‘Better Information means better care' leaflet
As you are aware, every household in England is receiving the leaflet ‘Better Information means better care leaflet’ during January. The leaflet helps support GP practices in raising awareness amongst patients about how their information is used for purposes beyond their direct care, including for the care.data programme
There are a number of public misconceptions about how data will be used. These are mostly due to a confusion around the different types of data that will be released by the Health and Social Care Information Centre (HSCIC). To make it easier for the public to understand, we are referring to the different types as: red (personal confidential data), amber (pseudonymised) and green (aggregated or anonymised) data. Each “colour" of data is protected by a different suite of privacy safeguards. For an explanation, see this blog by the Chief Data Officer.
For the avoidance of doubt:
- Data will not be made available for the purposes of selling or administering any kind of insurance
- Data will not be shared or used for marketing purposes
- NHS England and the HSCIC will not profit from providing data to outside organisations
Privacy Impact Assessment
For patients who wish to understand more about how we protect their data, we have published a privacy impact assessment for the care.data programme. This document provides details about the privacy implications of the programme (both negative and positive) and explains how we are mitigating each risk. In addition, the HSCIC has published a privacy impact assessment for all the personal data it processes, which includes the data extracted for care.data.
Your personal data - General Data Protection Regulations
New Pond Row Surgery is a Data Controller
We hold personal medical information about all our patients
We have a responsibility to protect your data under the General Data Protection Regulations. Your information is treated confidentially. All staff and contractors working at the surgery are subject to a confidentiality policy. We are obliged to process your data fairly and responsibly. Keeping your medical records confidential is important as you need to know that you can trust us with our data.
We also have a responsible to let you know how you can expect your data will be used and shared.
We have limitations within our clinical systems, however for the majority of our uses and sharing of data we will aim to record your consent either verbally or in writing before we share any of your data where it is outside of the usual processing required for providing you with GP or Primary Care services. The usual processes will include our standard practice to share (such as a hospital referral) or where it would be in your best interests for us to share (where there has been an emergency). It is our responsibility to share only what is necessary.
To provide you with General Practice services we will use and share your data in the following ways:
1) Contact you by phone, email, text, Apps, and letters
2) As part of your registration with New pond Row Surgery we imply that for your consent to pass on relevant clinical information to other professional staff involved in your direct care. This means that you are consenting for us to send information about you and your medical history to external agencies to support clinical and social referrals and to help you access and benefit from external services.
3) Send information about you and your medical history to other NHS organisations for clinical, research and statistical requirements (some of this may well be anonymous)
4) We take part in the NHS Adur Research Programme for Public Benefit and therefore, with your consent, your data may be included in research projects. (You will always be asked about taking part in research projects).
5) NHS National Research including 'Clinical Practice Research Datalink' and 'QResearch' is also active at New Pond Row. Data for this research is anonymous which means that no one knows which individuals are contributing. We are governed by laws overseeing how data is used in this context for your protection.
6) We are also obliged to comply with various laws that require our computers to send data to the national Health and Social Care Information Centre (NHS Digital). This is as directed by the Secretary of State for Health. Only when there is a legal basis for the transfer of data we may pass limited and relevant information to other NHS organisations to improve the efficient management of the NHS or to aid medical research.
Examples of organisations where we may need to send your information include:
- Hospitals - to provide information to support 'Secondary Care'
- County Council - to provide information to support access to their health and wellbeing services
- Sussex Community Foundation NHS Trust - to provide information to support District Nursing and Community Care - including Proactive Care
- Sussex Partnership Trust - to provide information to help with mental health
- Coastal West Sussex CCG and Emergency Services - If there is a large scale emergency incident a list of vulnerable people may need to be identified (People that are housebound / nursing homes / significantly frail). In this instance where harm could come otherwise - limited data will be shared for protection.
- Sussex Ambulance - SECAMB
- Out of Hours Services - IC24
- Share My Care - who provide information to out of hours and emergency services
- IBIS - who provide information to emergency services
- Innovations in Primary Care - MIAMI appointments and clinical services - Extended Hours and specialist clinics
- Other GP Practices - where you may be a temporary resident or receiving a particular service
From the 25th May 2018 we will no longer be charging for access to medical records to comply with the new legislation - General Data Protection Regulations. You have access to your Summary Care Record via Online Services already - for FREE. If you complete the forms for FULL ACCESS you can also see more information - this is also FREE - however due to the complex and numerous rules that the NHS imposes upon us before we are allowed to give you access it will take us significant time to process your requests and make these available to you. We strongly suggest that if you are concerned about any one particular aspect of your records to have a chat to us and we can answer specific questions to help you. This is likely to be a better solution for all - and we are very happy to be open with you and share information with you about your records within the NHS Guidance in which we are required to operate. To request your records you will need to complete a form - please talk to our reception team about this.
For your information:
Your DIGITAL records are held on the internet on a 'cloud-based' IT system called EMIS Web. https://www.emishealth.com/products/emis-web/
Your PAPER records are held in storage in Stanstead off-site in secure storage by a company called CAS Digital and Archive Document Storage https://cas.ltd/
Your PAPER records whilst in transit are processed by Primary Care Support England which is actually a private company called CAPITA https://pcse.england.nhs.uk/
Our communications with you
Please note our communications disclaimer which applies to all letters, emails, texts and phone communications:
DISCLAIMER 1: Unless expressly stated otherwise, the information contained in any letter, email or text sent by New Pond Row Surgery is confidential and is intended only for the named recipient(s). If anyone receiving a communication from New Pond Row is not the intended recipient , the content must not be copied, distributed, or used as the basis for any action or reliance upon it. If anyone has received an email or text in error, please notify the New Pond Row Surgery. Any unauthorised disclosure of the information contained in an email or text is strictly prohibited.
DISCLAIMER 2: If you have provided New Pond Row Surgery with a contact email or mobile number, we are implying your consent for New Pond Row Surgery to send information about you via email and text to anyone who can access your email or texts. If you share your email and mobile, you are responsible for who has access. New Pond Row Surgery can take no responsibility for you sharing your devices, or passwords. New Pond Row Surgery strongly recommends that every patient has a personal private individual email address and mobile number.