Access to Personal Information and Your Rights
You have a right under the Data Protection Act 1998 and the Data Protection Act 2018 from 25th May 2018, to request access to view or to obtain a copy of what information the organisation holds about you and to have it modified should it be inaccurate. The process to access your records is known as a Subject Assess Request (SAR) and the way it works is outlined below:
- Your SARs request must be made in writing to the organisation’s IG Lead at the address shown above
- The latest regulations state that there is no charge to have a printed copy of your information provided
- The request will be reviewed and if possible completed within one month (subject to our possible requests for further clarification for you)
- You will need to provide adequate proof of your identity before we will release the requested details (e.g. full name, address, date of birth, NHS number and details of your request), you must also provide two forms of identification
In addition to the right of access, under the Data Protection Act 2018, you will also have the following rights:
- Erasure, which is the right to request that your personal data is removed from our systems be they paper or electronic – please note that under certain circumstances we are legal obliged to maintain a copy of your data for contractual and or statutory reasons
- Restriction of processing, this is the right for you to request that we only process certain parts of your data
- Objection – you have the right to object to the way that we are processing your data
- Data portability – this concerns the right to request that we provide a copy of your data in an easily transportable format
- Automatic processing – you have the right to object to the way we automatically process data – in the case of our organisation we do not, at present, carry out automatic processing of your data
- If you have provided us with your consent to process your data for the purpose of providing our services, you have the right to withdraw this at any time. In order to do this should contact us by emailing or writing to the organisation.
Clinical Commissioning Group
The mission of Manchester Health and Care Commissioning Group:
- Determined to make Manchester a city where everyone can live a healthier life.
- To support you and your loved ones, investing in what you tell us is important to you.
- Make sure you receive the right care in the right place and at the right time, delivered by kind, caring people that you can trust.
- Make the most of our money by reducing waste and funding the things we know will work.
- To forge strong partnerships with people and organisations, in the city and across the region, and put health and wellbeing at the heart of the plans for developing Manchester’s future as a thriving city.
The values that lie at the heart of MHCC’s work are:
- Positive
- Collaborative
- Fair
MHCC’s aims are to:
- Improve the health and wellbeing of people in Manchester.
- Strengthen the social determinants of health and promote healthy lifestyles.
- Ensure services are safe, equitable and of a high standard with less variation.
- Enable people and communities to be active partners in their health and wellbeing.
- Achieve a sustainable health and care system.
To find out more about Manchester Health and Care Commissioning Group you can visit the website: www.mhcc.nhs.uk
Complaint Procedure
If you have a complaint or concern about the service you have received from the doctors or any of the staff working in this GP surgery, please let us know. This includes Primary Care Network staff working as part of our GP surgery. We operate a complaints procedure as part of an NHS system for dealing with complaints. Our complaints system meets national criteria.
How to complain
We hope that most problems can be sorted out easily and quickly when they arise and with the person concerned. For example, by requesting a face-to-face meeting to discuss your concerns.
If your problem cannot be sorted out this way and you wish to make a complaint, we would like you to let us know as soon as possible. By making your complaint quickly, it is easier for us to establish what happened. If it is not possible to do that, please let us have details of your complaint:
- Within 6 months of the incident that caused the problem; or
- Within 6 months of discovering that you have a problem, provided this is within 12 months of the incident.
Complaints should be addressed to the GP surgery team verbally or in writing [PRACTICE TO ADD SPECIFIC CONTACT DETAILS]. Alternatively, you may ask for an appointment with the GP surgery to discuss your concerns. They will explain the complaints procedure to you and make sure your concerns are dealt with promptly. Please be as specific as possible about your complaint.
What we will do
We will acknowledge your complaint within three working days. We will aim to have investigated your complaint within ten working days of the date you raised it with us. We will then offer you an explanation or a meeting with the people involved, if you would like this. When we investigate your complaint, we will aim to:
- Find out what happened and what went wrong.
- Make it possible for you to discuss what happened with those concerned, if you would like this.
