Policies and Procedures

The Surgery prides itself in maintaining professional standards. For certain examinations during consultations an impartial observer (a “Chaperone”) will be required.

This impartial observer will be a member of the team who is specially trained to be a chaperone. They will be familiar with the procedure and be available to reassure and raise any concerns on your behalf. If a chaperone is unavailable at the time of your consultation then your examination may be re-scheduled for another time.

You are free to decline any examination or chose an alternative examiner or chaperone. You may also request a chaperone for any examination or consultation if one is not offered to you. The GP may also ask for a chaperone. They may not undertake an examination if a chaperone is declined.

The role of a Chaperone:

• Maintains professional boundaries during intimate examinations.
• Acknowledges a patient’s vulnerability.
• Provides emotional comfort and reassurance.
• Assists in the examination.
• Assists with undressing patients, if required.

If you have a complaint or concern about the service you have received from the doctors or any of the staff working in this GP surgery, please let us know. This includes Primary Care Network staff working as part of our GP surgery. We operate a complaints procedure as part of an NHS system for dealing with complaints. Our complaints system meets national criteria.

How to complain

We hope that most problems can be sorted out easily and quickly when they arise and with the person concerned. For example, by requesting a face-to-face meeting to discuss your concerns.

If your problem cannot be sorted out this way and you wish to make a complaint, we would like you to let us know as soon as possible. By making your complaint quickly, it is easier for us to establish what happened. If it is not possible to do that, please let us have details of your complaint:

• Within 6 months of the incident that caused the problem; or
• Within 6 months of discovering that you have a problem, provided this is within 12 months of the incident.

Complaints should be addressed to the GP surgery team verbally or in writing to the Practice Manager. Alternatively, you may ask for an appointment with the GP surgery to discuss your concerns. They will explain the complaints procedure to you and make sure your concerns are dealt with promptly. Please be as specific as possible about your complaint.

What we will do

We will acknowledge your complaint within three working days. We will aim to have investigated your complaint within ten working days of the date you raised it with us. We will then offer you an explanation or a meeting with the people involved, if you would like this. When we investigate your complaint, we will aim to:

• Find out what happened and what went wrong.
• Make it possible for you to discuss what happened with those concerned, if you would like this.
• Make sure you receive an apology, where this is appropriate.
• Identify what we can do to make sure the problem does not happen again.

Complaining on behalf of someone else

We take medical confidentiality seriously. If you are complaining on behalf of someone else, we must know that you have their permission to do so. A note signed by the person concerned will be needed unless they are incapable (because of illness) of providing this.

Complaining to NHS England

We hope that you will use our Practice Complaints Procedure if you are unhappy. We believe this will give us the best chance of putting right whatever has gone wrong and an opportunity to improve our GP surgery.

However, if you feel you cannot raise the complaint with us directly, please contact NHS England. You can find more information on how to make a complaint at https://www.nhs.uk/using-the-nhs/about-the-nhs/how-to-complain-to-the-nhs/

Unhappy with the outcome of your complaint?

If you are not happy with the way your complaint has been dealt with by the GP surgery and NHS England and would like to take the matter further, you can contact the Parliamentary and Health Service Ombudsman (PHSO). The PHSO makes final decisions on unresolved complaints about the NHS in England. It is an independent service which is free for everyone to use.

To take your complaint to the Ombudsman, visit the Parliamentary and Health Service Ombudsman website or call 0345 015 4033

Need help making a complaint?

If you want help making a complaint, Healthwatch Hounslow can help you find independent NHS complaints advocacy services in your area.

Alternatively, POhWER is a charity that helps people to be involved in decisions being made about their care. Call POhWER’s support centre on 0300 456 2370 for advice.

If you have any special needs please let our staff know so that we can help and ensure that you get the same support in the future.

Wheelchair access

The Surgery has been specially designed to make it easier for disabled patients to visit. There are no steps at the entrance of the building giving patients easy access. Due to fire regulations, we do have heavy fire doors, however if you have trouble opening these please ask Reception for assistance as they are always happy to help.

There are several dedicated disabled car parking spaces available immediately outside the front entrance of The Surgery.

We have a wheelchair for patient’s use, at their own risk, should you require one whilst visiting our premises.

Disabled Parking – Blue Badge Scheme

The Blue Badge scheme is for people with severe mobility problems. It allows Blue Badge holders to park close to where they need to go.

Loop System

We have a loop induction system at the reception desk to assist the hearing impaired. For more information on the loop hearing system visit Hearing Link website.

• British Deaf Association
• The Deaf Health Charity – SignHealth
• Action Hearing Loss
• Royal Association for Deaf People
• National Deaf Children’s Society

Blind/Partially Sighted

If you or family members are blind or partially sighted we can give you a CD or large print of our practice leaflet upon request. Please ask Reception for further information.

For more advice and support for blind people please see the following websites:

• Royal National Institute of Blind People (RIND)
• Action for Blind People
• Blind.org.uk
• British Blind Sport

Guide Dogs

Guide dogs are welcome at the surgery but we ask that you be aware of other patients and staff who may have an allergy or fear of dogs.

Further Information:

• Guide Dogs

Other Disability Websites:

• BID Services
• Disability Go
• Disabled People, your Rights, Benefits, Carers and the Equality Act
• Disability Rights UK
• Living with a Disability NHS Choices
• Disability Action
• Mencap

Privacy Notice 

Your information, what you need to know 

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

Why we collect information about you 

Patients 

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 within any NHS organisation. These records help to provide you with the best possible healthcare and help us to protect your safety. 

We collect and hold data for 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 may collect information about you which helps us respond to your queries or secure specialist services.  

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments. We may keep your information in written form and/or in digital form. 

The records may include basic details about you, such as your name and address.  They may also contain more sensitive information about your health and also information such as outcomes of needs assessments. 

Staff 

As employers we are required to keep records about your employment to ensure we meet our legal responsibilities for example to ensure all employees have the right to work in the UK and to enable the development of a comprehensive understanding our workforce and how it is deployed to support our business functions. 

We collect and hold data to: 

• Inform the development of HR policies 
• Support workforce planning 

• Make recruitment decisions 
• Enable staff to be paid and have the correct pension contributions deducted 
• Monitor timekeeping and attendance 
• Assess training needs and maintain training records 
• Implement disciplinary and grievance processes  

• Maintain up to date records to ensure effective correspondence and ensure that we can contact you or your next of kin in an emergency.  For example, your details are shared with the payroll company for calculation of salary and production of payslip and the bank to pay you. 

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and disciplinary matters. We may keep your information in written form and/or in digital form. 

Details we collect about you 

Patients 

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP surgeries, A&E, etc.). These records help to provide you with the best possible healthcare. 

Records which this GP practice may hold about you include the following: 

• Details about you, such as your address and next of kin 
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc. 
• Notes and reports about your health 

• Details about your treatment and care 
• Results of investigations, such as laboratory tests, x-rays, etc. 
• Relevant information from other health professionals, relatives or your carers 
• The practice may receive emails and letters about your care (most frequently from hospitals and community services).  These are scanned into your medical record and the originals are shredded using a confidential waste company. 
• Patients can email the practice ([email protected]).  These emails may be saved into your record if clinically relevant.  If not clinically relevant (e.g. a prescription request once actioned does not need to be added to your medical record) it will be deleted. 

How we keep your information confidential and safe 

Everyone working for our organisation is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this. 

The health records we use 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. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel. 

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed. 

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

• Data Protection Act 2018 
• General Data Protection Regulation 
• Human Rights Act 
• Common Law Duty of Confidentiality 
• NHS Codes of Confidentiality and Information Security 

• Health and Social Care Act 2015 
• And all applicable legislation 

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on. 

How we use your information 

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for 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 section below. 

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below. 

