Privacy Policy

Data Protection Privacy Notice for Patients

Introduction

Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

This Privacy Notice applies to personal information processed by or on behalf of the Practice. It applies to the personal data of our patients and to the data you have given us about your carers/family members. It covers the following topics:

• Why do we need your data?
• What data do we collect about you?
• What is the legal basis for using your data?
• How do we store your data?
• How do we maintain the confidentiality of your data?
• How long do we keep your data?
• What are your data protection rights?
• Who do we share your data with?
• Are there other projects where your data may be shared?
• When is your consent not required?
• How can you access or change your data?
• What should you do if your personal information changes?
• Changes to our privacy policy
• Our Data Protection Officer
• How to contact the appropriate authorities

Why do we need your data?

As your General Practice, we need to know your personal, sensitive and confidential data in order to provide you with appropriate healthcare services. Your records are used to facilitate the care you receive, and to ensure you receive the best possible healthcare.

Information may be used within the GP practice for clinical audit, to monitor the quality of the service provided.

 

What data do we collect about you?

Personal data: We collect basic personal data about you which does not include any special types of information or location-based information.  This includes your name, postal address and contact details such as email address and telephone number.

By providing the Practice with your contact details, you are agreeing to the Practice using those channels to communicate with you about your healthcare, i.e. by letter (postal address), by voice-mail or voice-message (telephone or mobile number), by text message (mobile number) or by email (email address). If you are unhappy or have a concern about our using any of the above channels, please let us know.

Special Category personal data: We also collect confidential data linked to your healthcare which is known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare context) ethnicity and gender. This is obtained during the services we provide to you and through other health providers or third parties who have provided you with treatment or care, e.g. NHS Trusts, other GP surgeries, Walk-in clinics etc.

Records which the Practice holds about you may include the following information:

• Details about you, such as your address, carer, legal representative, emergency contact details
• Any contact the Practice 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

NHS records may be electronic, on paper, or a mixture of both.

Use of CCTV: Closed circuit television is utilised to protect the safety of our patients, staff and members of the public. To maintain privacy and dignity, CCTV is not in place where examinations or procedures are being undertaken. The Practice remains the data controller of this data and any disclosures or requests should be made to the Practice Manager.

Use of Digital Systems and Artificial Intelligence (AI)

We use a range of digital systems to support your care, including online consultation tools, messaging services, and clinical record systems.

We may also use artificial intelligence (AI) tools to support administrative and clinical processes, such as documenting consultations. These tools are subject to strict data protection, security, and clinical safety assessments.

Where such tools are used, we ensure appropriate safeguards are in place, including data processing agreements, security controls, and where required, patient transparency.

These systems are only used to support your care and are not used to make solely automated decisions about you.

What is the legal basis for using your data?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• Data Protection Act 2018
• The General Data Protection Regulations 2016
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management

 

Under the General Data Protection Regulation we will lawfully be using your information in accordance with:

Article 6 (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 (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”

For the processing of special categories data in employment, the basis is:

Article 9 (2) (b) – “processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law”

These articles apply to the processing of information and the sharing of it with others for specific purposes.

How do we store your data?

We have a Data Protection regime in place to oversee the effective and secure processing of your personal and special category (sensitive, confidential) data. No third parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place.

In certain circumstances you may have the right to withdraw your consent to the processing of data. These circumstances will be explained in subsequent sections of this document.

In some circumstances we may need to store your data after your consent has been withdrawn, in order to comply with a legislative requirement.

Some of the systems we use to process your data may store or process information outside of the United Kingdom. Where this occurs, we ensure appropriate safeguards are in place, such as UK adequacy regulations or approved contractual clauses.

How do we maintain the confidentiality of your data?

Our Practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection requirements. Our policy is to ensure all personal data related to our patients will be protected.

We use a combination of working practices and technology to ensure that your information is kept confidential and secure.

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.

