Practice Policies

Veritas Health Centre Privacy Notice Patient’s Personal Clinical Information

How We Use Your Personal Information

Veritas Health centre takes in responsibilities in relation to patient’s personal information security very seriously and in doing so has implemented this privacy notice to ensure compliance with the General Data Protection Regulation 2016 (GDPR). In this duty we are classed as your Data Controller.

This Privacy Notice explains why we collect information about you and how the information may be used.

The GDPR identifies Data Concerning Health as a Special Category of Personal Data.

In recognising this we are under a legal duty to ensure any personal information held is processed according to the following principles:

1. Lawfulness, fairness and transparency
2. Purpose limited
3. Data minimalized
4. Accurate
5. Storage is limited
6. We are accountable for our actions

We hold your personal data for one or more of the following reasons:

1. For the purposes of preventative medicine and health care treatment
2. For the reasons of public interests in the area of public health
3. For research of statistical purposes

Health care3 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 are used to help to provide you with the best possible healthcare. NHS health care 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. Examples of the types of records that we hold about you may include the following information:

• Details about you, such as your name, address, your carer/s, legal representatives and emergency contact details
• Any contact the Surgery has had with you, such as appointments, clinic visits, emergency appointments
• 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

Your records are used to facilitate the provision of relevant health care services. Information held about you may also be used to help protect the health of the public and also for the wider benefit of the NHS. Your personal information may also be used within the GP practice for clinical audit purposes in order 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 individually 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.

Medicines Management

This practice may conduct Medicines Management Reviews of medications prescribed to it’s patients. This consists of a review of repeat medications to ensure patients are prescribed the most appropriate, up to date and cost effective treatments. Medicines management staff may also conduct audits to help improve patient safety.

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 GDPR
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management
• Information: To Share or Not To Share Review

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

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)
• Where the law requires information to be passed on
• In accordance with the new information sharing principle following Dame Fiona Caldicott’s 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; and

• Where it is necessary for the purposes of facilitating any health related and/or medical treatment that you have consented to receive.

Who Are Our Partner Organisations?

We may also have to share information, subject to strict agreements on how it will be used, with the following organisations;

• NHS Trusts/Foundation Trusts
• Other GP Practices
• NHS Commissioning Support Units
• Independent Contractors such as dentists, opticians, pharmacists
• Local Pharmacies in relation to medication and other clinical issues relating to your health
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Group
• Social Care Services
• Health and Social Care Information Centre (HSCIC)
• Local Authorities
• Education Services
• Fire & Rescue Services
• Police & Judicial Services
• Private Sector Providers

Your Rights

Individuals have a number of rights in relation to the information that we hold about them. These rights include:

• The right to access information we hold about them and to obtain information about how we process it
• In some circumstances the right to withdraw their consent to our processing of their information, which they can do at any time. We may continue to process their information if we have another legitimate reason for doing so;
• In some circumstances, the right to receive certain information they have provided to us in an electronic format and/or request that we transmit it to a third party;
• The right to request that we rectify their information if it’s inaccurate or incomplete;
• In some circumstances, the right to request that we erase their information. We may continue to retain their information if we’re entitled or required to retain it:
• The right to object to, and to request that we restrict, our processing of their information in some circumstances. Again, there may be situations where individuals object to. Or ask us to restrict, our processing of their information but we’re entitled to continue processing their information and/or to refuse that request

Please ensure that any request concerning our processing of your personal information is provided to us in writing. Ordinarily there will be no charge to have a printed copy of the information held about you.

We are required unless there are extenuating circumstances to respond to you within one month.

Please note that in order to action any request 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.

Retentions and Destruction of Records

We will only use and store your Personal Information for as long as it is required for the purposes it was collected for. How long it will be stored for depends on the information in question, what it is being used for and, sometimes, statutory and/or regulatory legal requirements.

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.

Notification

The GDPR 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)

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential is

Dr G U Patel

Complaints

Should you have any concerns about how your information is managed by the Practice please contact the Practice Manager at the following address:

Veritas Health Centre

243-245 Chesterfield Road

Sheffield

S8 0RT

Tel: 0114 258 3997

Email: SHECCG.VeritasHealthCentre@nhs.net

If you are still unhappy following a review by the Practice you can then complain to the Information Commissioners Office (ICO). www.ioc.org.uk casework@ico.org.uk,

Telephone 0303 123 1113 (local rate) or 01625 545 745

COVID-19 Privacy Notice

(This Privacy Notice is to run alongside our standard Practice Privacy Notice)

Due to the unprecedented challenges that the NHS and we, Veritas Health Centre face due to the worldwide COVID-19 pandemic, there is a greater need for public bodies to require additional collection and sharing of personal data to protect against serious threats to public health. 