- Make sure you receive an apology, where this is appropriate.
- Identify what we can do to make sure the problem does not happen again.
Complaining on behalf of someone else
We take medical confidentiality seriously. If you are complaining on behalf of someone else, we must know that you have their permission to do so. A note signed by the person concerned will be needed unless they are incapable (because of illness) of providing this.
Complaining to NHS England
We hope that you will use our Practice Complaints Procedure if you are unhappy. We believe this will give us the best chance of putting right whatever has gone wrong and an opportunity to improve our GP surgery.
However, if you feel you cannot raise the complaint with us directly, please contact NHS England. You can find more information on how to make a complaint at https://www.england.nhs.uk/contact-us/complaint/complaining-to-nhse/.
Unhappy with the outcome of your complaint?
If you are not happy with the way your complaint has been dealt with by the GP surgery and NHS England and would like to take the matter further, you can contact the Parliamentary and Health Service Ombudsman (PHSO). The PHSO makes final decisions on unresolved complaints about the NHS in England. It is an independent service which is free for everyone to use.
To take your complaint to the Ombudsman, visit the Parliamentary and Health Service Ombudsman website or call 0345 015 4033
Need help making a complaint?
If you want help making a complaint, Healthwatch Hounslow can help you find independent NHS complaints advocacy services in your area.
Alternatively, POhWER is a charity that helps people to be involved in decisions being made about their care. Call POhWER’s support centre on 0300 456 2370 for advice.
Confidentiality
The practice complies with data protection and access to medical records legislation. Identifiable information about you will be shared with others in the following circumstances:
- To provide further medical treatment for you e.g. from district nurses and hospital services.
- To help you get other services e.g. from the social work department. This requires your consent.
- When we have a duty to others e.g. in child protection cases anonymised patient information will also be used at local and national level to help the Health Board and Government plan services e.g. for diabetic care.
If you do not wish anonymous information about you to be used in such a way, please let us know.
Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.
Gender Recognition Act 2004
After a minimum of two years and if certain key criteria are met, some trans people can apply for a Gender Recognition Certificate (GRC) under the Gender Recognition Act (GRA) 2004. If granted, the person acquires all the legal rights and responsibilities of their new gender and can get a new birth certificate.
Section 22 of the GRA states that it is an offence for a person who has acquired protected information in an official capacity to disclose the information to any other person. “Protected information” is defined in Section 22(2) as information relating to a person who has applied for a gender recognition certificate under the Act, and which concerns that application (or a subsequent application by them), or their gender prior to being granted a full GRC. Section 22 therefore is a privacy measure that prevents officials from disclosing that a person has a trans history.
However, there are exemptions from Section 22 for medical professionals. Section 5 of Statutory Instrument 2005 No.635 provides an exemption that applies to: registered medical practitioners, dentists, pharmaceutical chemists, nurses, paramedics, operating department practitioners and trainees in these professions. The following circumstances must apply:
- The disclosure is made to a health professional;
- The disclosure is made for medical purposes; and
- The person making the disclosure reasonably believes that the subject has given consent to the disclosure or cannot give such consent.
All of the above must apply.
Patients should never be asked to produce a GRC to ‘prove’ their trans status. Trans people are not required to obtain a GRC: many simply choose not to while others may not (yet) meet the eligibility criteria. As a precautionary measure, it is good practice to apply the Section 5 criteria set out above to all disclosures of information about the trans status of a patient; it may not be accurately known whether the person has a GRC or not.
In addition, the general protocols on medical confidentiality and information governance apply to all patients whether they have a GRC or not. Good information governance around this is essential because unlawful and unwarranted disclosures of a person’s trans status leave GPs open to legal proceedings and can have serious and unforeseen consequences in ‘outing’ trans people.
General confidentiality statement
We hold your patient records in the strictest confidence, regardless of whether they are electronic or on paper. We take all reasonable precautions to prevent unauthorised access to your records, however they are stored. Any information that may identify you is only shared with the practice team, or, if you are referred to hospital, to the clinician who will be treating you. We will only share information about you with anyone else if you give your permission in writing.