You may choose to opt-out to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start. 

Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared. 

You can object to your personal information being shared with other healthcare providers which will not affect your entitlement to care, but you should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object. 

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. 

Practice Website (Argyle Health Isleworth Practice | NHS GP Surgery in Hounslow) 

Passive information collection and use 

As you navigate through our website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, internet tags and navigational data collection. 

Please read the section on Cookies below and review the Cookie Settings for detailed information about Cookies and other tracking technologies used on our site. In this policy you will also find information on how to disable cookies and tracking technologies if you do not agree to their use as well as the consequence(s), if any, of disabling each specific cookie/tracking technology. If you do not disable any cookies or tracking technologies, we will infer your consent to their use. 

We and our third party service providers may passively collect and use information in a variety of ways, including: 

• Through your browser -  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device. 
• IP Address – Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site. 
• Using pixel tags, web beacons, clear GIFs, or other similar technologies -  These may be used in connection with some site pages and HTML-formatted e-mail messages to, among other things, track the actions of site users and e-mail recipients, and compile statistics about Site usage and response rates. 
• Device Information – We may collect information about your mobile device, such as a unique device identifier. 

Cookies and IP addresses  

A cookie is a small text file that is downloaded onto a computer or smartphone when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions. We use these to monitor access to our website and tailor any developments based on usage and pages visited. 

We use Google Analytics software on this site to anonymously track how visitors interact with this website. This includes identifying: 

• The pages visited on this site 
• How long the visitor spends on each page on this site 

• How visitors got to the site 
• What visitors click on while visiting the site 

We do this to help make sure the site is meeting the needs of visitors and help us make improvements, for instance improving site search. 

We don’t use cookies to track the identity of visitors or the information they have entered into the site. 

You give us consent to using cookies for analytic purposes if you continue to use our website. Alternatively, you can switch off cookies in your browser and the site will still work normally. 

Third Party Sites and Services 

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any App) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates. 

Security 

We use reasonable organisational, technical and administrative measure to protect personal information under our control and in accordance with this privacy policy. 

Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk. 

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section. 

Cross Border Transfers 

Personal information other than medical data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms to send communication emails to our users. 

Patients and staff 

CCTV 

Images are recorded to protect staff and practice property. It will not be used for any other purpose. Images from the CCTV system are securely stored and only authorised personnel may access them. The recorded images will only be retained long enough for any incident to come to light (e.g. for a theft to be noticed) and the incident to be investigated. Except for law enforcement bodies, images will not be provided to third parties. 

Telephone Recording 

All calls are recorded for training and quality purposes.  There is an announcement on the telephone system to alert anyone calling the surgery that calls may be recorded. Telephone calls are stored securely and only accessed by authorised personnel. 

How we keep your information confidential and safe 

Patients 

Everyone working for our organisation is subject to the Common Law Duty of Confidentiality. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this. 

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on. 

Patients and staff 

The records we use 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. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel. 

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed. 

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

• Data Protection Act 2018 
• Human Rights Act 
• Common Law Duty of Confidentiality 

• NHS Codes of Confidentiality and Information Security 
• Health and Social Care Act 2015 
• And all applicable legislation 

How we use your information 

Patients 

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for 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 section below. 

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below. Please also see https://digital.nhs.uk/data-and-information/looking-after-information for more information. 

You may choose to withdraw your consent to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start. 

Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared. Please see right to withdraw consent section below. 

You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object. 

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. 

Accurx 

Accurx is a clinical text messaging software that allows two-way communication between patients and the practice.   

Child Health Information – CHIS 

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS health visitors and school nurses, with the NWL Commissioning Support Unit, who provide the Child Health Information Service (CHIS) on behalf of NHS England.   

Clinical audit 

Information may be used by the ICB for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data. 

Clinical Research 

Sometimes your information may be requested to be used for research purposes – we will normally ask your permission before releasing your information for this purpose. 

In some instances, the Confidentially Advisory Group, part of the Health Research Authority may allow for identifiable information to be shared with researchers without consent of individuals. You may however opt-out of this, details of which can be found below under the ‘National Data Opt-Out’. 

Electronic Prescribing Service (EPS) 

We share information about your medications with your pharmacy when you inform us of your usual pharmacy.  This allows your repeat medication prescription to be sent securely to your preferred pharmacy so that you do not need to attend the surgery to collect your prescription. 

Enhanced Data Sharing Module  

The Argyle Health Isleworth Practice uses TPP SystmOne and this allows you to choose whether other health and care providers can access your information to help provide you with care. We have drawn up an “allowed list” of local organisations with whom we can share your data (when you register for their services and give them verbal permission to provide your care through a TPP clinical system). See the link below under who are our partner organisations. 

Organisations outside of this allowed group who use the same software will require formal documented permission to see your records. Your GP system will send you an SMS or email which you can give to the organisation asking for access which will formally validate your consent. It is possible for you to set your own specific permissions (as distinct from the allowed list we have provided).  

GP Connect 

We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.
GP Connect is not used for any purpose other than direct care. 

Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS Digital service called GP connect.  

The NHS 111 service (and other services determined locally e.g. Other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services.  

Further information can be found here: https://digital.nhs.uk/services/gp-connect 

Improving Diabetes Care and long-term condition management 

We share information about patients with diabetes with the Diabetic Retinopathy Screening Service (DRSS) to ensure that all diabetic patients receive annual screening. 

Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients. 

Individual Funding Request 

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for 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 taken under consideration 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. 

Invoice Validation 

Invoice validation is an important process. It involves using your NHS number to check which ICB is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly. 

Local Information Sharing 

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. In order to provide you with health and social care services your GP practice works in close collaboration with neighbouring practices as part of a Primacy Care Network (PCN).  Our practice is part of The Ealing Network PCN. The organisational boundary within which professionally trained staff can access your health record without consent has extended from your GP practice to this Primary Care Network and staff employed on its behalf. Staff are trained to understand their legal and professional responsibilities of confidence to their patients and will only access your records when they are required to do so to support you care. They will identify themselves and their role using a smart card and access to your PCN record is recorded, monitored, and audited. 

If you require attention from a local health or care professional outside of your usual PCN services, such as in an Evening and Weekend GP Hub services, Emergency Department, Minor Injury Unit or Out of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent. 

Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or EMIS remote consulting system). 

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Aside from your registered health care provider, your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged). 

MISL 

We use a secure storage service to store our patient records off site. 

MJOG 

We use a text messaging platform called MJOG to send text messages regarding health campaigns and screening and to ask for feedback about our services.  

National Fraud Initiative – Cabinet Office 

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice.  

National Registries 

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user. 

NHS Digital 

The NHS needs data about the patients it treats in order to plan and deliver its services and to ensure that care and treatment provided is safe and effective.  The General Practice Data collection for planning and research will help the NHS to improve health and care services for everyone by collecting patient data that can be used to so this.  We have agreed to share the patient data we look after in our practice with NHS Digital who will securely store, analyse, publish and share this patient data to improve health and care services for everyone.  This includes: 

• Informing and developing health and social care policy 
• Planning and commissioning health and care services 
• Taking steps to protect public health including managing and monitoring the covid pandemic 
• In exceptional circumstances, providing you with individual care 
• Enabling healthcare and scientific research 

This means that we can get on with looking after our patients and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it to improve health and care for everyone. 

Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality. 

Data may be shared from the GP medical records about: 

• any living patient registered at a GP practice in England when the collection started – this includes children and adults 
• any patient who died after this data sharing started, and was previously registered at a GP practice in England when the data collection started 

We will not share your name or where you live. Any other data that could directly identify you, for example your NHS number, General Practice Local Patient Number, full postcode and date of birth, is replaced with unique codes which are produced by de-identification software before the data is shared with NHS Digital. 

NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and GP practices. 

The full privacy notice can be found here: NHS Digital Privacy Notice 

NHS England and Open Exeter 

NHS England has a legal duty to keep a list of all patients registered with GP Practices in England. This list is held in the National Health Application and Infrastructure Services (NHAIS) systems.  These systems also hold data about patients registered with GPs in Wales and the Isle of Man. NHS Digital, and other service agencies around the country manage these systems on behalf of NHS England. 

The data are used to provide Primary Care Support Services. NHS England has a contract with Capita Business Services Ltd, operating as Primary Care Support England to provide these services which include: 

• Moving paper patient records between practices and into storage when patients leave or move practices 
• Storing paper records of unregistered and deceased patients 
• Sending letters to patient to inform them of their NHS number when one is first allocated 
• Providing the cervical cytology call and recall administrative service on behalf of Public Health England 

• Delivering prior notification lists of patients eligible for screening to GPs 
• Processing new patient registrations and de-registrations at GP practices to maintain accurate lists of numbers of patients at GP Practices– 
• Making payments to NHS Ophthalmic practitioners for NHS services provided 
• Making payments to GP practices based on lists of registered patients, and specific payments for childhood vaccinations and immunisations 
• Writing to patients on behalf of Primary Care commissioners with regards to provision of primary care services or assignment to a GP Practice list. 

• Writing to patients when they have been removed from their GP Practice list 
• Conducting audits and reconciliations of GP Practice lists to ensure list sizes are accurate. 

The data from the NHAIS list is used to update the Personal Demographics Service (PDS). This provides information for hospitals, Public Health England Cancer Screening Programmes, Child Health systems and other health providers making sure that they know their patients’ current GP Practice and can access other essential information such as the Summary Care Record. 

NHS England Regional Local Teams (RLTs) and Integrated Care Boards (ICBs) (where delegated) may also undertake necessary processing of a limited subset of these data (e.g. patient name, address, postcode and NHS number) for example when managing practice closures and list dispersals (the process used to allocate patients to neighbouring GP Practices). This processing is necessary to inform patients of their reregistration options and ‘Choice’ as required under the NHS Constitution. 

Sources of the data:  The data are transferred automatically from GP practice systems in to the NHAIS systems. The data is also updated by Primary Care Support England after notifications from data subjects themselves. 

The categories of personal data held on the systems are: 

• Name – including any previous names, unless name changes are the result of adoption, gender reassignment or witness protection schemes 
• Current and historic addresses and whether the address is a registered nursing home 
• Dates of Birth 
• Gender 

• Place of Birth 
• NHS number 
• Cervical Screening history 
• Special allocation scheme status 
• Current and Previous GP practice details 

• GPs Banking details 

Categories of recipients:  Statistical information (numbers) produced from NHAIS systems is shared with other organisations to enable them to fulfil their statutory obligations, for example the Office of National Statistics, Public Health England and local authorities for their public health purposes. Personal data may also be shared with the approval of NHS England’s Caldicott Guardian when he is assured that confidentiality is respected, for example when hospitals need to update their records for direct care purposes or to support specific research projects with ethical and or Health Research Authority approval. 

Patient Participation Group (PPG) 

We invite all patients at point of registration and opportunistically thereafter if they would like to be part of our Patient Participation Group.  Email addresses and contact details are kept securely for the purpose of communicating with the group about meetings and any other events or issues we would like the PPG’s opinion on. 

Public Health 

We share information about patients with Public Health England in relation to notifiable diseases (e.g. measles, salmonella), screening programmes (cervical cytology) and childhood immunisations. 

Shred it 

The practice uses shred it a document shredding service to securely dispose of confidential material 

Risk Stratification 

‘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 a number of 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. 

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the NWL Clinical Commissioning Group. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from: 

NHS England » Risk Stratification 

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.  Please see below for more information on how to withdraw consent. 

Safeguarding 

To ensure that adult and child safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned. 

Summary Care Record (SCR) 

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. 

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reasons for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement. 

During the height of the pandemic changes were made to the Summary Care Record (SCR) to make additional patient information available to all appropriate clinicians when and where they needed it, to support direct patients care, leading to improvements in both care and outcomes. 

These changes to the SCR will remain in place, unless you decide otherwise. 

Regardless of your past decisions about your Summary Care Record preferences, you will still have the same options that you currently have in place to opt out of having a Summary Care Record, including the opportunity to opt-back in to having a Summary Care Record or opt back in to allow sharing of Additional Information. 

You can exercise these choices by doing the following: 

1.   Choose to have a Summary Care Record with all information shared. This means that any authorised, registered and regulated health and care professionals will be able to see a detailed Summary Care Record, including Core and Additional Information, if they need to provide you with direct care. 

2.   Choose to have a Summary Care Record with Core information only. This means that any authorised, registered and regulated health and care professionals will be able to see limited information about allergies and medications in your Summary Care Record if they need to provide you with direct care. 

3.   Choose to opt-out of having a Summary Care Record altogether. This means that you do not want any information shared with other authorised, registered and regulated health and care professionals involved in your direct care. You will not be able to change this preference at the time if you require direct care away from your GP practice. This means that no authorised, registered and regulated health and care professionals will be able to see information held in your GP records if they need to provide you with direct care, including in an emergency. 

To make these changes, you should inform your GP practice or complete this form and return it to your GP practice. 

Supporting Medicines Management 

NWL ICB uses pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the ICB medicines management team may provide support relating to obtaining medications on behalf of your GP Practice to support your care. 

Supporting Locally Commissioned Services 

ICBs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality. The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide. 

Suspected Cancer 

Data may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital NHS Foundation Trust, London North West Healthcare NHS Trust and University College London Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual patients. 

Universal Care Plan (UCP – formerly CMC) 

UCP is a platform which gives patients an opportunity to express their wishes about how and where they are treated. It enables all healthcare professionals to offer more personalised medical care, with full respect to each patient’s preferences. 

Data Retention 

We manage patient records in line with the Records Management Code of Practice which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.  

Our partner organisations 

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

• NHS Trusts 

• Specialist Trusts 
• GP Federations 
• Independent Contractors such as dentists, opticians, pharmacists 
• Private Health Sector Providers e.g. Bupa 
• Voluntary Sector Providers e.g. carers centre 

• Ambulance Trusts 
• Integrated Care Boards 
• Local Authorities e.g. social services 
• Education Services e.g. school nurses 
• Fire and Rescue Services 

• Police 
• Other ‘data processors’ 

We will not share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function. No information will ever be shared where we do not have a lawful basis to do so. 

Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below). 

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence. 

Right to withdraw consent to share personal information (Opt- Out) 

Patients 

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data. 

There are two main types of opt-out. 

Type 1 Opt-Out 

If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to register a Type 1 opt out please fill out the form below and email it to [email protected] 

National Data Opt-Out 

NHS Digital have created an opt-out system named the National Data Opt-Out which allows individuals to opt-out of their information being used for planning and research purposes. From 25 May 2018, NHS Digital has had to apply this opt-out for all their data flows, and from 2020 all health and care organisations will have to ensure the opt-out is respected. Individuals who previously opted out with a ‘Type 2’ objection will not have to do anything as you will be automatically be opted out.  

If you wish to apply the National Opt-Out, please go to NHS Digitals website here https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/ 

Access to your information 

Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing or speak to a member of the Practice staff. Under special circumstances, some information may be withheld.  

If you wish to have a copy of the information we hold about you, please email the Practice Manager at [email protected] 

Our practice is compliant with the National Data Opt Out 

Staff 

You have the following rights in relation to the personal data we hold on you: 

• The right to be informed about the data we hold on you and what we do with it 
• The right of access to the data we hold on you 

• The right for any inaccuracies in the date we hold on you, however they come to light to be corrected.  This is also known as “rectification” 
• The right to have data deleted in certain circumstances. This is also known as “erasure” 
• The right to restrict the processing of data.  
• The right to transfer the data we hold on you to another party. This is also known as “portability” 

If you wish to exercise any of these rights please speak to the Practice Manager 

Access to your information 

Patients and staff 

Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.  

