice collects information about you and how that information may be used. Separate detailed Privacy Notices are available for specific tasks and you can access these by clicking on the links below this overarching message.

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. Out-of-hours, GP Surgery, Walk-in clinic, Hospital etc.). These records help to provide you with the best possible healthcare.

NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which Harbourside Family Practice holds about you may include the following information;

Details about you, such as your address, carer, legal representative, emergency contact details
Any contact the surgery has had with you e.g. appointments, clinic visits, home visits, etc.
Notes and reports about your health
Details about your treatment and care
Results of investigations such as laboratory tests, x-rays etc.
Relevant information from other health professionals, relatives or those who care for you

Your records are used to ensure you receive the best possible care. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.

Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose.

Risk Stratification

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts (Hospitals) and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information using software managed by NHS Digital, and is only provided back to your GP as data controller in an identifiable form. 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 your data being used in this way.

Medicines Management

The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost effective treatments. This service is provided to practices within North Somerset by our local Clinical Commissioning Groups.

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:

Data Protection Act 2018 (which will be succeeded by the General Data Protection Regulation (GDPR) on 25th May 2018)
Human Rights Act 1998
Common Law Duty of Confidentiality
Health and Social Care Act 2012
NHS Codes of Confidentiality, Information Security and Records Management
Information: To Share or Not to Share Review

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential and 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), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.

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;

NHS Trusts
Specialist Trusts
NHS England
Independent Contractors such as dentists, opticians, pharmacists
Private Sector Providers
Voluntary Sector Providers
Ambulance Trusts
Clinical Commissioning Groups
Social Care Services
Local Authorities
Education Services
Fire and Rescue Services
Police

Please note that this list is not exhaustive and we may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.

You will be informed who your data will be shared with and in some cases asked for explicit consent for this happen when this is required.

Access to personal information

You have a right under the Data Protection Act 2018 to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. In order to request this, you need to do the following:

Your request must be made in writing to the Practice Manager
There will be no charge to have a printed copy of the information held about you
We are required to respond to you within 30 days
You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) and provide 2 forms of identification so that your identity can be verified and your records located

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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.

Notification

The Data Protection Act 2018 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 www.ico.org.uk the practice is registered with the Information Commissioners Office (ICO) as a data controller under the Data Protection Act 1998. The registration number is Z5294070 and can be viewed online in the public register at http://www.ico.gov.uk/

Who is the Data Controller?

The Data Controller is Harbourside Family Practice who is responsible for keeping your information secure and confidential.

Who is the Data Protection Officer (DPO)?

Our DPO function is provided through contract with NHS South, Central & West Commissioning Support Unit. (To contact the DPO, please get in touch with the practice manager)

Complaints

Should you have any concerns about how your information is managed by the Practice please contact the Practice Manager by emailing harbourside.practicemanager@nhs.net or in writing to Harbourside Family Practice, 2 Haven View, Portishead, Bristol, BS20 7QA.

If you are still unhappy following a review by the Practice you can then complain to the Information Commissioners Office (ICO) via their website www.ico.org.uk

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you have any concerns about how your data is shared then please contact the practice.

The Population Health Management Privacy Notice can be found here.

National Data Opt-Out Programme

The national data opt-out is a new service that allows people to opt out of their confidential patient information being used for research and planning.

The national data opt-out is introduced on 25 May 2018, providing a facility for individuals to opt-out from the use of their data for research or planning purposes. This is provided in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs. The service will initially be in beta, while we ensure the service design is optimal.

Individual preferences will be collected from 25 May and by 2020 all health and care organisations are required to have applied these preferences in all research and planning situations in which confidential patient information is used. NHS Digital will apply these preferences with immediate effect.

The national data opt-out will replace the previous ‘type 2’ opt-out, which required NHS Digital to refrain from sharing a patient’s confidential patient information for purposes beyond their direct care. Any person with an existing type 2 opt-out will have it automatically converted to a national data opt-out from 25 May 2018 and will shortly receive a letter giving them more information and a leaflet explaining the new national data opt-out.

You can find out more and set your opt-out choice by using the online service at nhs.uk/your-nhs-data-matters.

Please click here for an information leaflet.

GP Practice Privacy Notice for the General Practice Data for Planning and Research

Please click here for the privacy notice.

Privacy Notice for the IMPPP Study

Please click here for the privacy notice for BlueBayCT part of the Vision-Cegedim Group.

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