In order to look after your healthcare needs in the most efficient way we, Veritas Health Centre may therefore need to share your personal information, including medical records, with staff from other GP Practices including Practices within our Primary Care Network, as well as other health organisations (i.e. Clinical Commissioning Groups, Commissioning Support Units, Local authorities etc.) and bodies engaged in disease surveillance for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.

The Secretary of State has served notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) to require organisations to process confidential patient information in the manner set out below for purposes set out in Regulation 3(1) of COPI.

Purpose of this Notice

The purpose of this Notice is to require organisations such as Veritas Health Centre to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI. This Notice is necessary to require organisations such as Veritas Health Centre to lawfully and efficiently process confidential patient information as set out in Regulation 3(2) of COPI for purposes defined in regulation 3(1), for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.

Requirement to Process Confidential Patient Information

The Secretary of State has served notice to recipients under Regulation 3(4) that requires  to process confidential patient information, including disseminating to a person or organisation permitted to process confidential patient information under Regulation 3(3) of COPI, renewed 27 January 2021. Veritas Health Centre

Veritas Health Centre is only required to process such confidential patient information:

• where the confidential patient information to be processed is required for a Covid-19 Purpose and will be processed solely for that Covid-19 Purpose in accordance with Regulation 7 of COPI
• from 20^th March 2020 until 30 September 2021.

Covid-19 Purpose.

A Covid-19 Purpose includes but is not limited to the following:

• understanding Covid-19 and risks to public health, trends in Covid-19 and such risks, and controlling and preventing the spread of Covid-19 and such risks
• identifying and understanding information about patients or potential patients with or at risk of Covid-19, information about incidents of patient exposure to Covid-19 and the management of patients with or at risk of Covid-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from Covid-19
• understanding information about patient access to health services and adult social care services and the need for wider care of patients and vulnerable groups as a direct or indirect result of Covid-19 and the availability and capacity of those services or that care
• monitoring and managing the response to Covid-19 by health and social care bodies and the Government including providing information to the public about Covid-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services
• delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with Covid-19, including the provision of information, fit notes and the provision of health care and adult social care services
• research and planning in relation to Covid-19.

Recording of processing

 A record will be kept by Veritas Health Centre of all data processed under this Notice.

Sending Public Health Messages

Data protection and electronic communication laws will not stop Veritas Health Centre from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.

Digital Consultations

It may also be necessary, where the latest technology allows Veritas Health Centre to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.

Research and Pandemic Planning

The Secretary of State has directed NHS Digital to collect, process and analyse data in connection with COVID-19 to support the Secretary of State’s response to COVID-19 and support various COVID-19 purposes set out in the COVID-19 Public Health Directions 2020, 17 March 2020 (as amended) (COVID-19 Direction) and below. This enables NHS Digital to collect data and analyse and link the data for COVID-19 purposes with other data held by NHS Digital. 

The purpose of the data collection is also to respond to the intense demand for General Practice data to be shared in support of vital planning and research for COVID-19 purposes, including under the general legal notice issued by the Secretary of State under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI). 

 NHS Digital has therefore been requested by the joint co-chairs of the Joint GP IT Committee (JGPITC) (the BMA and RCGP) to provide a tactical solution during the period of the COVID-19 pandemic to meet this demand and to relieve the growing burden and responsibility on General Practices. On 15 April 2020 the BMA and RCGP therefore gave their support via JGPITC to NHS Digital’s proposal to use the General Practice Extraction Service (GPES) to deliver a data collection from General Practices, at scale and pace, as a tactical solution to support the COVID-19 response in the pandemic emergency period.

It is a requirement of the JGPITC that all requests by organisations to access and use this data will need to be made via the NHSX SPOC COVID-19 request process, that will triage and prioritise these requests and refer appropriate requests on to the NHS Digital Data Access Request Service (DARS).   NHS Digital will consult with representatives of the BMA and the RCGP on all requests for access to the data. An outline of the process for this agreed with the BMA and the RCGP is published here. Requests by organisations to access record level data from this collection will also be subject to Independent Group Advising on the Release of Data (IGARD) consideration. Data applicants will need to demonstrate they have a lawful basis to access the data for COVID-19 purposes. 