If you wish to have a copy of the information we hold about you, please contact, the Practice Manager  

Change of Details  

Patients 

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 are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date. 

Staff 

Please let your line manager know if there are any changes to your details so that our records for you are accurate and up to date. 

Mobile telephone number 

Patients 

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

Notification 

The Data Protection Act 2018 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 at: https://ico.org.uk/ESDWebPages/Entry/ZA275301 

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

Complaints 

If you have concerns or are unhappy about any of our services, please contact the Practice Manager, or email [email protected] 

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 

Information we are required to provide you 

Further Information 

Further information about the way in which the NHS uses personal information and your rights in that respect can be found at the links below. 

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 the Data Protection Act 2018. 

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 programmes 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 

Reviews of and Changes to our Privacy Notice 

We will keep our Privacy Notice under regular review. This notice was last reviewed in March 2023 

The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:

• Have a publication scheme in place
• Allow public access to information held by public authorities.

The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.

Public authorities include government departments, local authorities, the NHS, state schools and police forces.

The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.

The Surgery publication scheme

A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:

• who we are and what we do
• what we spend and how we spend it
• what our priorities are and how we are doing it
• how we make decisions
• our policies and procedures
• lists and registers
• the services we offer

You can request our publication scheme leaflet at the surgery.

Who can request information?

Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use. 

How should requests be made?

Requests must:

• be made in writing (this can be electronically e.g. email/fax)
• state the name of the applicant and an address for correspondence
• describe the information requested.

What cannot be requested?

Personal data about staff and patients covered under Data Protection Act.

For more information see these websites:

• Legislation GOV.UK
• Information Commissioners Office

All GP Practices are required to declare mean earnings (i.e. average pay) for GPs working to deliver NHS services to patients at each practice.

The average pay for GPs working in the practice of The Argyle Surgery in the last financial year was £21,806 before tax and National Insurance.

This is for 5 part time GPs and 3 part time locum GPs who worked in the practice for more than six months.

NHS England require that the net earnings of doctors engaged in the practice is publicised. However, it should be noted that the prescribed method of calculating earnings is potentially misleading because it takes no account of how much time doctors spend working in the practice and should not be used for any judgement about GP earnings, nor to make any comparisons with other practices.

Visiting patients at home is part of the GP contract but it is the doctor’s decision whether or not the patient can be reasonably expected to attend the surgery.

GP home visits cannot replace the emergency services for several reasons. However GPs should visit patients at home if their medical condition makes it inappropriate for them to attend the surgery.

Each visit should be triaged to ensure it is appropriate.

There are many reasons why a home visit might not be appropriate for the patient:

• It can delay clinical assessment, as visiting cannot be carried out on an emergency basis, whereas assessing patient in the surgery might be. Travelling to and from home visits can delay clinical assessment as the doctor may not be able to locate the patient’s address as quickly as the patient can attend the surgery.
• Travelling to and from home visits, when clinically not needed, could prejudice the care of patients in the surgery, as the absent doctor will not be able to treat routine or emergency patients whilst away from the surgery.
• The environment in a patient’s home is not ideal for clinical examination and assessment.
• Equipment for assessment and treatment by a GP which is portable to a patient’s home is not as effective as the equipment in the surgery.

Also by taking a GP out of the surgery to do a home visit, including the travel time there and back means they are not able to respond to urgent problems in the practice and this needs to be weighed up against the necessity of the visit.

These are not appropriate reasons for a home visit request:

• Transport issues – We may be able to offer assistance for example with plusbus but overall it is not the responsibility of the practice to arrange transport to help the patients get to the surgery.
• Childcare issues
• Poor mobility – At the GPs discretion patients with poor mobility may be visited but it would be usual for these patients to attend the surgery unless truly housebound. If patients are able to attend appointments elsewhere they should be able to attend the practice.
• Unwell children – Children in particular are best assessed in the practice so that the GP has the best equipment / medication to hand. If a child is truly too unwell to bring to the surgery it is likely that the triage advice would be to call 999 to avoid any further delays in treatment.
• Residents of care homes – This in itself does not automate a home visit and usual criteria and triage should be applied.

We aim to keep our surgery clean and tidy and offer a safe environment to our patients and staff. We are proud of our modern, purpose built Practice and endeavour to keep it clean and well maintained at all times.

If you have any concerns about cleanliness or infection control, please report these to our Reception staff.

Our GPs and nursing staff follow our Infection Control Policy to ensure the care we deliver and the equipment we use is safe.

We take additional measures to ensure we maintain the highest standards:

• Encourage staff and patients to raise any issues or report any incidents relating to cleanliness and infection control.  We can discuss these and identify improvements we can make to avoid any future problems.
• Carry out an annual infection control audit to make sure our infection control procedures are working.
• Provide annual staff updates and training on cleanliness and infection control
• Review our policies and procedures to make sure they are adequate and meet national guidance.
• Maintain the premises and equipment to a high standard within the available financial resources and ensure that all reasonable steps are taken to reduce or remove all infection risk.
• Use washable or disposable materials for items such as couch rolls, modesty curtains, floor coverings, towels etc., and ensure that these are laundered, cleaned or changed frequently to minimise risk of infection.
• Make Alcohol Hand Rub Gel available throughout the building

We have allocated a Named Accountable GP for all of our registered patients. If you do not know who your named GP is, please ask a member of our reception team. Unfortunately, we are unable to notify patients in writing of any change of GP due to the costs involved.

Where it is clinically appropriate and practical to register, we now accept new registrations from patients who work in the local area but reside outside of our registration area. Patients registered this way would not be entitled to home visit from the practice, however they will be able to contact NHS 111 in order to be seen by a practice closer to where they live.

For further information about this type of registration, please contact us on 0208 630 3604 or feel free to come into the practice.

The NHS Constitution establishes the principles and values of the NHS in England.

For more information see these websites:

• UK – The NHS Constitution for England
• NHS Choices – NHS Constitution

What is non-NHS work and why is there a fee?

The National Health Service provides most health care to most people free of charge, but there are exceptions: prescription charges have existed since 1951 and there are a number of other services for which fees are charged.

Sometimes the charge is because the service is not covered by the NHS, for example, providing copies of health records or producing medical reports for insurance companies, solicitors or employers.

The Government’s contract with GPs covers medical services to NHS patients but not non-NHS work. It is important to understand that many GPs are not employed by the NHS; they are self-employed and they have to cover their costs – staff, buildings, heating, lighting, etc. – in the same way as any small business.

In recent years, however, more and more organisations have been involving doctors in a whole range of non-medical work. Sometimes the only reason that GPs are asked is because they are in a position of trust in the community, or because an insurance company or employer wants to ensure that information provided to them is true and accurate.

Examples of non-NHS services for which GPs can charge their own NHS patients are:

• accident/sickness certificates for insurance purposes
• school fee and holiday insurance certificates
• reports for health clubs to certify that patients are fit to exercise
• private prescriptions for travel purposes

Examples of non-NHS services for which GPs can charge other institutions are:

• life assurance and income protection reports for insurance companies
• reports for the Department for Work and Pensions (DWP) in connection with
• disability living allowance and attendance allowance
• medical reports for local authorities in connection with adoption and fostering
• copies of records for solicitors

Do GPs have to do non-NHS work for their patients?

With certain limited exceptions, for example a GP confirming that one of their patients is not fit for jury service, GPs do not have to carry out non-NHS work on behalf of their patients. Whilst GPs will always attempt to assist their patients with the completion of forms, they are not required to do such non-NHS work.