Data Sharing
Certain departments at Wythenshawe Hospital are now able to access (read only) GP held patient records held at this practice.
Access to the GP record will enable the clinician to commence suitable treatment in a timely manner, avoid unnecessary admission, reduce length of stay if admitted and improve discharge planning.
This is especially important for:
- Older patients where the history is frequently limited.
- Patients with complex medical histories.
- Patients who are unconscious when presenting at the emergency department.
- Patients suffering from dementia.
- Patients with allergies of which the clinician would be otherwise unaware.
- Patients on GP prescribed medications with incomplete information about their prescription.
Which Staff Will be Authorised to Access the Record?
Access will be strictly limited to doctors, senior registered nurses, pharmacists and other senior registered clinicians working in the following areas:
- Emergency department.
- Urgent care unit.
- Clinical decisions unit.
- Acute medical unit.
- Acute medical receiving unit.
Patient Consent
All patients will be asked permission at the point of care by the clinician who needs to view their record. The system will not allow the clinician to proceed to view the record without recording in EMIS that they have asked the patient’s permission except in an emergency eg if the patient is unconscious.
Equality and Diversity Policy
Our policy is designed to ensure and promote equality and inclusion, supporting the ethos and requirements of the Equality Act 2010 for all visitors of our practice.
The aim of this policy is to remove any potential discrimination in the way that people with protected characteristics are cared for by the Practice. This means we take into account the needs of all patients and will not treat someone less favourably because of their age, disability, gender reassignment (including trans status), gender identity, marriage and civil partnership, pregnancy and maternity, race, religion or belief, or sexual orientation.
We are committed to:
- ensuring that all visitors are treated with dignity and respect
- promoting equality of opportunity between men and women
- providing the same treatment and services (including the ability to register with the practice) to any visitor irrespective of age, sex, marital status, pregnancy, race, ethnicity, disability, sexual orientation, medical condition, religion or belief
This policy applies to the general public, including all patients and their families, visitors and contractors.
Discrimination by the Practice or Visitors / patients against you.
If you feel discriminated against:
- You should bring the matter to the attention of the Practice Manager
- Our Practice Manager will investigate the matter thoroughly and confidentially within 14 working days
- Our Practice Manager will establish the facts and decide whether discrimination has taken place and advise you of the outcome of the investigation within 14 working days
If you are not satisfied with the outcome, you should raise a formal complaint through our Complaints Procedure
Discrimination against our Practice staff
The Practice will not tolerate any form of discrimination or harassment of our staff by any visitor. Any visitor who expresses any form of discrimination against or harassment of any member of our staff will be required to leave the practice premises immediately. If the visitor is a patient they may also be removed from the practice list if any such behaviour occurs at the discretion of the Practice Management.
Fair Processing Notice
How we use your personal information
This fair processing notice explains why the GP practice 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.
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 this GP Practice hold about you may include the following information;
- Details about you, such as your address, legal representative, emergency contact details.
- 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.
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 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.
Under the powers of the Health and Social Care Act 2012 (HSCA) the Health and Social Care Information Centre (HSCIC) can request Personal Confidential Data (PCD) from GP Practices without seeking the patient’s consent. The Care Data Programme allows PCD to be collected by the HSCIC to ensure that the quality and safety of services is consistent across the country. 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.
Any patient 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.
Risk Stratification
Risk stratification is a process for identifying and managing patients who are at a higher risk of emergency hospital admission. Typically this is because patients have a long term condition such as COPD or cancer. NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help prevent avoidable admissions.
Information about you is collected from a number of sources including NHS Trusts and from this GP practice. A risk score is then arrived at through an analysis of your anonymous information using computer programmes. Your information is only provided back to your GP or member of your care team in an identifiable form. Risk stratification enables your GP to focus on the prevention of 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 manager or your healthcare professional to discuss how the disclosure of your personal information can be restricted. All 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.
