Privacy Statement Policy

Our Duties

As part of our legal duties, this practice is required to;

  • Maintain full and accurate records of the care and services we provide you
  • Keep records about you confidential and secure

Your Information

The practice aims to provide you with safe, high quality care that is based on accurate, up to date information.

This information allows us to work others involved in your care and this may involve sharing information with other health and social care organisations.

Information Includes:

  • Basic details such as address, date of birth and next of kin
  • Contact we have had with you
  • Notes and reports about your health
  • Details and records about your treatment and care

Others may also need to use records about you to:

  • Check the quality of care you are receiving
  • Protect the health of the general public  
  • Keep track of NHS spending
  • Help investigate any concerns or complaints you ask us to
  • Teach students or staff
  • Support health and social care research

Sometimes we share your information with third parties to support your care such as:

  • Hospitals
  • Social care
  • Community Health
  • Clinical Commissioning Groups
  • Mental Health Providers
  • NHS Digital

When we are sharing information to support third parties in providing your care, we will work hard to ensure it is the minimum necessary and that it is done so securely and lawfully. We aim to ensure that we only use your personal information in a way that you would reasonably expect.

When we share information that is used for healthcare management or planning, this does not allow for you to be identified.

Sometimes we will be required to share information for other reasons;

  • When required to by law
  • We have special permission for health or research purposes (e.g. if you have agreed to take part in a research trial)
  • There is a strong public interest (e.g. there is a risk of serious harm or crime)

Objections

You can choose not to have information that could identify you shared beyond your GP practice.  You can also choose to prevent information that does not identify you from being shared for planning and research.

Simply contact your GP either to register an opt-out or end an opt-out you have already registered and they will update your medical record.  Your GP practice will also be able to confirm whether or not you have registered an opt-out in the past.

If you have previously told your GP practice that you don’t want NHS Digital to share your personal confidential information for purposes other than your own care and treatment, your opt-out will have been implemented by NHS Digital from 29th April 2016 as instructed in a direction from the Secretary of State.  It will remain in place unless you change it.

As the Secretary of State’s direction; this included the policy on how to apply opt-outs was not available before April 2016 it was not possible for NHS Digital to honour opt-outs made before this date.  This means that information may have been shared without respecting these opt-outs between January 2014 and April 2016.

You can find more information on NHS Digital’s website:

See how NHS Digital uses your information.

Read about how NHS Digital handles your information and your choices.

Your Rights

Under Data Protection law, you have a right to;

  • object to certain uses of your data
  • to be provided with a copy information held about you
  • that your information will not be used for direct marketing purposes
  • have any incorrect information amended or erased

Please contact your surgery for any requests made in connection with these rights.

For a copy of your information;

  • Your request must be made in writing to your surgery
  • The surgery is required to respond to your request in writing within 40 days (a month from May 2018)
  • You will need to give the surgery your full name, address, date of birth and NHS number
  • You will be required to provide personal identification such as a driving licence or passport

Use of the Website

Generally, our website will not require you to enter personal information. When it does, for example; online appointment booking, we will apply the same confidentiality principles as those described above.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should be aware that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites.

Data Security

We intend to protect the confidentiality, quality and integrity of your personal information and we have implemented appropriate technical and organisational measures to do so. These include staff training, up to date policies and procedures and working to align with national cyber security guidelines.

Freedom of Information

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:

Disability Access

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.

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:

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:

Other Disability Websites:

Confidentiality

The practice complies with the Data Protection Act.  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:

Fair Processing Notice

The Fair Processing Notice is intended to inform you about the type of patient information that GP Practices hold, how that information might be used, with whom we may share that information, and how we ensure it is kept secure.

Data Sharing Measure in relation to the COVID pandemic

  1. The secretary of state has served notice under the Health Service COPI (Control of Patient Information) Regulations 2002 to require organisations to process confidential patient information during the COVID Pandemic and these measures will remain in place until September 2020. In addition, aggregate data which supports the planning and delivery of health care during the COVID pandemic will be processed securely through the Whole Systems Integrated Care database. Any such data will be formally identified as COVID related and used only for this purpose until Sep 2020.
  2. Primary care staff across each CCG will be able to access your full medical record without consent during the COVID-19 pandemic but will only do so when this is necessary to provide you with care. They will be required to use a smartcard which confirms their identity, and which limits their access and actions to those appropriate for their role. They will all have been trained to understand their professional and legal responsibilities in providing you with care. Access to records by trained clinicians will be made available for example when patients:

    – are asked to present to the Respiratory Hubs offering care for COVID related illness

    – are directed to other hubs based services for routine face to face, or telephone or video consultation

    – require community visiting services

  3. The extension to smart card permissions is currently limited to CCG wide sharing, but in the event of the pandemic escalating we have taken measures to implement NWL wide sharing and will notify patients through this Fair Processing Notice, should that need arise.
  4. The government have requested reinstatement of the “break glass” facility” previously available in TPP clinical systems so as to allow a declared access to patient records in the event of an emergency.

Updates to Summary Care Records

Fair Processing Notice

GP Practice Transparency Notice

Further Information

Chaperones

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 practice Nurse, Health Care Assistant or chaperone trained receptionist who is 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 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.

Complaint Procedure

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. 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 investigate and respond to your complaint as soon as we can, but please note that responses are subject to the length of the complaint and doctor/staff availability to process them. 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 the NWL Complaints Team – who are now responsible for the complaints as opposed to NHS England. You can find more information on how to make a complaint at How to complain to the NHS – NHS (www.nhs.uk)

 

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.