GDPR in relation to research within GP practices
The General Data Protection Regulation (GDPR) came into force on 25 May 2018. During the past few months there have been concerns that GDPR would have a significant impact on the way that we deliver healthcare research. The Health Research Authority (HRA) has now issued guidance regarding this. To view further information please follow this link
Fair Processing Notice
As your registered GP Practice, we are the Data Controller for any personal data that we hold about you. The Data Protection Officer is Bex Lovewell, Sentinel Healthcare SouthWest Community Interest Company, Unit 1, 5 Research Way, Plymouth Science Park, Plymouth, PL6 8BT email@example.com
How We Use Your Information
This notice briefly explains why the doctor’s surgery collects information about you, and how that information may be used.
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. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
Records may be held in electronic or manual (written down) format, and may include the following information;
- Details about you, such as name, address, date of birth, phone numbers and next of kin
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, 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 and know you well
To ensure you receive the best possible care, your records are used to facilitate the care you receive. 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 for clinical audit to monitor the quality of the service provided.
Where we do this, we take strict measures to ensure that individual patients cannot be identified.
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 obtain your consent before releasing the information.
Should you have any concerns about how your information is managed at the surgery please contact the Practice Manager to discuss how the disclosure of your personal information can be limited. There is an SCR opt OUT form on request.
How do we maintain the confidentiality of your records?
Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. Anyone who receives information from an NHS organisation has a legal duty to keep it confidential.
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, safeguarding issues), or where the law requires information to be passed on.
Third Party Processors
In order to deliver the best possible service, the practice will share data (where required) with other NHS bodies such as other GP practices and hospitals. In addition the practice will use carefully selected third party service providers. When we use a third party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties includes:
Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
Delivery services (for example if we were to arrange for delivery of any medicines to you).
Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).
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
- 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
- Other 'data processors' such as DELT GPIT services
Access to your Information
You have a right under the General Data Protection Regulation (GDPR) to access/view what information the surgery holds about you, and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject access’. If you would like to make a ‘subject access request’ (SAR) please do so in writing and we will look to get an electronic copy to you within the statutory timeframe.
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 GDPR 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 Information Commissioner’s Office website.