All employees and sub-contractors engaged by our Practice are asked to sign a confidentiality agreement. The Practice will, if required, sign a separate confidentiality agreement if the client deems it necessary.  If a sub-contractor acts as a data processor for our Practice an appropriate contract will be established for the processing of your information.

 

Some of this information will be held centrally and used for statistical purposes. Where this happens, 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 Practice will always gain your consent before releasing the information for this purpose in an identifiable format.   In some circumstances you can Opt-out of the Practice sharing any of your information for research purposes.

 

How long do we keep your data?

We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records Management Code of Practice for Health and Social Care and in accordance with National Archives requirements.

More information on records retention can be found online at: Records Management Code of Practice – NHS Transformation Directorate (england.nhs.uk) 

 

What are your data protection rights?

If we already hold your personal data, you have certain rights in relation to it. 

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example a research project), or consent to market to you, you may withdraw your consent at any time.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to erase your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. 

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.

National Data Opt-Out: The National Data Opt-Out is a service introduced on 25 May 2018 that allows people to opt out of their confidential patient information being used for research and planning purposes. The National Data Opt-Out replaces the previous Type 2 Opt-Out, which required NHS England not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient who had a Type 2 Opt-Out has had it automatically converted to a National Data Opt-Out from 25 May 2018 and has received a letter giving them more information and a leaflet explaining the new service. If a patient wants to change their choice, they can use the new service to do this. You can find out more from the Practice or by visiting:

https://www.nhs.uk/your-nhs-data-matters/

 

If you wish to raise a query or request relating to any of the above, please contact us. We will seek to deal with it without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

 

Who do we share your data with?

We use your information to support your direct care based on legal obligations and public task. In most cases, we do not rely on your consent to share information for your care.

To provide around-the-clock safe care, we will make information available to trusted organisations for specific purposes unless you have asked us not to. We refer to these organisations to Data Processors and have additional privacy notices for these organisations. 

To support your care and improve the sharing of relevant information to our partner organisations when they are involved in looking after you, we will share information to other systems. The general principle is that information is passed to these systems unless you request that this does not happen, but that system users should ask for your consent before viewing your record.

Our partner organisations are:

• NHS Trusts / Foundation Trusts
• GPs
• NHS Commissioning Support Units
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Integrated Commissioning Boards
• Social Care Services
• NHS England (NHSE) 
• Multi Agency Safeguarding Hub (MASH)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police and Judicial Services
• Voluntary Sector Providers
• Private Sector Providers
• Other ‘data processors’ which you will be informed of

 

You will be informed who your data will be shared with, and in cases where your consent is required you will be asked for it.

Below are some examples of when we would wish to share your information with trusted partners. 

Primary Care Networks: We have formed a Primary Care Network. This means we work closely with a number of local practices and care organisations for the purpose of direct patient care. They will only be allowed to access your information if it is to support your healthcare needs. If you have any concerns about how your information may be accessed within our primary care network, we would encourage you to speak or write to us.

Extended Access: We provide extended access services to our patients which means you can access medical services outside of our normal working hours. In order to provide you with this service, we have formal arrangements in place with the Clinical Commissioning Group and with other practices whereby certain key “hub” practices offer this service on our behalf for you as a patient to access outside our opening hours. Those key “hub” practices will need to have access to your medical record to be able to offer you the service. We have robust data sharing agreements and other clear arrangements in place to ensure your data is always protected and used for those purposes only.

Medicines Management: The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up-to-date and cost-effective treatments. Our local NHS Clinical Commissioning Group employs specialist pharmacists and they may at times need to access your records to support and assist us with prescribing. This reason for this is to help us manage your care and treatment.

Individual Funding Requests: An Individual Funding Request is a request made on your behalf, with your consent, by a clinician, for the funding of specialised healthcare which falls outside the range of services and treatments that ICB has agreed to commission for the local population. An Individual Funding Request is considered when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.

