Practice Privacy Notice

Fair Processing Notice (Privacy Notice)

Your Personal Information – what you need to know

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form.

Our Commitment to Data Privacy and Confidentiality Issues

As a GP practice, all our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation. This includes the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.

Data we collect about you

Records which this GP Practice will hold or share about you will include the following:

Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.

Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.

Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place.

Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care. For example, it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing at Appendix A.

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

improving the quality and standards of care provided
research into the development of new treatments
preventing illness and diseases
monitoring safety
planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this when allowed by law.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for Health and Social Care 2016.

Individuals Rights under GDPR

Under GDPR 2016 the Law provides the following rights for individuals. The NHS uphold these rights in a number of ways.

The right to be informed
The right of access
The right to rectification
The right to erasure (not an absolute right) only applies in certain circumstances
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling.

Your right to opt out of data sharing and processing

The NHS Constitution states, ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’. For further information please visit: The NHS Constitution

Type 1 Opt Out

This is an objection that prevents an individual’s personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to apply a Type 1 Opt Out to your GP record, please complete and return a type 1 opt out form available from the surgery or on the internet.

National data opt-out

The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.

All health and care organisations are required to apply national data opt-outs where confidential patient information is used for research and planning purposes. NHS Digital has been applying national data opt-outs since 25 May 2018. Public Health England has been applying national data opt-outs since September 2018.

The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. For

more information go to National data opt out programme and the associated privacy notice for NHS Digital can be found at;

NHS Digital GDPR Processing

To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.

On this web page you will:

See what is meant by confidential patient information
Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
Find out more about the benefits of sharing data
Understand more about who uses the data
Find out how your data is protected
Be able to access the system to view, set or change your own opt-out setting
Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
See the situations where the opt-out will not apply

Right of Access to your information (Subject Access Request)

Under Data Protection Legislation everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access to, and you may find information has been redacted or removed for the following reasons;

Does not cause harm to the patient
That legal confidentiality obligations for the non-disclosure of third-party information are adhered to

You do not need to give a reason to see your data and requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require.

Where multiple copies of the same information are requested, the surgery may charge a reasonable fee for the extra copies.

You will need to provide proof of identity to receive this information.

If you would like to access your GP record online, please see here or discuss with reception.

Change of Detail

It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.

Mobile telephone number

If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile.

Email address

Where you have provided us with your email address, with your consent we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email, please let us know.

Notification

Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a Data Controller and our registration can be viewed online in the public register https://ico.org.uk/ESDWebPages/Entry/Z5259285

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Data Protection Officer

Should you have any data protection questions or concerns, please contact our Data Protection Officer via the surgery at: sxicb-bh.prestonparksurgery@nhs.net

What is the right to know?

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However, you can request this under a right of access request – see section above ‘Access to your information’.

Right to Complain

If you have concerns or are unhappy about any of our services, please contact the Practice Manager or submit an online form here: Feedback and complaints – Preston Park Surgery

For independent advice about data protection, privacy and data-sharing issues, you can contact:

The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Phone: 0303 123 1113 Website: https://ico.org.uk/global/contact-us

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under Data Protection Legislation.

NHS Digital – Joining Up and Sharing Health ad Care Data

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong.

https://www.gov.uk/government/publications/the-nhs-constitution-for-england

Appendix A – The Practice will share patient information with these organisations where there is a legal basis to do so.