Is it true that the BMA sets fees for non-NHS work?

The British Medical Association (BMA) suggest fees that GPs may charge their patients for non-NHS work (i.e. work not covered under their contract with the NHS) in order to help GPs set their own professional fees. However, the fees suggested by them are intended for guidance only; they are not recommendations and a doctor is not obliged to charge the rates they suggest.

Why does it sometimes take my GP a long time to complete my form?

Time spent completing forms and preparing reports takes the GP away from the medical care of his or her patients. Most GPs have a very heavy workload and paperwork takes up an increasing amount of their time. Our GPs do non-NHS work out of NHS time at evenings or weekends so that NHS patient care does suffer.

I only need the doctor’s signature – what is the problem?

When a doctor signs a certificate or completes a report, it is a condition of remaining on the Medical Register that they only sign what they know to be true. In order to complete even the simplest of forms, therefore, the doctor might have to check the patient’s ENTIRE medical record. Carelessness or an inaccurate report can have serious consequences for the doctor with the General Medical Council (the doctors’ regulatory body) or even the Police.

If you are a new patient we may not have your medical records so the doctor must wait for these before completing the form.

What will I be charged?

It is recommended that GPs tell patients in advance if they will be charged, and what the fee will be. It is up to individual doctors to decide how much they will charge. The surgery has a list of fees based on these suggested fees which is available on request.

What can I do to help?

• Not all documents need a signature by a doctor, for example passport applications. You can ask another person in a position of trust to sign such documents free of charge. Read the information that comes with these types of forms carefully before requesting your GP to complete them.
• If you have several forms requiring completion, present them all at once and ask your GP if he or she is prepared to complete them at the same time to speed up the process.
• Do not expect your GP to process forms overnight: urgent requests may mean that a doctor has to make special arrangements to process the form quickly, and this may cost more. Usually non-NHS work will take 2 weeks.

All information about patients is confidential: from the most sensitive diagnosis, to the fact of having visited the surgery or being registered at the Practice. All patients can expect that their personal information will not be disclosed without their permission except in the most exceptional of circumstances, when somebody is at grave risk of serious harm.

All members of the primary health care team (from reception to doctors) in the course of their duties will have access to your medical records. They all adhere to the highest standards of maintaining confidentiality.

As our reception area is a little public, if you wish to discuss something of a confidential nature please mention it to one of the receptionists who will make arrangements for you to have the necessary privacy.

Under 16s

The duty of confidentiality owed to a person under 16 is as great as the duty owed to any other person. Young people aged under 16 years can choose to see health professionals, without informing their parents or carers. If a GP considers that the young person is competent to make decisions about their health, then the GP can give advice, prescribe and treat the young person without seeking further consent.

However, in terms of good practice, health professionals will encourage young people to discuss issues with a parent or carer. As with older people, sometimes the law requires us to report information to appropriate authorities in order to protect young people or members of the public.

Useful Websites

• Confidentiality NHS Code of Practice
• Confidentiality and Mental Health
• Confidentiality Guidance

Privacy Notice 

Your information, what you need to know 

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

Why we collect information about you 

Patients 

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 within any NHS organisation. These records help to provide you with the best possible healthcare and help us to protect your safety. 

We collect and hold data for 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 may collect information about you which helps us respond to your queries or secure specialist services.  

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments. We may keep your information in written form and/or in digital form. 

The records may include basic details about you, such as your name and address.  They may also contain more sensitive information about your health and also information such as outcomes of needs assessments. 

Staff 

As employers we are required to keep records about your employment to ensure we meet our legal responsibilities for example to ensure all employees have the right to work in the UK and to enable the development of a comprehensive understanding our workforce and how it is deployed to support our business functions. 

We collect and hold data to: 

• Inform the development of HR policies 
• Support workforce planning 

• Make recruitment decisions 
• Enable staff to be paid and have the correct pension contributions deducted 
• Monitor timekeeping and attendance 
• Assess training needs and maintain training records 
• Implement disciplinary and grievance processes  

• Maintain up to date records to ensure effective correspondence and ensure that we can contact you or your next of kin in an emergency.  For example, your details are shared with the payroll company for calculation of salary and production of payslip and the bank to pay you. 

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and disciplinary matters. We may keep your information in written form and/or in digital form. 

Details we collect about you 

Patients 

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP surgeries, A&E, etc.). These records help to provide you with the best possible healthcare. 

Records which this GP practice may hold about you include the following: 

• Details about you, such as your address and next of kin 
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc. 
• Notes and reports about your health 

• Details about your treatment and care 
• Results of investigations, such as laboratory tests, x-rays, etc. 
• Relevant information from other health professionals, relatives or your carers 
• The practice may receive emails and letters about your care (most frequently from hospitals and community services).  These are scanned into your medical record and the originals are shredded using a confidential waste company. 
• Patients can email the practice ([email protected]).  These emails may be saved into your record if clinically relevant.  If not clinically relevant (e.g. a prescription request once actioned does not need to be added to your medical record) it will be deleted. 

How we keep your information confidential and safe 

Everyone working for our organisation is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this. 

The health records we use 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. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel. 

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed. 

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

• Data Protection Act 2018 
• General Data Protection Regulation 
• Human Rights Act 
• Common Law Duty of Confidentiality 
• NHS Codes of Confidentiality and Information Security 

• Health and Social Care Act 2015 
• And all applicable legislation 

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on. 

How we use your information 

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for 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 section below. 

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below. 

You may choose to opt-out to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start. 

Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared. 

You can object to your personal information being shared with other healthcare providers which will not affect your entitlement to care, but you should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object. 

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. 

Practice Website (Argyle Health Isleworth Practice | NHS GP Surgery in Hounslow) 

Passive information collection and use 

As you navigate through our website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, internet tags and navigational data collection. 

Please read the section on Cookies below and review the Cookie Settings for detailed information about Cookies and other tracking technologies used on our site. In this policy you will also find information on how to disable cookies and tracking technologies if you do not agree to their use as well as the consequence(s), if any, of disabling each specific cookie/tracking technology. If you do not disable any cookies or tracking technologies, we will infer your consent to their use. 

We and our third party service providers may passively collect and use information in a variety of ways, including: 

• Through your browser -  Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version.  We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device. 
• IP Address – Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site. 
• Using pixel tags, web beacons, clear GIFs, or other similar technologies -  These may be used in connection with some site pages and HTML-formatted e-mail messages to, among other things, track the actions of site users and e-mail recipients, and compile statistics about Site usage and response rates. 
• Device Information – We may collect information about your mobile device, such as a unique device identifier. 

Cookies and IP addresses  

A cookie is a small text file that is downloaded onto a computer or smartphone when the user accesses a website. It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions. We use these to monitor access to our website and tailor any developments based on usage and pages visited. 

We use Google Analytics software on this site to anonymously track how visitors interact with this website. This includes identifying: 

• The pages visited on this site 
• How long the visitor spends on each page on this site 

• How visitors got to the site 
• What visitors click on while visiting the site 

We do this to help make sure the site is meeting the needs of visitors and help us make improvements, for instance improving site search. 

We don’t use cookies to track the identity of visitors or the information they have entered into the site. 

You give us consent to using cookies for analytic purposes if you continue to use our website. Alternatively, you can switch off cookies in your browser and the site will still work normally. 

Third Party Sites and Services 

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any App) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates. 

Security 

We use reasonable organisational, technical and administrative measure to protect personal information under our control and in accordance with this privacy policy. 

Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk. 

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section. 

Cross Border Transfers 

Personal information other than medical data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms to send communication emails to our users. 