Care Data
The Health and Social Care Act 2012 allows the Health and Social Care Information Centre (HSCIC) to collate personal confidential data from GP practices without seeking your specific consent. Care.data is an example of a service that NHS England (not individual GP practices) has set up to use HSCIC to collect data from GP practices about patients. This is in order to make increased use of information from medical records with the intention of improving healthcare and the quality of care delivered to patients.
Information will be extracted from GP systems and includes personal confidential data such as referrals, NHS prescriptions and other clinical data. It also includes identifiers like your date of birth (DoB), postcode, NHS number and gender. This is so that your information can be linked with data from other healthcare settings for example, the hospital.
If you want to know more, please see the ‘How information about you helps us to provide better care’ leaflet.
Invoice Validation
If you have received treatment within the NHS, access to your personal information may be required in order to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.
This information would most likely include information such as your name, address, date of treatment and 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.
NHS Health Checks
All of our patients aged 40-74 not previously diagnosed with cardiovascular disease are eligible to be invited for an NHS health check. Nobody outside the healthcare team in the practice will see confidential information about you during the invitation process and only contact details would be securely transferred to a data processor (if that method was employed).
You may be ‘given the chance to attend your health check either within the practice or at a community venue. If your health check is at a community venue all data collected will be securely transferred back into the practice system and nobody outside the healthcare team in the practice will see confidential information about you during this process.
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), Human Rights Act, the Common Law Duty of Confidentiality, and the NHS Codes of Confidentiality and Security.
All of our staff, contractors and committee members receive appropriate and on-going training to ensure they are aware of their personal responsibilities and have contractual obligations to uphold confidentiality, enforceable through disciplinary procedures. Only a limited number of authorised staff has 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 and / or in accordance with the new information sharing principle following Dame Fiona’s Caldicott 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. The following are examples of the types of organisations that we are likely to share information with:
- NHS and specialist hospitals, trusts
- Independent Contractors such as dentists, opticians, pharmacists
- Private and voluntary sector providers
- Ambulance trusts
- Clinical commissioning groups and NHS England
- Social care services and local authorities
- Education services
- Police, fire and rescue services
- Other ‘data processors’ during specific project work e.g. Diabetes UK
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.
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.
Access to Personal Information
You have a right under the Data Protection Act 1998 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:
- Give you a description of it.
- Tell you why we are holding it.
- Tell you who it could be disclosed to.
- Let you have a copy of the information in an intelligible form.
If you would like to make a ‘subject access request’, you need to do the following:
- Your request must be made in writing to the GP – for information from the hospital you should write direct to them
- There may be a charge to have a printed copy of the information held about you
- We are required to respond to you within 40 days
- You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located
Notification
The Data Protection Act 1998 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 Z6467417 and can be viewed online in the public register at www.ico.org.uk/what_we_cover/register_of_data_controllers.
Further Information
Further information about the way in which the NHS uses personal information and your rights in that respect can be found in:
The NHS Constitution: www.gov.uk/government/publications/the-nhs-constitution-for-england.
The HSCIC Guide to Confidentiality gives more information on the rules around information sharing: www.hscic.gov.uk/confguideorg.
An independent review of how information about patients is shared across the health and care system led by Dame Fiona Caldicott was conducted in 2012. The report, Information: To share or not to share? The Information Governance Review, can be found at www.gov.uk/government/publications/the-information-governance-review.
The NHS Commissioning Board – NHS England – Better Data, Informed Commissioning, Driving Improved Outcomes: Clinical Data Sets provides further information about the data flowing within the NHS to support commissioning.
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 Information Commissioner’s Office website at www.ico.org.uk/.
Objections / Complaints
Should you have any concerns about how your information is managed at the GP surgery, please contact the GP Practice Manager. If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) via their website.
If you are happy for your data to be extracted and used for the purposes described in this fair processing notice then you do not need to do anything.
If you do not want your personal data being extracted and leaving the GP practice for any of the purposes described, you need to let us know as soon as possible.
We will then enter clinical codes into your records that will prevent data leaving the practice and / or leaving the central information system at the Health and Social Care Information Centre (HSCIC) for use by secondary providers.