Activity	Rationale
Commissioning and contractual purposes Planning Quality and Performance	Purpose: Anonymous data is used by the Integrated Care Board (ICB) for planning, performance and commissioning purposes, as directed in the practices contract, to provide services as a public authority. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Patients may opt out of having their personal confidential data used for planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/ to apply a National Data Opt Out Processor: Sussex Integrated Care Board
Summary Care Record Including additional information	Purpose: The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that opting out of having your information shared with the Summary Care Record could result in a delay to care that may be required in an emergency. Processor: NHS England
Research	Purpose: We may share anonymous or pseudonymised patient information with research companies for the purpose of exploring new ways of providing healthcare and treatment for patients with certain conditions. This data will not be used for any other purpose. Where personal confidential data is shared your consent will be required. Where you have opted out of having your information shared for this planning or research your information will not be shared. Legal Basis: Articles 6(1)(a) and 9(1)(a) – explicit consent; or Article 6(1)(c) (where we are legally obligated to share your personal data) for your standard personal data and Article 9(2)(j) (scientific research) for your health data. Where identifiable data is required for research, patient consent will be needed, unless there is a legitimate reason under law to do so or there is support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales. Sharing of aggregated non identifiable data is permitted. Processor: Clinical Research Network and NHS Digital Privacy notice NHS Digital – How we protect your personal data
Individual Funding Requests	Purpose: We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our standard NHS contract. The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time, but this may affect the decision to provide individual funding. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Data processor: Sussex Integrated Care Board
Safeguarding Adults	Purpose: We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of individuals. Consent is not required to share information for this purpose. Legal Basis: Direct Care under UK 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…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine Data Processor: Sussex Integrated Care Board
Safeguarding Children	Purpose: We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Consent may not be required to share this information. Data Processor: Sussex Integrated Care Board
Risk Stratification – Preventative Care	Purpose: ‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops. Information about you is collected from several sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health. If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions. Type of Data: Identifiable/Pseudonymised/Anonymised/Aggregate Data Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processors: Preston Park Surgery
Public Health Screening programmes (identifiable) Notifiable disease information (identifiable) Smoking cessation (anonymous) Sexual health (anonymous) Vaccination Programmes	Purpose: Personal identifiable and anonymous data is shared. The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service to name a few. The law allows us to share your contact information, and certain aspects of information relating to the screening with Public Health England so that you can be appropriately invited to the relevant screening programme. More information can be found at: https://www.gov.uk/guidance/population-screening-explained or speak to the practice. Patients may not opt out of having their personal information shared for Public Health reasons. Patients may opt out of being screened at the time of receiving an invitation. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Data Processors: Public Health England
Direct Care NHS Trusts Community Providers Pharmacies Enhanced care providers Nursing Homes Other Care Providers	Purpose: Personal information is shared with other secondary care trusts and providers to provide you with individual direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service. Legal Basis: 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(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine Processors: Secondary care providers and trusts
Care Quality Commission	Purpose: The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data. More detail on how they ensure compliance with data protection law (including UK GDPR) and their privacy statement can be found here: https://www.cqc.org.uk/about-us/our-policies/privacy-statement Legal Basis: Article 6(1)(c) ‘…processing is necessary for compliance with a legal obligation’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine Processors: Care Quality Commission
Population Health Management	Purpose: Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data to: Understand the health and care needs of the care system’s population, including health inequalities Provide support to where it will have the most impact Identify early actions to keep people well, not only focusing on people in direct contact with services but looking to join up care across different partners. Type of Data: Identifiable/Pseudonymised/Anonymised/Aggregate Data. NB only organisations that provide your care will see your identifiable data. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine Data Processors: Optum, Cerner
Payments	Purpose: Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amounts paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non-patient related elements such as premises. Finally, there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. To make patient-based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws. Legal Basis: Article 6(1)(c) ‘processing is necessary for compliance with a legal obligation to which the controller is subject’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’. Data Processors: NHS England, ICB, Public Health
Patient Record data base	Purpose: Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date. Your record will follow you as you change surgeries throughout your life. Closed records will be archived by NHS England Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’. Processor: TPP and PCSE
NHS Digital	Purpose: NHS Digital is the secure haven* for NHS patient data, a single secure repository where data collected from all branches of the NHS is processed. NHS Digital provides reports on the performance of the NHS, statistical information, audits and patient outcomes (https://digital.nhs.uk/data-and-information). Examples include A/E and outpatient waiting times, the numbers of staff in the NHS, percentage target achievements, payments to GPs etc and more specific targeted data collections and reports such as the Female Genital Mutilation, general practice appointments data and English National Diabetes Audits. GPs are required by the Health and Social Care Act to provide NHS Digital with information when instructed. This is a legal obligation which overrides any patient wishes. Legal Basis: Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” Article 9(2)(h) “processing is necessary for the purposes of preventive 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 on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;” Processor: NHS Digital
