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Cathedral Medical Group
Cawley Road, Chichester, West Sussex PO19 1XT

Telephone: 01243 813 450
Fax: 01243 813 474
Aesthetics: 01243 813457

Email: cathedralmedical@nhs.net

 


Introduction 

 

Cathedral Medical Group recognises the need for an appropriate balance between openness and confidentiality in the management and use of information. The Surgery fully supports the principles of corporate governance and recognises its public accountability, but equally places importance on the confidentiality of, and the security arrangements to safeguard, both personal information about patients and staff and commercially sensitive information. Cathedral Medical Group also recognises the need to share patient information with other health organisations and other agencies in a controlled manner consistent with the interests of the patient and, in some circumstances, the public interest.

 

Cathedral Medical Group believes that accurate, timely and relevant information is essential to deliver the highest quality health care. As such it is the responsibility of all clinicians and managers to ensure and promote the quality of information and to actively use information in decision making processes.

 

 

 

Why we collect information about you

 

In the National Health Service we aim to provide you with the highest quality of health care.  To do this we must keep records about you, your health and the care we have provided or plan to provide to you. 

 

These records may include:

  • Basic details about you, such as address, date of birth, next of kin.
  • Contact we have had with you such as clinical visits.
  • Notes and reports about your health.
  • Details and records about your treatment and care.
  • Results of x-rays, laboratory test etc.
  • Relevant information from people who care for you and know you well, such as health professionals and relatives

It is good practice for people in the NHS who provide care to:

 

  • discuss and agree with you what they are going to record about you;
  • give you a copy of letters they are writing about you; and
  • show you what they have recorded about you, if you ask.

 

 

How your records are used

 

The people who care for you use your records to:

  • Provide a good basis for all health decisions made by you and care professionals.
  • Allow you to work with those providing care.
  • Make sure your care is safe and effective.
  • Work effectively with others providing you with care.

Others may also need to use records about you to:

  • Check the quality of care (such as clinical audit).
  • Protect the health of the general public.
  • Keep track of NHS spending.
  • Manage the health service.
  • Help investigate any concerns or complaints you or your family have about your health care.
  • Teach health workers.
  • Help with research

Some information will be held centrally to be used for statistical purposes.  In these instances we take strict measures to ensure that individual patients cannot be identified.

 

We use anonymous information, wherever possible, but on occasions we may use personally identifiable information for essential NHS purposes such as research and auditing.  However, this information will only be used with your consent, unless the law requires us to pass on the information.

 

 

 

General Data Protection Regulations (GDPR)

 

The Organisation is aware of and will adhere to the General Data Protection Regulations (GDPR). 

 

Cathedral Medical Group will comply with GDPR article 30(1) and will document in writing and maintain a record of our processing activities, covering areas such as processing purposes, data sharing and retention. This information will be available to patients in a series of Privacy Notices.  Ours Privacy Notices are as follows (the first of which follows:-

  • Direct Care (Routine Care and Referrals) - below
  • Summary Care Record
  • Emergencies
  • Public Health England
  • Safeguarding
  • National Screening Programmes
  • Care Quality Commission
  • NHS Digital
  • Payments
  • Research

The above Privacy Notices are available in the Surgery Waiting Room and Reception hold a copy too. Full privacy notices will be found on our website under “ useful documents”  in due course.

 

 

 

Notification

 

We are required to notify the Information Commissioner of the purposes for which we process personal information.

 

The details are publicly available from the Information Commissioner,

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. 

Tel: 01625 545745

 

 

 

Privacy Notice – Direct Care (Routine Care and Referrals)

 

Explanation

 

This practice keeps data on you relating to who you are, where you live, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care.

 

When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS information.

 

GPs have always delegated tasks and responsibilities to others that work with them in their surgeries, on average an NHS GP has between 1,500 to 2,500 patients for whom he or she is accountable. It is not possible for the GP to provide hands on personal care for each and every one of those patients in those circumstances, for this reason GPs share your care with others, predominantly within the surgery but occasionally with outside organisations.

 

If your health needs require care from others elsewhere outside this practice we will exchange with them whatever information about you that is necessary for them to provide that care. When you make contact with healthcare providers outside the practice but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all of those reports. Normally we will receive equivalent reports of contacts you have with non NHS services but this is not always the case.

 

Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law.

 

People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments, the practice nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst the GP you see or speak to will normally have access to everything in your record.

 

You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests. Please see below.

 

We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.

 

1) Data Controller contact details 

Cathedral Medical Group

Cawley Road, Chichester, PO19 1XT

 

2) Data Protection Officer contact details

 

 

Dr Zaid Almashta

Cathedral Medical Group

01243 813450

 

3) Purpose of the  processing

Direct Care is care delivered to the individual alone, most of which is provided in the surgery. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.


4) Lawful basis for  processing

The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere  is supported under the following Article 6 and 9 conditions of the GDPR:

 

Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.

 

Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services...” 

 

We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”*

 

5) Recipient or categories of

recipients of the processed data

The data will be shared with Health and care professionals and support staff in this surgery and at hospitals, diagnostic and treatment centres who contribute to your personal care. 

 

6) Rights to object

You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.

7) Right to access

and correct

You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.

 


8) Retention period

The data will be retained in line with the law and national guidance. https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016 or speak to the practice.

 

9)  Right to Complain.

You have the right to complain to the Information Commissioner’s Office, you can use this link https://ico.org.uk/global/contact-us/ 

 

or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website)

 

* “Common Law Duty of Confidentiality”, common law is not written out in one document like an Act of Parliament. It is a form of law based on previous court cases decided by judges; hence, it is also referred to as 'judge-made' or case law. The law is applied by reference to those previous cases, so common law is also said to be based on precedent.

 

The general position is that if information is given in circumstances where it is expected that a duty of confidence applies, that information cannot normally be disclosed without the information provider's consent.

 

In practice, this means that all patient information, whether held on paper, computer, visually or audio recorded, or held in the memory of the professional, must not normally be disclosed without the consent of the patient. It is irrelevant how old the patient is or what the state of their mental health is; the duty still applies.

 

Three circumstances making disclosure of confidential information lawful are:

 

  • where the individual to whom the information relates has consented;
  • where disclosure is in the public interest; and
  • where there is a legal duty to do so, for example a court order.

 

 

You have the right

 

You have the right to confidentiality under the GDPR, the Human Rights Act 1998 and the common law duty of confidence (the Disability Discrimination and the Race Relations Acts may also apply).

 

You also have the right to ask for a copy of all records about you, this is known as a Subject Access Request:

  • Your request must be made in writing to the surgery.
  • We are required to respond to you within one month.
  • You will need to give adequate information (for example full name, address, date of birth NHS number etc.).
  • You will be required to provide ID before any information is released to you.

It would help the practice if you could:

  • Limit the size of your request to the specific areas you are interested in, e.g. a particular period of care or care for a particular interest.
  • Agree to view this information online via a SystmOnline account.

If, on viewing your records, you think anything is inaccurate or incorrect, please inform us.

 

Subject Access Requests should not be used to obtain medical records for commercial purposes, e.g. for passing to an insurance company. Under the Data Protection Bill 2018, it will be illegal to use Subject Access Requests for this purpose, such access should be made under the Access to Medical Reports  Act 1988.

 

 


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