Patients and staff 

CCTV 

Images are recorded to protect staff and practice property. It will not be used for any other purpose. Images from the CCTV system are securely stored and only authorised personnel may access them. The recorded images will only be retained long enough for any incident to come to light (e.g. for a theft to be noticed) and the incident to be investigated. Except for law enforcement bodies, images will not be provided to third parties. 

Telephone Recording 

All calls are recorded for training and quality purposes.  There is an announcement on the telephone system to alert anyone calling the surgery that calls may be recorded. Telephone calls are stored securely and only accessed by authorised personnel. 

How we keep your information confidential and safe 

Patients 

Everyone working for our organisation is subject to the Common Law Duty of Confidentiality. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this. 

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on. 

Patients and staff 

The records we use 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. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel. 

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed. 

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

• Data Protection Act 2018 
• Human Rights Act 
• Common Law Duty of Confidentiality 

• NHS Codes of Confidentiality and Information Security 
• Health and Social Care Act 2015 
• And all applicable legislation 

How we use your information 

Patients 

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for 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 section below. 

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below. Please also see https://digital.nhs.uk/data-and-information/looking-after-information for more information. 

You may choose to withdraw your consent to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start. 

Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared. Please see right to withdraw consent section below. 

You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object. 

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. 

Accurx 

Accurx is a clinical text messaging software that allows two-way communication between patients and the practice.   

Child Health Information – CHIS 

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS health visitors and school nurses, with the NWL Commissioning Support Unit, who provide the Child Health Information Service (CHIS) on behalf of NHS England.   

Clinical audit 

Information may be used by the ICB for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data. 

Clinical Research 

Sometimes your information may be requested to be used for research purposes – we will normally ask your permission before releasing your information for this purpose. 

In some instances, the Confidentially Advisory Group, part of the Health Research Authority may allow for identifiable information to be shared with researchers without consent of individuals. You may however opt-out of this, details of which can be found below under the ‘National Data Opt-Out’. 

Electronic Prescribing Service (EPS) 

We share information about your medications with your pharmacy when you inform us of your usual pharmacy.  This allows your repeat medication prescription to be sent securely to your preferred pharmacy so that you do not need to attend the surgery to collect your prescription. 

Enhanced Data Sharing Module  

The Argyle Health Isleworth Practice uses TPP SystmOne and this allows you to choose whether other health and care providers can access your information to help provide you with care. We have drawn up an “allowed list” of local organisations with whom we can share your data (when you register for their services and give them verbal permission to provide your care through a TPP clinical system). See the link below under who are our partner organisations. 

Organisations outside of this allowed group who use the same software will require formal documented permission to see your records. Your GP system will send you an SMS or email which you can give to the organisation asking for access which will formally validate your consent. It is possible for you to set your own specific permissions (as distinct from the allowed list we have provided).  

GP Connect 

We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.
GP Connect is not used for any purpose other than direct care. 

Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS Digital service called GP connect.  

The NHS 111 service (and other services determined locally e.g. Other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services.  

Further information can be found here: https://digital.nhs.uk/services/gp-connect 

Improving Diabetes Care and long-term condition management 

We share information about patients with diabetes with the Diabetic Retinopathy Screening Service (DRSS) to ensure that all diabetic patients receive annual screening. 

Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients. 

Individual Funding Request 

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for 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 taken under consideration 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. 

Invoice Validation 

Invoice validation is an important process. It involves using your NHS number to check which ICB is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly. 

Local Information Sharing 

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. In order to provide you with health and social care services your GP practice works in close collaboration with neighbouring practices as part of a Primacy Care Network (PCN).  Our practice is part of The Ealing Network PCN. The organisational boundary within which professionally trained staff can access your health record without consent has extended from your GP practice to this Primary Care Network and staff employed on its behalf. Staff are trained to understand their legal and professional responsibilities of confidence to their patients and will only access your records when they are required to do so to support you care. They will identify themselves and their role using a smart card and access to your PCN record is recorded, monitored, and audited. 

If you require attention from a local health or care professional outside of your usual PCN services, such as in an Evening and Weekend GP Hub services, Emergency Department, Minor Injury Unit or Out of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent. 

Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or EMIS remote consulting system). 

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Aside from your registered health care provider, your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged). 

MISL 

We use a secure storage service to store our patient records off site. 

MJOG 

We use a text messaging platform called MJOG to send text messages regarding health campaigns and screening and to ask for feedback about our services.  

National Fraud Initiative – Cabinet Office 

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice.  

National Registries 

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user. 

NHS Digital 

The NHS needs data about the patients it treats in order to plan and deliver its services and to ensure that care and treatment provided is safe and effective.  The General Practice Data collection for planning and research will help the NHS to improve health and care services for everyone by collecting patient data that can be used to so this.  We have agreed to share the patient data we look after in our practice with NHS Digital who will securely store, analyse, publish and share this patient data to improve health and care services for everyone.  This includes: 

• Informing and developing health and social care policy 
• Planning and commissioning health and care services 
• Taking steps to protect public health including managing and monitoring the covid pandemic 
• In exceptional circumstances, providing you with individual care 
• Enabling healthcare and scientific research 

This means that we can get on with looking after our patients and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it to improve health and care for everyone. 

Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality. 

Data may be shared from the GP medical records about: 

• any living patient registered at a GP practice in England when the collection started – this includes children and adults 
• any patient who died after this data sharing started, and was previously registered at a GP practice in England when the data collection started 

We will not share your name or where you live. Any other data that could directly identify you, for example your NHS number, General Practice Local Patient Number, full postcode and date of birth, is replaced with unique codes which are produced by de-identification software before the data is shared with NHS Digital. 

NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and GP practices. 

The full privacy notice can be found here: NHS Digital Privacy Notice 

NHS England  

NHS England has a legal duty to keep a list of all patients registered with GP Practices in England. This list is held in the National Health Application and Infrastructure Services (NHAIS) systems.  These systems also hold data about patients registered with GPs in Wales and the Isle of Man. NHS Digital, and other service agencies around the country manage these systems on behalf of NHS England. 

The data are used to provide Primary Care Support Services. NHS England has a contract with Capita Business Services Ltd, operating as Primary Care Support England to provide these services which include: 

• Moving paper patient records between practices and into storage when patients leave or move practices 
• Storing paper records of unregistered and deceased patients 
• Sending letters to patient to inform them of their NHS number when one is first allocated 
• Providing the cervical cytology call and recall administrative service on behalf of Public Health England 

• Delivering prior notification lists of patients eligible for screening to GPs 
• Processing new patient registrations and de-registrations at GP practices to maintain accurate lists of numbers of patients at GP Practices– 
• Making payments to NHS Ophthalmic practitioners for NHS services provided 
• Making payments to GP practices based on lists of registered patients, and specific payments for childhood vaccinations and immunisations 
• Writing to patients on behalf of Primary Care commissioners with regards to provision of primary care services or assignment to a GP Practice list. 

• Writing to patients when they have been removed from their GP Practice list 
• Conducting audits and reconciliations of GP Practice lists to ensure list sizes are accurate. 

The data from the NHAIS list is used to update the Personal Demographics Service (PDS). This provides information for hospitals, Public Health England Cancer Screening Programmes, Child Health systems and other health providers making sure that they know their patients’ current GP Practice and can access other essential information such as the Summary Care Record. 

NHS England Regional Local Teams (RLTs) and Integrated Care Boards (ICBs) (where delegated) may also undertake necessary processing of a limited subset of these data (e.g. patient name, address, postcode and NHS number) for example when managing practice closures and list dispersals (the process used to allocate patients to neighbouring GP Practices). This processing is necessary to inform patients of their reregistration options and ‘Choice’ as required under the NHS Constitution. 

Sources of the data:  The data are transferred automatically from GP practice systems in to the NHAIS systems. The data is also updated by Primary Care Support England after notifications from data subjects themselves. 