Medical reports Subject Access Requests (also see below item)	Purpose: Your medical record may be shared in order that: Solicitors/persons acting on your behalf can conduct certain actions as instructed by you. Insurance companies seeking a medical report where you have applied for services offered by then can have a copy to your medical history for a specific purpose. Legal Basis: Article 6(1)(a) – consent for personal data; and Article 9(2)(a) – explicit consent for special-category data. Processor: Solicitors and insurance organisations
Request for information processing	Purpose: The iGPR Electronic Reporting Solution provides GP Practices a solution to manage Subject Access Requests (SARs) under UK GDPR and other requests for information that are received from patients and third parties. The solution integrates directly with the practice clinical system. Legal Basis: Under GDPR the surgery has used its legal basis of Article 6 1 (e) Public Task Article 9 2 (h) health data Processor: iGPR Technologies Ltd
Electronic reporting solution – Managed Service	Purpose: The iGPR Electronic Reporting Solution provides GP Practices a solution to manage Subject Access Requests (SARs) under UK GDPR and other requests for information that are received from patients and third parties. The solution integrates directly with the practice clinical system. iGPR acts as a data Processor and securely reviews, prepares and supplies copies of medical records or reports when we as your GP practice are either legally required or when you have given your consent. Legal Basis: Under GDPR the surgery has used its legal basis of Article 6 1(c) it is necessary under a legal obligation to which the controller is subject Article 6 1 (e) Public Task – it is necessary for the performance of a task carried out in the public interest or under official authority vested in the controller Article 9 2 (a) health data – the data subject has given explicit consent Processor: iGPR Technologies Ltd
Medicines Management Team Medicines Optimisation	Purpose: Your medical record is shared with the medicines management team pharmacists, in order that your medication can be kept up to date and any necessary changes to medication can be implemented. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: Preston Park Community PCN / NHS Sussex Medicine Management Team / Practice Pharmacists
GP Federation GP Extended Access Video consultations Minor injuries services	Purpose: Your medical record will be shared with The Brighton Federation in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics. The Federation will be acting on behalf of the GP practice. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: The Brighton Federation
Primary Care Network (PCN)	Purpose: Your medical record will be shared with Preston Park Community Primary Care Network in order that they can provide direct care services to the patient population. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: Preston Park PCN compromising of Stanford Medical Centre, Beaconsfield, The Haven, Preston Park Surgery and Warmdene Surgery
Smoking cessation	Purpose: Personal information is shared for the smoking cessation service to be provided. Only those patients who wish to be party to this service will have their data shared Legal Basis: Consented Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: Preston Park Surgery
Social Prescribers	Purpose: Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their health social care needs. Only those patients who wish to be party to this service will have their data shared Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: Age UK
Police	Purpose: Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared consent will not always be required. The Police will require the correct documentation to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime. Or where the information is necessary to protect a person or community. Legal Basis: UKGDPR Article 6(1)(c) – to comply with a legal obligation; and Article 9(2)(j) – ‘for reasons of substantial public interest’ Processor: Police Constabulary
Coroner	Purpose: Personal health records or information relating to a deceased patient may be shared with the coroner. Legal Basis: UK GDPR: Article 6(1)(c) – to comply with a legal obligation; and Article 9(2)(h) – ‘necessary for the purposes of preventative or occupational medicine’. Processor: The Coroner
Medical Examiner Service University Hospitals Sussex	Purpose: Purpose: Medical records associated with deceased patients are outside scope of the UK GDPR. However, next of kin details are within the scope of the UK GDPR. We will share specified deceased patient records and next of kin details with the Medical Examiners within University Hospitals Sussex. Legal Basis: Article 6(1)(c) – necessary under a legal obligation to which the controller is subject”; and Article 9(2)(h)– “processing is necessary for the purposes of preventive 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” Processor: Medical Examiners service – University Hospitals Sussex
Non-commissioned, private healthcare providers (e.g. BUPA, Virgin Care, etc.)	Purpose: Personal information shared with private health care providers to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with Private Providers. Legal Basis: Articles 6(1)(a) and 9(2)(a) consent by the patient given under contract to the provider. Provider: Various
Messaging Service	Purpose: Personal identifiable information shared with the messaging service in order that messages including appointment reminders; results; campaign messages related to specific patients’ health needs; and direct messages to patients, can be transferred to the patient in a safe way. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Provider: TPP,AccuRX, NHSAPP, eConsult,
Remote consultation Including – Video Consultation Clinical photography	Purpose: Personal information including images may be processed, stored and with the patients consent shared, to provide the patient with urgent medical advice. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Patients may be videoed or asked to provide photographs with consent. There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No identifiable pictures of children. Processor: e-Consult, AccuRX
MDT meetings	Purpose: For some long-term conditions, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions. Personal data will be shared with other agencies in order that mutual care packages can be decided. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: Organisations with whom information is shared
General Practice Extraction Service (GPES) 1. At risk patients’ data collection Version 3 2. CVDPREVENT Audit 3. Physical Health Checks for people with Severe Mental Illness 4. National Obesity Audit	Purpose: GP practices are required to provide data extraction of their patient’s personal confidential information for various purposes to NHS England. The objective of this data collection is on an ongoing basis to identify patients registered at General Practices who fit within a certain criterion, to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction; by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work: 1. At risk patients including severely clinically vulnerable 2. NHS England has directed NHS England to collect and analyse data in connection with Cardiovascular Disease Prevention Audit 3. GPES Physical Health Checks for people with Severe Mental Illness (PHSMI) data collection. 4. National Obesity Audit – NHS Digital Legal Basis: All GP Practices in England are legally required to share data with NHS England for this purpose under section 259(1)(a) and (5) of The Health and Social Care Act 2012 Further detailed legal basis can be found in each link. Any objections to this data collection should be made directly to NHS England. enquiries@nhsdigital.nhs.uk Processor: NHS England