Are there other projects where your data may be shared?

Local Research: We regularly work with local health and academic organisations to conduct research studies with the aim of improving care for the general population. We will always ask for your permission to take part, except in situations where we can demonstrate that your information has been anonymised (where you cannot be identified) and your privacy is protected. In these situations we are not required to seek consent from individuals.

Risk Stratification: Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned admission or re-admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP practice. A risk score arrived at through an analysis of your de-identified information is provided back to your GP practice as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way.

Other research projects: With your consent we would also like to use your name, contact details and email address to inform you of services that may benefit you. There may be occasions when authorised research facilities would like to invite you to participate in research, innovations, identifying trends or improving services. At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent or to opt out prior to any data processing taking place. This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the Practice.

When is your consent not required?

We will only ever use or pass on information about you to others involved in your care if they have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances.

There are certain circumstances where we are required by law to disclose information, for example:

• where there is a serious risk of harm or abuse to you or other people
• where a serious crime, such as assault, is being investigated or where it could be prevented
• notification of new births
• where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS)
• where a formal court order has been issued
• where there is a legal requirement, for example if you had committed a Road Traffic Offence

We are also required to act in accordance with Principle 7 of the Caldicott Review (Revised version 2013) which states: “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.

 

How can you access or change your data?

You have a right under the Data Protection legislation to request access to view or to obtain copies of the information the Practice holds about you and to have it amended should it be inaccurate.

Your request should be made to the Practice and we have a form (SAR – Subject Access Request) which you will need to complete. We are required to respond to you within one calendar month.

For information from the hospital you should write direct to them. You will need to give adequate information (full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located.

There is no charge to receive a copy of the information held about you.

 

What should you do if your personal information changes?

Please contact the Practice Manager as soon as any of your details change. This is especially important for changes of address or contact details (such as your mobile phone number).

The Practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.

 

Changes to our privacy policy

It is important to point out that we may amend this Privacy Notice from time to time.

 

Our Data Protection Officer

The Practice has appointed Umar Sabat as its Data Protection Officer.

He can be contacted on the following e-mail address: 

If you have any concerns about how your data is shared, or if you would like to know more about your rights in respect of the personal data we hold about you, then please contact the Practice Data Protection Officer.

 

How to contact the appropriate authorities

If you have any concerns about how your information is managed at your GP Practice, please contact the GP Practice Manager or the Data Protection Officer in the first instance.

If you are still unhappy following a review by the GP Practice, you have a right to lodge a complaint with the UK supervisory authority, the Information Commissioner’s Office (ICO), at the following address:

Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel:     01625 545745

Email: https://ico.org.uk/

 

Willows Health is the trading name for Willows Group Ltd. Willows Group Ltd is a group of 11 GP Practices: Willowbrook Medical Centre (including sub-branch Springfield Road Health Centre), Willows Medical Centre, Clarendon Park Medical Centre, Heatherbrook Surgery, Sayeed Medical Centre, Pasley Road Medical Centre, Dishley Grange Medical Centre (including sub-branch Hathern Surgery), Ar-Razi Medical Centre, De Montfort Surgery. All GP Practices are run by the same GP Partners. Each GP surgery is registered under Willows Group Ltd with the ICO.

This Children’s Privacy Notice is a way of telling you about what happens to the information that your GP practice collects about you whenever you come to see us. It also tells you how we make sure your information it is kept safe.

What do we collect?

We collect information about you such as:

Your Name
Your birthday and year you were born
Your address and contact information
The name of the person who will generally bring you to your appointments
The reason that you are coming to see us
Any information that you or your family gives us
Any other people we may need to send you to see to make sure you have the best care possible (such as hospital doctors, specialists etc.)

What we do to care for you

Why do we collect it?

Your surgery’s main purpose is to deliver healthcare to the people within this area.