The categories of personal data held on the systems are: 

• Name – including any previous names, unless name changes are the result of adoption, gender reassignment or witness protection schemes 
• Current and historic addresses and whether the address is a registered nursing home 
• Dates of Birth 
• Gender 

• Place of Birth 
• NHS number 
• Cervical Screening history 
• Special allocation scheme status 
• Current and Previous GP practice details 

• GPs Banking details 

Categories of recipients:  Statistical information (numbers) produced from NHAIS systems is shared with other organisations to enable them to fulfil their statutory obligations, for example the Office of National Statistics, Public Health England and local authorities for their public health purposes. Personal data may also be shared with the approval of NHS England’s Caldicott Guardian when he is assured that confidentiality is respected, for example when hospitals need to update their records for direct care purposes or to support specific research projects with ethical and or Health Research Authority approval. 

Patient Participation Group (PPG) 

We invite all patients at point of registration and opportunistically thereafter if they would like to be part of our Patient Participation Group.  Email addresses and contact details are kept securely for the purpose of communicating with the group about meetings and any other events or issues we would like the PPG’s opinion on. 

Public Health 

We share information about patients with Public Health England in relation to notifiable diseases (e.g. measles, salmonella), screening programmes (cervical cytology) and childhood immunisations. 

Shred it 

The practice uses shred it a document shredding service to securely dispose of confidential material 

Risk Stratification 

‘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 a number of 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. 

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the NWL Clinical Commissioning Group. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from: 

NHS England » Risk Stratification 

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.  Please see below for more information on how to withdraw consent. 

Safeguarding 

To ensure that adult and child safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned. 

Summary Care Record (SCR) 

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. 

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reasons for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement. 

During the height of the pandemic changes were made to the Summary Care Record (SCR) to make additional patient information available to all appropriate clinicians when and where they needed it, to support direct patients care, leading to improvements in both care and outcomes. 

These changes to the SCR will remain in place, unless you decide otherwise. 

Regardless of your past decisions about your Summary Care Record preferences, you will still have the same options that you currently have in place to opt out of having a Summary Care Record, including the opportunity to opt-back in to having a Summary Care Record or opt back in to allow sharing of Additional Information. 

You can exercise these choices by doing the following: 

1.   Choose to have a Summary Care Record with all information shared. This means that any authorised, registered and regulated health and care professionals will be able to see a detailed Summary Care Record, including Core and Additional Information, if they need to provide you with direct care. 

2.   Choose to have a Summary Care Record with Core information only. This means that any authorised, registered and regulated health and care professionals will be able to see limited information about allergies and medications in your Summary Care Record if they need to provide you with direct care. 

3.   Choose to opt-out of having a Summary Care Record altogether. This means that you do not want any information shared with other authorised, registered and regulated health and care professionals involved in your direct care. You will not be able to change this preference at the time if you require direct care away from your GP practice. This means that no authorised, registered and regulated health and care professionals will be able to see information held in your GP records if they need to provide you with direct care, including in an emergency. 

To make these changes, you should inform your GP practice or complete this form and return it to your GP practice. 

Supporting Medicines Management 

NWL ICB uses pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the ICB medicines management team may provide support relating to obtaining medications on behalf of your GP Practice to support your care. 

Supporting Locally Commissioned Services 

ICBs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality. The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide. 

Suspected Cancer 

Data may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital NHS Foundation Trust, London North West Healthcare NHS Trust and University College London Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual patients. 

Universal Care Plan (UCP – formerly CMC) 

UCP is a platform which gives patients an opportunity to express their wishes about how and where they are treated. It enables all healthcare professionals to offer more personalised medical care, with full respect to each patient’s preferences. 

Data Retention 

We manage patient records in line with the Records Management Code of Practice which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.  

Our partner organisations 

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

• NHS Trusts 

• Specialist Trusts 
• GP Federations 
• Independent Contractors such as dentists, opticians, pharmacists 
• Private Health Sector Providers e.g. Bupa 
• Voluntary Sector Providers e.g. carers centre 

• Ambulance Trusts 
• Integrated Care Boards 
• Local Authorities e.g. social services 
• Education Services e.g. school nurses 
• Fire and Rescue Services 

• Police 
• Other ‘data processors’ 

We will not share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function. No information will ever be shared where we do not have a lawful basis to do so. 

Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below). 

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence. 

Right to withdraw consent to share personal information (Opt- Out) 

Patients 

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data. 

There are two main types of opt-out. 

Type 1 Opt-Out 

If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to register a Type 1 opt out please fill out the form below and email it to [email protected] 

National Data Opt-Out 

NHS Digital have created an opt-out system named the National Data Opt-Out which allows individuals to opt-out of their information being used for planning and research purposes. From 25 May 2018, NHS Digital has had to apply this opt-out for all their data flows, and from 2020 all health and care organisations will have to ensure the opt-out is respected. Individuals who previously opted out with a ‘Type 2’ objection will not have to do anything as you will be automatically be opted out.  

If you wish to apply the National Opt-Out, please go to NHS Digitals website here https://www.nhs.uk/your-nhs-data-matters/manage-your-choice/ 

Access to your information 

Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing or speak to a member of the Practice staff. Under special circumstances, some information may be withheld.  

If you wish to have a copy of the information we hold about you, please email the Practice Manager at [email protected] 

Our practice is compliant with the National Data Opt Out 

Staff 

You have the following rights in relation to the personal data we hold on you: 

• The right to be informed about the data we hold on you and what we do with it 
• The right of access to the data we hold on you 

• The right for any inaccuracies in the date we hold on you, however they come to light to be corrected.  This is also known as “rectification” 
• The right to have data deleted in certain circumstances. This is also known as “erasure” 
• The right to restrict the processing of data.  
• The right to transfer the data we hold on you to another party. This is also known as “portability” 

If you wish to exercise any of these rights please speak to the Practice Manager 

Access to your information 

Patients and staff 

Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.  

If you wish to have a copy of the information we hold about you, please contact, the Practice Manager  

Change of Details  

Patients 

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 are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date. 

Staff 

Please let your line manager know if there are any changes to your details so that our records for you are accurate and up to date. 

Mobile telephone number 

Patients 

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

Notification 

The Data Protection Act 2018 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 at: https://ico.org.uk/ESDWebPages/Entry/ZA275301 

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

Complaints 

If you have concerns or are unhappy about any of our services, please contact the Practice Manager, or email [email protected] 

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 

Information we are required to provide you 

Further Information 

Further information about the way in which the NHS uses personal information and your rights in that respect can be found at the links below. 

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 the Data Protection Act 2018. 

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 programmes 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 

Reviews of and Changes to our Privacy Notice 

We will keep our Privacy Notice under regular review. This notice was last reviewed in March 2023 

New contractual requirements came into force from 1 April 2014 requiring that GP Practices should make available a statement of intent in relation to the following IT developments:

• Summary Care Record (SCR)
• GP to GP Record Transfers
• Patient Online Access to Their GP Record
• Data for commissioning and other secondary care purposes

The same contractual obligations require that we have a statement of intent regarding these developments in place and publicised by 30 September 2014.

Please find below details of the practices stance with regards to these points.

Summary Care Record (SCR)

NHS England require practices to enable successful automated uploads of any changes to patient’s summary information, at least on a daily basis, to the summary care record (SCR) or have published plans in place to achieve this by 31st of March 2015.

Having your Summary Care Record (SCR) available will help anyone treating you without your full medical record. They will have access to information about any medication you may be taking and any drugs that you have a recorded allergy or sensitivity to.

Of course, if you do not want your medical records to be available in this way then you will need to let us know so that we can update your record. You can do this via the opt out form.
The practice confirms that your SCR is automatically updated on at least a daily basis to ensure that your information is as up to date as it can possibly be.