OpenSAFELY COVID-19 and Data Analytics Services	Purpose: “NHS England has been directed by the government to establish and operate the OpenSAFELY COVID-19 Service and the OpenSAFELY Data Analytics Service. These services provide a secure environment that supports research, clinical audit, service evaluation and health surveillance for COVID-19 and other purposes. Each GP practice remains the controller of its own GP patient data but is required to let approved users run queries on pseudonymised patient data. This means identifiers are removed and replaced with a pseudonym. Only approved users are allowed to run these queries, and they will not be able to access information that directly or indirectly identifies individuals. Legal Basis: UK GDPR – Article 6 basis: UK GDPR Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject (the Directions). UK GDPR Article 9 basis: UK GDPR Article 9(2)(g) – processing is necessary for reasons of substantial public interest, on the basis of domestic law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject, by virtue of compliance with a direction supplemented by: Patients who do not wish for their data to be used as part of this process can register a type 1 opt out with their GP. Here you can find additional information about OpenSAFELY.” Processor: NHS England The Phoenix Partnership (TPP)
Medication/Prescribing	Purpose: Prescriptions containing personal identifiable and health data will be shared with organisations who provide medicines management including chemists/pharmacies, to provide patients with essential medication regime management, medicines and or treatment as their health needs dictate. This process is achieved either by face-to-face contact with the patient or electronically. Pharmacists may be employed to review medication, Patients may be referred to pharmacists to assist with diagnosis and care for minor treatment, patients may have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver care and medication Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: Pharmacy of choice
Professional Training	Purpose: We are a training surgery. Our clinical team are required to be exposed to on the job, clinical experience, as well as continual professional development. On occasion you may be asked if you are happy to be seen by one of our GP registrars, pharmacists or other clinical team to assist with their training as a clinical professional. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and with moderators at the RCGP and HEE. Legal Basis: 6 1 (a) consent, patients will be asked if they wish to take part in training sessions Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Recordings remain the control of the GP practice, and they will delete all recordings from the secure site once they are no longer required. Processor: University of Sussex
Telephony X-On Surgery Connect	Purpose: The practice uses an internet-based telephony system that records telephone calls, for their own purpose and to assist with patient consultations. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients. We record incoming and outgoing calls (non-clinical) and retain the recordings for 30 days. After this point, the recordings are automatically deleted. The 30-day retention period enables us to download and retain exact and unaltered copies of calls where required for medico-legal purposes. Legal Basis: While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way. Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Provider: Surgery Connect – X-On
Lexacom Live	Purpose: The practice intends to use ‘Lexacom AI’ to process and transcribe clinical conversations, either between a clinician and patients or of a clinician dictating their clinical findings/management plan during, before or following patient consultations. The technology looks to capture relevant details such as different speakers, medical terminology and symptomatology. Legal Basis: Article 6(1)e “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller” Article 9(2)h “processing is necessary for the purposes of preventive 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” Processor: Lexacom
Healthtech1	Purpose: Personal information is shared with Healthtech1 for the providers’ administrative purposes of registering patients at the practice using the clinical system, EMIS. Legal Basis: Providing services for: the provision of health care or treatment the management of health care systems or services or social care systems or services The lawful basis lies within Article 6 of the UK GDPR: 6(1)(e) Public task: the processing is necessary for ‘You’ to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law. The lawful basis of processing special category data lies within Article 9 of the UK GDPR: 9(2)(h) ‘…medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems…’ Additionally in Data Protection Act 2018 (Schedule 10, 8. Medical Purposes (1,b)): Medical purposes: 8(1) The processing is necessary for medical purposes and is undertaken by— (a) a health professional, or (b) a person who in the circumstances owes a duty of confidentiality which is equivalent to that which would arise if that person were a health professional. Data Processor: Healthtech1
Learning Disability Mortality Programme LeDer	Purpose: The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with these criteria will be shared with NHS England. Legal Basis: It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information who fit within a certain criterion. Processor: ICB, NHS England
Shared Care Record	Purpose: In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP connect, which is managed by NHS England, to enable a shared care record, which will assist in patient information to be used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population. Where data is used for secondary uses no personal identifiable data will be used. Where personal confidential data is used for research explicit consent will be required. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: NHS England
Local shared care record Plexus	Purpose: Health and Social care services are developing shared systems to share data efficiently and quickly. It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment. It is also quicker for staff to access a shared record than to try to contact other staff by phone or email. Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job. Systems do not share all your data, just data which services have agreed is necessary to include. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: Plexus
Anticoagulation Monitoring / Community Anticoagulation Service	Purpose: Personal Confidential data is shared with DAWN AC to provide an anticoagulation clinic to patients who are on anticoagulation medication. This will only affect patients who are within these criteria. Legal Basis: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’ Processor: DAWN AC (Managed by Boots The Chemist)

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