Benefits of this sharing

Organisations, including the Government, health and social care organisations and researchers need access to this vital data for a range of COVID-19 purposes, to help plan, monitor and manage the national response to the COVID-19 pandemic, which will help save lives. COVID-19 purposes for which this data may be analysed and used may include:

• understanding COVID-19 and risks to public health, trends in COVID-19 and such risks, and controlling and preventing the spread of COVID-19 and such risks

• identifying and understanding information about patients or potential patients with, or at risk of COVID-19, information about incidents of patient exposure to COVID-19 and the management of patients with or at risk of COVID-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID19

• understanding information about patient access to health services and adult social care services as a direct or indirect result of COVID-19, and the availability and capacity of those services • monitoring and managing the response to COVID-19 by health and social care bodies and the Government including providing information to the public about COVID-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services

• delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with COVID-19, including the provision of information, fit notes and the provision of health care and adult social care services; and

• research and planning in relation to COVID-19.

Data may be analysed and linked to other data held by NHS Digital or held by other organisations to which access to the data is granted for COVID-19 purposes, through the process described above.

Data will be collected nationally from all GP Practices by NHS Digital every fortnight. All requests to access this data will be triaged through the NHSX SPOC COVID-19 request process and assessed and fulfilled by NHS Digital through DARS. This will significantly reduce the burden on General Practice at a time when demand on resources is high, enabling General Practice to focus on delivering health care and support to patients. It will also reduce compliance burden and risk for General Practice associated with sharing data and complying with the terms of the general legal notice issued under COPI, which applies to General Practices.

Legal Basis for this collection

NHS Digital has been directed by the Secretary of State under section 254 of the 2012 Act under the COVID-19 Direction to establish and operate a system for the collection and analysis of the information specified for this service: GPES Data for Pandemic Planning and Research (COVID-19). A copy of the COVID-19 Direction is published here:  https://digital.nhs.uk//about-nhs-digital/corporate-information-and-documents/directions-anddata-provision-notices/secretary-of-state-directions/covid-19-public-health-directions-2020.

Details of the information to be collected can be found on the NHS Digital website – Specification of this DPN. Type 1 objections will be upheld in collecting this data from General Practices and therefore the data for those patients who have registered a Type 1 objection with their GP will not be collected. The Type 1 objection prevents an individual’s personal identifiable confidential information from being shared outside of their GP Practice except when it is being used for the purposes of their direct care. The National Data Opt-Out will not apply to the collection of the data, as this is a collection which is required by law. 

This information is required by NHS Digital under section 259(1)(a) of the 2012 Act to comply with the COVID-19 Direction. In line with section 259(5) of the 2012 Act, all organisations in England that are within the scope of this Notice, as identified below under Health and Social Care Bodies within the scope of the collection, must comply with the requirement and provide information to NHS Digital in the form, manner and for the period specified in this Notice.   This Notice is issued in accordance with the procedure published as part of NHS Digital’s duty under section 259(8) of the 2012 Act. 

In August 2020, the NHS announced that the seasonal national flu immunisation programme criteria for 2020 - 2021 will be expanded to include patients on the SPL. Therefore, to provide information that will support the identification of patients at moderate or high risk of complications from flu, a revision to the weekly extract of data has taken place. This, version three of the extract for the purpose of maintaining and updating the SPL, will continue until the expiry of the COVID-19 Direction. This is currently 31 March 2022 but will be reviewed in September 2020 and every six months thereafter. The frequency of the data collection may change in response to demand.

The Secretary of State has directed NHS Digital to collect, process and analyse data in connection with COVID-19 to support the Secretary of State’s response to COVID-19 and support various COVID-19 purposes set out in the COVID-19 Public Health Directions 2020, 17 March 2020 (COVID-19 Direction) (as amended) (COVID-19) Direction) and below. This enables NHS Digital to collect data and analyse and link the data for COVID-19 purposes with other data held by NHS Digital. The rationale for changing the data extraction is that the initial data collection was based on an existing specification for flu vaccination eligibility. This data extraction was then refined in order to more accurately reflect the patients who are clinically extremely vulnerable to COVID-19 and also to minimise the data we are collecting. A further refinement of the data extraction has taken place leading to the inclusion of new data being extracted. This will provide information to inform vaccination programmes. This General Practice Extraction

Service (GPES) data will be extracted weekly and be used to assist in producing a weekly update of the SPL. The objective of this collection is on an ongoing basis to identify patients registered at General Practices who may be: • clinically extremely vulnerable if they contract COVID-19 • at moderate or high risk of complications from flu or COVID-19. The data collected will be analysed and linked with other data NHS Digital or other organisations hold to identify: • a list of clinically extremely vulnerable patients who will be advised to take shielding measures to protect themselves. Advice given to these patients has been published by Public Health England and is available here: https://www.gov.uk/government/publications/guidance-on-shielding-and-protectingextremely-vulnerable-persons-from-covid-19/guidance-on-shielding-and-protectingextremely-vulnerable-persons-from-covid-19#what-do-we-mean-by-extremelyvulnerable • a list of patients at moderate or high risk of complications from flu to inform the flu call/recall vaccination programme.