Freedom of Information
The Freedom of Information Act, gives the general right of access to all types of recorded information held by the practice. The intention of the Act is to encourage a spirit of openness and transparency in the NHS and the whole public sector. Our organisation aims to fully support this.
The public have had full access rights from January 2005. This means that far more information will be routinely and freely made available. This is subject to some exemptions, which will be outlined later in this leaflet.
Any individual or organisation can make a request for information. The applicant does not have to explain why this information is requested. The Act gives the right to:
- Be told if information exists.
- Receive information (ideally in the format requested, for example, as a copy or summary or the applicant may ask to inspect a record).
Responding to Requests
All requests for information must be responded to within 20 working days. A fee can be charged when dealing with a request. This will be calculated in accordance with the Act. If a fee is required for information requested, the 20 day timescale can be extended to up to three months.
The Secretary of State has set limits to charges, should the request for information exceed these charges, this practice does not have to action the request. There maybe a charge for information not covered by the Act or for large amounts of information that might not otherwise be disclosed due to the cost.
The practice is not obliged to comply with vexatious requests or repeated or substantially similar requests from the same person other than at reasonable intervals.
Exemptions
There is a range of exemptions covering personal data, security, formulation of government policy commercial and individual confidentiality. A further absolute exemption is where information is accessible by other means or if the information has been provided in confidence. Other exemptions include information relating to commercial interests and audit functions
Request for Information
Requests must be in writing (email acceptable) and must include the name and address for the correspondence and a clear description of the information requested.
Requests for information should be made to the practice manager:
Miss Geraldine Jackson
Letter:
Brooklands Medical Practice
594-596 Altrincham Road
Brooklands
Manchester
M23 9JH
Email: smccg.brooklands@nhs.net
The Information Commissioner
The information Commissioner is an independent public body and reports directly to Parliament. The Commissioner is responsible for implementing the Act. Further information available at www.ico.org.uk.
Access to Records
In accordance with the Data Protection Act 1998 and Access to Health Records Act, patients may request to see their medical records. Such requests should be made through the practice manager and may be subject to an administration charge. No information will be released without the patient consent unless we are legally obliged to do so.
GP Earnings
All GP practices are required to declare the mean earnings for GPs working to deliver NHS services to patients at each practice.
The average pay for GPs working in Brooklands Medical Practice in the last financial year was £31,388 before tax and National Insurance. This is for 1 full time GPs and 7 part time GPs and 0 locum GPs who worked in the practice for more than six months.
Legal Basis for Processing
Our legal basis for processing your data relies on certain conditions set out GDPR Articles 6 and 9 which will be relevant from 25th May as part of the 2018 UK Data Protection Act.
Maintaining the Confidentiality of Your Records
We will take all possible care to protect your privacy and will only use information collected with the law including:
- Data Protection Act 1998 and the Data Protection Act 2018 from 25th May 2018
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012 (if appropriate)
- Codes of Confidentiality, Information Security and Records Management
Our staff are all trained and briefed in data protection principles and understand they have a legal obligation to keep information about you confidential. They also understand that information about you will only be shared with other parties if there is an agreed need to do so or a legal reason. We will only share your data without your permission if there are very exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the Caldicot Principle 7 e.g. to share or not to share. 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. Whilst the Caldicott Principles were originally developed for NHS purposes, we have adopted the underlying principles in order to align with best practice.
All personal information that we manage is stored within the UK within a secure environment and we always use suitably protected methods and systems to transfer your personal information.
Named GP
It is a national requirement that all registered patients are allocated a named GP who is responsible for the overall care they receive from the practice.
All patients have been allocated a named GP and if you would like to know which doctor this is please ask a member of our reception team.
If you have a preference as to which doctor this is, we will make every reasonable effort to accomodate your request.
Non-NHS Work
Certain services provided by your doctor are not covered by the NHS and you may be asked to pay a fee.