We collect the data we need to care for you in the best way. We ask for your address so that we know where we can contact you. We ask for your date of birth as your age may be important to your care. Each time you come to see us we will write down things that you tell us, things that we tell you and any medicines we may need to give to you. That way, we can look back at what we have done for you to make sure we are treating you in the best way.

What do we do with it?

We keep the information we collect electronically and on paper. All of this information together is called your Health Record. When you first see us your Health Record will be given a number.

Everyone’s Health Record number will be different. Anyone involved in caring for you at Willows Health can see what has been collected. This way we can all make the right decisions about your care with all of the information you have given us.

Who do we share it with?

We will share the information we record about you with the doctors within the practice. That way they are kept up to date on what we are doing for you. Your parents/guardians should get a copy of any letters we send to your doctor about your care. We might share it with other health professionals involved in your care. We might share it with your school if we think it is important for them to know. If you have a social worker, we will share it with them too. If you tell us something that makes us worried about your safety or the safety of someone else you know, we might have to share this with other people outside of the hospital – even if you don’t want us to. This is part of our job to keep you and others safe.

We also need to share information with the Care Quality Commission who regulates healthcare providers. For more information click here on the link below:

https://www.cqc.org.uk/about-us/our-policies/privacy-statement

Keeping your records safe

Everyone working in our practice understands that they need to keep your information safe. This is called keeping your information confidential or protecting your privacy. They have training every year to remind them of this. We tell them that they are only allowed to look at your information if they are involved in your care or to help us run our practice. They understand that they must keep any information safe. Especially the information that identifies you; this might be your name or address and anything you come to see us about. We are not allowed to give any of this type of information to anyone who shouldn’t see it. This includes talking to them about it.

We sometimes might have Doctors and Nurses Students who are at University or College and want to work in a doctor’s practice sometimes spend time with us. This is so that we can teach them how to look after patients and their families. They are also told how to keep information we collect safe.

Checking we are doing our best

All doctor’s practices are checked by organisations to make sure they are treating and caring for patients and families in the best way they can. The people who inspect us may ask to see a small number of Health Records. They check that notes are written clearly and are kept safe to ensure that we are recording and storing your information safely.

How long do we keep the information for?

All doctor’s practices treating children must keep their information for the rest of their lives and then for 10 years after you die. If we have an incident or complaint, sometimes we need to use patient information to help us investigate incidents, complaints or legal claims. If this relates to you we will make sure we let you and your parents/guardians know.

Am I able to see the information you collect about me?

Yes! As one of our patients you are able to see the records that relate to you and you only. You or your family will need to ask your doctor first though as there may be things that we would need to explain to you such as abbreviations or medical words.

Can I have a copy of my records?

Yes! Your parent/ guardian will need to write to us (they can email us) to tell us what they want to see – it may just be part of your record, for example, an x ray or a report. We will check they are who they say they are to make sure we are not sharing your information with anyone who shouldn’t see it.

If I think some of my information is wrong can I do anything about it?

Yes! Your parent or guardian needs to contact The Practice Manager at the practice telling them what it is that you think is wrong.

If I’m unhappy with the way you’ve used some of my information can I do anything?

Yes! Let us know by contacting the Practice Manager, the person responsible for helping to run the practice, or you can contact the Information Commissioners Office.

We hope this notice tells you what you need to know about the information we collect about you.

If you want to know anything else, please contact the practice and we will make sure we listen you very carefully and look after your needs the best that we can.

Willows Health has the ability to record telephone calls to protect patients and staff and other health workers. Patients are protected by our having a record of our conversations with you, staff and other health workers are protected from potential abuse.

We record call for staff training and quality control. When you register with us, we will make this clear to you and we will also make this clear to you each time you contact us and via our web site and other sources of information calls that contain only administrative information, such as enquiries about appointments, and retained for 3 years and are then automatically deleted.