Further information on the flu programme can be found here: https://www.england.nhs.uk/wpcontent/uploads/2020/05/Letter_AnnualFlu_2020-21_20200805.pdf

The extract may also be used for future direct care purposes relating to the COVID-19 outbreak. The methodology NHS Digital has used to produce the SPL is explained in detail and is published on the NHS Digital SPL website page here:

https://digital.nhs.uk/coronavirus/shielded-patient-list Patients

added to the SPL will be contacted by post, email (and/or SMS message where this is necessary) by the NHS on behalf of the Chief Medical Officer, Chris Whitty, to:

• advise of the measures they can take to reduce their risk of contracting the virus and sign-post them to the Extremely Vulnerable Persons service operated by gov.uk at https://www.gov.uk/coronavirus-extremely-vulnerable

• offer a flu vaccination or to contact non-responders who remain unvaccinated (as per NHS England specifications for the service). The SPL will also be used to inform GPs of their individual patients on the SPL, by flagging those patient records on GP patient record systems. The SPL will be shared with a variety of other organisations involved in the care and support of those patients and for planning, commissioning and research purposes associated with COVID-19. Full details of those with whom information has been shared can be found on the NHS Digital SPL website here:

https://digital.nhs.uk/coronavirus/shielded-patient-list/distribution.

Requests by organisations to access record level data from this collection will be subject to Independent Group Advising on the Release of Data (IGARD) consideration. Data applicants will need to demonstrate they have a lawful basis to access the data for COVID-19 purposes.

Benefits of the collection

Organisations, including Government, health and social care organisations need to access this vital data for a range of COVID-19 purposes, to help plan, monitor and manage the national response to the COVID-19 pandemic, which will help save lives. COVID-19 purposes for which this data may be analysed and used may include: • understanding COVID-19 and risks to public health, trends in COVID-19 and such risks, and controlling and preventing the spread of COVID-19 and such risks • identifying and understanding information about patients or potential patients with, or at risk of COVID-19, information about incidents of patient exposure to COVID-19 and the management of patients with or at risk of COVID-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID19. Data will be analysed and linked to other data held by NHS Digital or held by other organisations to which access to the data is granted for COVID-19 purposes, through the process described above. Data will be collected nationally from all General Practices by NHS Digital every week. All requests to access this data will be through Data Access Request Service (DARS). This will significantly reduce the burden on General Practice at a time when demand on resources is high, enabling General Practice to focus on delivering health care and support to patients. It will also reduce compliance burden and risk for General Practice associated with sharing data and complying with the terms of the general legal notice issued under the National Health Service (Control of Patient Information Regulations) 2002 (COPI), which applies to General Practices Patients facing the greatest risk if they contract COVID-19 and/or are in the moderate to high risk of complications from flu:

• will be identified and known to health organisations
• will have a greater awareness of the recommended preventative shielding measures
• will be able to follow clear advice
• will be able to ask for help and support, including social care support and essential food supplies, through the Extremely Vulnerable Persons service operated by gov.uk.

It will enable the SPL to be updated weekly to identify new patients and changes to patients on the List and will enable support provisions to be more dynamic and responsive to both social and clinical need.

It will also enable vital planning, commissioning, and research to be carried out for COVID-19 purposes. If patients facing the greatest risk follow advice, it is hoped that this will contribute to the delay and mitigation of the spread of COVID-19 and save lives.

Visitors to The Practice

We have an obligation to protect our staff and employees’ health, so it is reasonable for staff at Veritas Health Centre to ask any visitors to our practice to tell us if they have visited a particular country, or are experiencing COVID-19 symptoms. This must only be in pre-approved circumstances and we would also ask all patients to consider government advice on the NHS 111 website and not attend the practice.

Where it is necessary for us to collect information and specific health data about visitors to our practice, we will not collect more information than we need, and we will ensure that any information collected is treated with the appropriate safeguards.

 Review and Expiry of this Notice

This Notice will be reviewed on or before 30 September 2021 and may be extended by The Secretary of State.  If no further notice is sent to Veritas Health Centre by The Secretary of State this Notice will expire on 30 September 2021.