These include:
- Pre-employment medicals
- Private medicals
- Insurance claim forms
- Private certificates
- Fitness to drive medicals
- Travel cancellation forms
- Fitness to travel
If you have any queries about fees or any other private medical services, please discuss them with the receptionist or the practice manager.
Notification
The Data Protection Act 1998 and the Data Protection Act 2018 requires organisations that control data to register with the Information Commissioners Office (ICO) website www.ico.org.uk.
The organisation is registered with the ICO as a Data Controller under the Data Protection Act 1998. The registration number is <ICOCode> and can be viewed online in the public register.
Partner Organisations
It may be possible that we will share your information with other organisations, if this is required we will apply very strong controls. The current organisations who we share data with includes:
- NHS Trusts
- Local Authorities e.g.
- Specialist Panels
- Clinical Commissioning Groups
It is noted that the above list is not exhaustive, and we may contract with other external organisations to undertake processing of your personal information. These 3rd party organisations will abide with our stringent contractual conditions regarding the protection of personal data.
In some cases, you will be requested to provide positive consent if we intend to share your personal details with other organisations.
Privacy Notice
Brooklands Medical Practice fully appreciates the importance of protecting and managing your data and maintaining your privacy. To ensure that we comply with these requirements all our data management and clinical processes fully recognise the data protection law in force in the UK (e.g. the Data Protection Act 1998 and from 25th May 2018, the Data Protection Act 2018 which includes relevant articles from the EU General Data Protection Regulation (GDPR)
Please read the following information carefully to understand how we process your personal data.
For the purpose of the Data Protection Laws, the Data Controller is Brooklands Medical Practice, whose address is 594-596 Altrincham Road, Brooklands, Manchester, Greater Manchester, M23 9JH.
When we refer to ‘we’, ‘us’ and ‘our’, we mean Brooklands Medical Practice.
Use of Your Personal Information
Maintaining the Confidentiality of Your Records
Legal Basis for Processing
Partner Organisations
Access to Personal Information and Your Rights
Retention of your Data
Withdrawal of Consent
Updating Personal Details
Notification
Complaints
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 us.
Retention of your data
Your data will be retained for no longer than is absolutely necessary and in accordance with our Documentation Management Lifecycle Policy and the associated Schedule of Retention.
Suggestions, Comments and Complaints
Let the Practice Know Your Views
Brooklands Medical Practice is always looking for ways to improve the services it offers to patients. To do this effectively, the practice needs to know what you think about the services you receive. Tell us what we do best, where we don’t meet your expectations plus any ideas and suggestions you may have. Only by listening to you can the practice continue to build and improve upon the service it offers.
Practice Complaints Procedure
If you have a complaint about the service you have received from any member of staff working in this practice, please let us know. The practice operates a complaints procedure as part of the NHS system for dealing with complaints. Our complaints system meets national criteria.
In the first instance please discuss your complaint with the staff member concerned. Where the issue cannot be resolved at this stage, please contact Geraldine Jackson, practice manager, who will try to resolve the issue and offer you further advice on the complaints procedure. If your problem cannot be resolved at this stage and you wish to make a formal complaint, please let us know as soon as possible, ideally within a matter of days. This will enable the practice to get a clear picture of the circumstances surrounding the complaint.
If it is not possible to raise your complaint immediately, please let us have details of your complaint within the following timescales:
- Within 12 months of the incident that caused the problem.
- Within 12 months from when the complaint comes to your notice the practice will acknowledge your complaint within three working days.
When the practice looks into your complaint it aims to:
- The practice will arrange a meeting with you to discuss the complaint, to agree with you how the complaint is going to be investigated and the timescale for this to be completed.
- Ascertain the full circumstances of the complaint.
- Make arrangements for you to discuss the problem with those concerned, if you would like this.
- Make sure you receive an apology, where this is appropriate.
- Identify what the practice can do to make sure the problem does not happen again.
Advocacy Service for NHS Complaints
This is a national service that supports people who want to make a complaint about their NHS Care or treatment. Your local service can be found on www.pohwer.net/our-services/nhs-complaints-advocacy.