GP to GP Record Transfers

NHS England require practices to utilise the GP2GP facility for the transfer of patient records between practices, when a patient registers or de-registers (not for temporary registration).
It is very important that you are registered with a doctor at all times. If you leave your GP and register with a new GP, your medical records will be removed from your previous doctor and forwarded on to your new GP via NHS England. It can take your paper records up to two weeks to reach your new surgery.

With GP to GP record transfers your electronic record is transferred to your new practice much sooner.

The practice confirms that GP to GP transfers are already active and we send and receive patient records via this system.

Patient Online Access to Their GP Record

NHS England require practices to promote and offer the facility to enable patients online access to appointments, prescriptions, allergies and adverse reactions or have published plans in place to achieve this by 31st of March 2015.

We currently offer the facility for booking and cancelling appointments and also for ordering your repeat prescriptions and viewing a summary of your medical records on-line. If you do not already have a user name and password for this system – please register your interest with our reception staff.

Data for commissioning and other secondary care purposes

It is already a requirement of the Health and Social Care Act that practices must meet the reasonable data requirements of commissioners and other health and social care organisations through appropriate and safe data sharing for secondary uses, as specified in the technical specification for care data.

At our practice we have specific arrangements in place to allow patients to “opt out” of care.data which allows for the removal of data from the practice. Please see the page about care data on our website

The Practice confirm these arrangements are in place and that we undertake annual training and audits to ensure that all our data is handled correctly and safely via the Information Governance Toolkit.

About your Summary Care Record

Your Summary Care Record contains important information about any medicines you are taking, any allergies you suffer from and any bad reactions to medicines that you have previously experienced.

Allowing authorised healthcare staff to have access to this information will improve decision making by doctors and other healthcare professionals and has prevented mistakes being made when patients are being cared for in an emergency or when their GP practice is closed.

Your Summary Care Record also includes your name, address, date of birth and your unique NHS Number to help identify you correctly.

You may want to add other details about your care to your Summary Care Record. This will only happen if both you and your GP agree to do this. You should discuss your wishes with your GP practice.

Healthcare staff will have access to this information, so that they can provide safer care, whenever or wherever you need it, anywhere in England.

FAQs

Who can see my Summary Care Record?

Healthcare staff who have access to your Summary Care Record:

• need to be directly involved in caring for you
• need to have an NHS Smartcard with a chip and passcode
• will only see the information they need to do their job and
• will have their details recorded every time they look at your record

Healthcare staff will ask for your permission every time they need to look at your Summary Care Record. If they cannot ask you (for example if you are unconscious or otherwise unable to communicate), healthcare staff may look at your record without asking you, because they consider that this is in your best interest.

If they have to do this, this decision will be recorded and checked to ensure that the access was appropriate.

What are my choices?

You can choose to have a Summary Care Record or you can choose to opt out.

If you choose to have a Summary Care Record and are registered with a GP practice, you do not need to do anything as a Summary Care Record is created for you.

If you choose to opt out of having a Summary Care Record and do not want a SCR, you need to let your GP practice know by filling in and returning an opt-out form. Opt-out forms can be downloaded from the website or from your GP practice.

If you are unsure if you have already opted out, you should talk to the staff at your GP practice. You can change your mind at any time by simply informing your GP practice and either filling in an opt-out form or asking your GP practice to create a Summary Care Record for you.

Children and the Summary Care Record

If you are the parent or guardian of a child under 16, you should make this information available to them and support the child to come to a decision as to whether to have a Summary Care Record or not.

If you believe that your child should opt-out of having a Summary Care Record, we strongly recommend that you discuss this with your child’s GP. This will allow your child’s GP to highlight the consequences of opting-out, prior to you finalising your decision.

Where can I get more information?

For more information about Summary Care Records you can:

• talk to the staff at your GP practice
• phone the Health and Social Care Information Centre on 0300 303 5678
• Read the Summary Care Record patient information

Patient’s Rights

We are committed to giving you the best possible service. This will be achieved by working together. Help us to help you. You have a right to, and the practice will try to ensure that:

• You will be treated with courtesy and respect
• You will be treated as a partner in the care and attention that you receive
• All aspects of your visit will be dealt with in privacy and confidence
• You will be seen by a doctor of your choice subject to availability
• In an emergency, out of normal opening hours, if you telephone the practice you will be given the number to receive assistance, which will require no more than one further call
• You can bring someone with you, however you may be asked to be seen on your own during the consultation
• Repeat prescriptions will normally be available for collection within two working days of your request
• Information about our services on offer will be made available to you by way of posters, notice boards and newsletters
• You have the right to see your medical records or have a copy subject to certain laws.

Patient’s Responsibilities

With these rights come responsibilities and for patients we would respectfully request that you:

• Treat practice staff and doctors with the same consideration and courtesy that you would like yourself. Remember that they are trying to help you
• Please ensure that you order your repeat medication in plenty of time allowing 48 working hours.
• Please ensure that you have a basic first aid kit at home and initiate minor illness and self-care for you and your family.
• Please attend any specialist appointments that have been arranged for you or cancel them if your condition has resolved or you no longer wish to attend
• Please follow up any test or investigations done for you with the person who has requested the investigation
• Attend appointments on time and check in with Reception
• Patients who are more than 20 minutes late for their appointment may not be seen.
• If you are unable to make your appointment or no longer need it, please give the practice adequate notice that you wish to cancel. Appointments are heavily in demand and missed appointments waste time and delay more urgent patients receiving the treatment they need
• An appointment is for one person only. Where another family member needs to be seen or discussed, another appointment should be made
• Patients should make every effort to present at the surgery to ensure the best use of nursing and medical time. Home visits should be medically justifiable and not requested for social convenience
• Please inform us when you move home, change your name or telephone number, so that we can keep our records correct and up to date
• Read the practice leaflets and other information that we give you. They are there to help you use our services. If you do not understand their content please tell us
• Let us have your views. Your ideas and suggestions whether complimentary or critical are important in helping us to provide a first class, safe, friendly service in pleasant surroundings.

NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. For more information see these websites:

• GOV.UK – The NHS Constitution for England
• NHS Choices – NHS Constitution

The practice fully supports the NHS Zero Tolerance Policy. The aim of this policy is to tackle the increasing problem of violence against staff working in the NHS and ensures that doctors and their staff have a right to care for others without fear of being attacked or abused.

We understand that ill patients do not always act in a reasonable manner and will take this into consideration when trying to deal with a misunderstanding or complaint. We ask you to treat your doctors and their staff courteously and act reasonably.

All incidents will be followed up and you will be sent a formal warning after a second incident or removed from the practice list after a third incident if your behaviour has been unreasonable.

However, aggressive behaviour, be it violent or verbal abusive, will not be tolerated and may result in you being removed from the Practice list and, in extreme cases, the Police will be contacted if an incident is taking place and the patient is posing a threat to staff or other patients.

Removal from the Practice List

A good patient-doctor relationship, based on mutual respect and trust, is the cornerstone of good patient care. The removal of patients from our list is an exceptional and rare event and is a last resort in an impaired patient-practice relationship. When trust has irretrievably broken down, it is in the patient’s interest, just as much as that of The Surgery, that they should find a new practice. An exception to this is on immediate removal on the grounds of violence e.g. when the Police are involved.

Removing other members of the household

In rare cases, however, because of the possible need to visit patients at home it may be necessary to terminate responsibility for other members of the family or the entire household. The prospect of visiting patients where a relative who is no longer a patient of the practice by virtue of their unacceptable behaviour resides, or being regularly confronted by the removed patient, may make it too difficult for the practice to continue to look after the whole family. This is particularly likely where the patient has been removed because of violence or threatening behaviour and keeping the other family members could put doctors or their staff at risk.