Meon Health Practice keeps data on patients relating to the following:
- who you are
- where you live
- what you do
- your family or named contact/carers
- your employers
- your habits
- your problems and diagnoses
- the reasons you seek help
- your appointments
- where you are seen and when you are seen who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care.
When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS.
GPs have always delegated tasks and responsibilities to others that work with them in their practice. On average an NHS GP has between 1,500 to 2,500 patients for whom he or she is accountable. It is not possible for the GP to provide hands on personal care for each and every one of those patients. For this reason GPs share your care with others, predominantly within the Practice but occasionally with external organisations.
If your health needs require care from others elsewhere outside this practice we will exchange with them whatever information about you that is necessary for them to provide that care. When you make contact with healthcare providers outside the practice but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all of those reports. Normally we will receive equivalent reports of contacts you have with non NHS services but this is not always the case.
Highlands, Jubilee and Whiteley surgeries have merged together as a Primary Care Network called Meon Health Practice. For the purposes of direct care, the organisation referred to in this privacy notice is Meon Health Practice. Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law.
Staff who have access to your information will only normally have access to that which they need to fulfil their roles.
You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests. Please see below.
We are required by articles in the General Data Protection Regulations (GDPR) to provide you with the information in the following 9 subsections.
Data Controller
Amanda Gray, Managing Director
on behalf of the Partners
Meon Health Practice
102 Highlands Road
Fareham
PO15 6JF
Tel: 01329 845777
Data Protection Officer
Caroline Sims
Primary Care IG Consultant
Email: hiowicb-hsi.comms-meonhealthpractice@nhs.net
Purpose of the processing
Direct Care is care delivered to the individual alone, most of which is provided in the Practice. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.
Lawful basis for processing
The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this Practice and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the GDPR:
- Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.
- Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”
Organisations and their employees will also respect and comply with their obligations under the common law duty of confidence
Recipient or categories of recipients of the processed data
The data will be shared with Health and care professionals and support staff in this Practice and at hospitals, diagnostic and treatment centres who contribute to your personal care.
- Anima Digital Software – Continuum Health Ltd (R3U6M) – For the purposes of direct patient care (consent taken directly on website)
- Heidi Health Medical Scribe for Patient Care – Heidi Health Trading Pty Ltd (ZB671518) – For the purposes of enhancing clinical documentation and note taking for consultations and medical records (please inform staff prior to the start of your consultation if you do not give your consent)
- Care Homes/Nursing Homes
- Child and Adolescent Mental Health Service (CAMHS)
- Child Health
- Community Professionals (Social Workers/District Nurse/Health Visitors)
- Continence and Stoma Service
- Coroner
- Care Quality Commission
- Docmail – a third Party mailing company (name and address only) – to deliver vaccination campaigns
- Primary Care Network – Meon Health Practice
- Care and Health Information Exchange (Formerly known as Hampshire Health Record)
- Individual Funding Requests
- MJOG – Text messaging system for vaccination campaigns and appointment reminders ( Mobile Telephone number only)
- AccuRX – individual text messaging – system verified consent to use
- Multi Disciplinary Teams
- Out of Hours Services
- Primary Care Services England
- Referrals to Private Healthcare
- Safeguarding
- Secondary Care (Hospitals)
- National Care Records Service
- Independent Contractors such as dentists, opticians, pharmacists
- Fire and Rescue Services
- Police and Judicial Services
- Hampshire Community Mental Health Service (MIND)
- Hampshire and Isle of Wight Integrated Care Board Medicines Optimisation Team
Data Extraction by the Integrated Care Board
The Integrated Care Board (ICB) at times extracts information about your care, but the information they extract via our computer systems cannot identify you to them. This information only refers to you by way of a code that only your practice can identify (it is pseudonymised). We will never give the ICB access to any system or information that would enable them to identify you.
The Integrated Care Board requires this pseudonymised information for the following purposes:
- For management and monitoring of the GP Practice core contract
- For management and monitoring of the GP Practice enhanced services
- For assurance of compliance with these contracts
- For assurance of the effective spending of public funding
- To conform with delegated responsibilities from NHS England
- To fulfil the ICB’s role in ensuring services commissioned meet patient population need and are being delivered in accordance with commissioning intentions Other “data processors” which you will be informed of
How the NHS and care services use your information
Meon Health Practice is one of many organisations working in the health and care system to improve care for patients and the public.
Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment.
The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
- improving the quality and standards of care provided
- research into the development of new treatments
- preventing illness and diseases
- monitoring safety
- planning services
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care.
To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
- See what is meant by confidential patient information
- Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
- Find out more about the benefits of sharing data
- Understand more about who uses the data
- Find out how your data is protected
- Be able to access the system to view, set or change your opt-out setting
- Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
- See the situations where the opt-out will not apply
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and
https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care. Our organisation ‘is / is not currently’ compliant with the national data opt-out policy.
It is recommended that this is included to be clear to patients whether your own organisation is currently compliant with the policy for applying national data opt-outs.
Microtech Surgery Pod
The Surgery Pod allows patients to enter basic information which can support their health care such as blood pressure, weight and height. Information entered is added to the patient medical record via a secure link.
The Duty of Confidentiality is with explicit consent.
Legal Basis
Article 6.1.e – under authority vested in the controller.
Article 9.2.h – for the management of health or social care.
Elite Data Analysis Service
Workload and Workforce Purpose: The purpose of this project transformation is to use staff and patient data to inform where there is a need for resource to be reviewed to maximise appointment time, depending on the need and volume of patients. The data being used will be Pseudonymised and as such will not be identifiable by the organisation processing the data. It is hoped that by analysing the workflow of clinical time and appointment setting, a more robust workforce pattern can be established to provide a greater service for patients and improve quality.
Redicare Control
Patient can be referred to Redicare for lifestyle and therapy focused education to support the care of patients with chronic conditions such as High Blood Pressure, Pre-Diabetes, Type 2 Diabetes, Dyslipidaemia, PCOS and Non-Alcoholic Fatty Liver Disease, Obesity and other similar conditions.
The remote consultation service will be delivered within the enhances access appointment times.
Legal basis – 6.1.e – under the authority of the NHS Contract
Lawful basis for sharing – 9.2.h – to deliver health care
Suvera Ltd
Patients on the Hypertension Register can be referred to Suvera for annual reviews and management of their raised blood pressure and cholesterol management. The remote consultation service will be delivered throughout the year as part of the practices call/recall for long term condition monitoring and treatment.
Legal basis – 6.1.e – under the authority of the NHS Contract
Lawful basis for sharing – 9.2.h – to deliver health care
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.
The NHS 111 service and Anima digital software – Continuum Health Ltd (R3U6M) (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.
GP Connect is not used for any purpose other than direct care.
Legal basis – 6.1.e – NHS Contract authority.
9.2.h – delivery of direct health care.
InHealth Ltd
InHealth Ltd is commissioned by Portsmouth Hospitals University NHS Trust to provide the Targeted Lung Health Checks (“TLHC”) service. The aim of the service is to identify lung cancers at an earlier stage, which evidence shows deliver much better outcomes. InHealth Ltd has been engaged to provide support to GP Practices as a Data Processor.
Rights to object
You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.
Right to access and correct
You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law. Please contact the practice.
Retention period
The data will be retained in line with the law and national guidance. Records Management Code of Practice – NHSX
Right to complain
You have the right to complain to the Information Commissioner’s Office, you can use this link https://ico.org.uk/global/contact-us/ or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate). There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website) or speak to the practice.
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