Calls, or transcripts of calls, audio or audio-visual recordings or elements of the discussion you have with the clinicians that contain clinical information may be added to your medical records, but this will be clarified with you at the time. The recordings are stored on the surgery telephone system

1) Data Controller contact details
Willows Group Ltd

2) Data Protection Officer contact details
Umar Sabat umar.sabat@ig-health.co.uk

3) Purpose of the processing
To facilitate your access to care and in the case of telephone or other audio visual consultations for your direct care.

4) Lawful basis for processing
The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the GDPR:
Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.
Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…” We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”

5) Recipient or categories of recipients of the shared data 
Necessary data will be shared with Health and care professionals and support staff in this surgery. Clinical data or records of consultations may be transcribed or appended to the records we hold on you and may thence be shared at hospitals, diagnostic and treatment centres who contribute to your personal care. Actual recordings will not be shared with anyone outside the practice. Please see our Privacy Notice for Direct Care. The actual recordings are stored on the telephone system and after a designated period of time will be either deleted or saved, onto the surgery Shared Drive if it is deemed necessary. You will be informed if the recording is to be stored for longer than is set out in this Privacy Notice and you will be informed of the reasons.

6) Rights to object 
You have the right to object to some or all your information being processed (shared) under current data protection legislation (Article 21 the General Data Protection Regulations 2016, and the Data Protection Act 2018).

7) Right to access and correct 
Access You have the right to see the data that is being shared about you. This is known as ‘the right of subject access’. You can make a request for this information from a provider.
If your health or care provider holds information about you, and you make a subject access request they will:
• Give you a description of it
• Tell you why it is being held
• Tell you who it could be shared with
• Let you have a copy of the information in an intelligible form.
To make a Subject Access Request, you will need to contact your health or care provider’s Data Protection Officer in writing. The contact details for the DPO for each organisation can be found in section 2 of this Privacy Notice as displayed by each individual organisation, or on their website.

Rectification
You have the right to have inaccurate personal data rectified, and in some circumstances removed. Requests to amend or delete data should be made to the individual Data Controller via the DPO, as per the contact information in section 2 of this Privacy Notice.
Under current data protection legislation, all data controllers have a responsibility to ensure the information held about you is correct and up to date and must take all reasonable steps to correct or erase incorrect information as soon as possible.
All requests to amend or remove information will be addressed on an individual basis by each Data Controller, however, it should be noted that, for example, information recorded by a health or care professional that is believed to be correct at the time of documentation, even when subsequently updated, is unlikely to be removed.
There is no right to have accurate medical records deleted except when ordered by a Court of Law

8) Retention period 
The phone provider stores call recordings for three years. This information can be accessed by the surgery during this period. Clinical data transcribed from your telephone or other electronic consultations may become part of your clinical record and is retained according to relevant rules and regulations, see Privacy Notice on Direct Care.

9) Right to Complain.
You have the right to complain to the Information Commissioner’s Office, you can use this link https://ico.org.uk/global/contact-us/
or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website)

Please note the National Data Opt Out does not apply to this sharing of information. For further information please see: https://www.nhs.uk/your-nhs-data-matters/

We are working closely with IDEOSHIFT Ltd, a trusted partner, to support us in delivering essential back-office functions. This collaboration includes services such as document processing, call handling, and routine administrative tasks that help ensure the smooth running of our operations.

To maintain high standards of confidentiality and data protection, all IDEOSHIFT staff involved in these processes receive appropriate training in data security and handling of personal information. As part of this arrangement, some data processing activities may take place outside of the UK, by sub-processors, specifically in India.

Any personal data processed in this way is handled strictly in accordance with UK data protection laws and is covered by the relevant international data transfer arrangements and agreements by the Information Commissioner’s Office (ICO), which ensure your information remains protected to the same high standards as if it were processed within the UK.

The data shared is used solely to support your care and to enhance the efficiency and effectiveness of our services. We are committed to maintaining your privacy and ensuring that your information is treated with the utmost care and respect at all times.