Ombudsman
If you have not received a satisfactory response from this practice, your local Clinical Commissioning Group, or NHS England, you can then refer your complaint to the Parliamentary and Health Service Ombudsman who investigates complaints about the NHS in England. If you make a complaint it is practice policy to ensure you are not discriminated against, or subjected to any negative effect on your care, treatment or support.
You can call the Ombudsman’s complaints helpline on 0345 015 4033 or www.ombudsman.org.uk or Textphone (Minicom) 0300 061 4298.
Summary Care Records
There is a Central NHS Computer System called the Summary Care Record (SCR). It is an electronic record which contains information about the medicines you take, allergies you suffer from and any bad reactions to medicines you have had.
Why do I need a Summary Care Record?
Storing information in one place makes it easier for healthcare staff to treat you in an emergency, or when your GP practice is closed.
This information could make a difference to how a doctor decides to care for you, for example which medicines they choose to prescribe for you.
Who can see it?
Only healthcare staff involved in your care can see your Summary Care Record.
Do I have to have one?
No, it is not compulsory. If you choose to opt out of the scheme, then you will need to complete our online Summary Care Record Opt-out form.
More Information
For further information visit the NHS Care records website.
Training Practice
We are an approved training practice for fully qualified doctors who wish to gain special experience in general practice. This may mean that this doctor accompanies your usual doctor. On occasions and with your full knowledge and consent, we video record routine consultations purely for training purposes.
The surgery also takes 3rd and 4th year medical students for one day a week during certain times of the year. Again these students may be accompanying your usual doctor but only if you are in total agreement.
Updating Personal Details
If any of your details e.g. your name, address or other personal data have changed or are incorrect you have a responsibility to inform the professional treating you who will arrange for the necessary updates to be made.
This will help us to ensure that the data we hold about you is accurate and complete.
Use of Your Personal Information
This privacy notice explains why we collect information about you and how that information may be used.
Our health care professionals who provide you with our services maintain records about your health and any treatment or care you have received previously. These records help to provide our clients with the best possible healthcare.
Your records may exist is several formats including electronic, paper or a mixture of both, and we deploy many working organisations and approaches to ensure that such information is maintained within a confidential and secure environment. The records which we could hold about you may include the following information:
- Personal details relating to you, including your address and contact details, carer, legal representative and parents’ emergency contact details
- Any contact we have had or intend to have with you such as appointments, clinic or surgery visits, home visits, etc.
- Notes and reports about your health which is deemed to be of a sensitive nature
- Details about your referral, diagnostics procedures, treatment and care
- Results of any additional relevant investigations
- Relevant information from other health professionals, relatives or those who care for you
To ensure you receive the highest levels of care, your records will be used to facilitate the care that we provide. Anonymised information held about could, on occasions, be used to help protect the health and wellbeing of the general public and to help us manage our contracts with commissioners. Information could also be used within our organisation for the purposes of clinical audits which in turn will provide monitoring of the quality of the services we provide.
Some of this information will be used for statistical purposes and we will ensure that individuals cannot be identified. For situations where we may contribute to research projects we will always gain your explicit consent before releasing any relevant information.
Withdrawal of Consent
If you have provided us with consent to process your data for the purpose of providing our services, you have the right to withdraw this at any time. In order to do this should contact us in writing.
Zero Tolerance
The NHS operate a zero tolerance policy with regard to violence and abuse and the practice has the right to remove violent patients from the list with immediate effect in order to safeguard practice staff, patients and other persons.
Violence in this context includes actual or threatened physical violence or verbal abuse which leads to fear for a person’s safety.
In this situation we will notify the patient in writing of their removal from the list and record in the patient’s medical records the fact of the removal and the circumstances leading to it.
This relates to any form of abuse from patients or staff which includes (but is not limited to) homophobia, biphobia, transphobia, racism, sexism, ageism, or harassment or abuse on basis of disability, marriage or civil partnership, pregnancy or maternity, religion or belief.