Privacy notice

This privacy notice explains what information we collect about you, how we store this information, how long we retain it and with whom and for which legal purpose we may share it.

Bethany Medical Centre also publishes a number of specific notices which are available at the bottom of this page.

To find out more about our privacy notice, please read the following:

  • Who we are?
  • Why we collect personal information about you?
  • What is our legal basis for processing your personal information?
  • What personal information do we need to collect about you and how do we obtain it?
  • What do we do with your personal information and what we may do with your personal information?
  • Who do we share your personal information with and why?
  • How we maintain your records?
  • What are your rights?
  • Who is the Data Protection Officer?
  • How to contact the Information Commissioners Office

Who we are?

Bethany Medical Centre employs more than 9 and operates from 151 Grafton Street, St Helens.

Our practice is registered with the Information Commissioner’s Office (ICO) to process personal and special categories of information under the Data Protection Act 2018 (subject to parliamentary approval) and our registration number is Z7474355.

Why we collect personal information about you?

The staff caring for you need to collect and maintain information about your health, treatment and care, so that you can be given the best possible care. This personal information can be held in a variety of formats, including paper records, electronically on computer systems, in video and audio files.

What is our legal basis for processing personal information about you?

Any personal information we hold about you is processed for the purposes of ‘provision of health or social care or treatment or the management of health of social care systems and services under chapter 2, section 9 of the Data Protection Act 2018 (subject to parliamentary approval).

For further information on this legislation please visit: www.legislation.gov.uk.

What personal information do we need to collect about you and how do we obtain it?

Personal information about you is collected in a number of ways. This can be from referral details from our staff, other 3rd parties or hospitals, directly from you or your authorised representative.

We will likely hold the following basic personal information about you: your name, address (including correspondence), telephone numbers, date of birth, next of kin contacts, etc. We might also hold your email address, marital status, occupation, overseas status, place of birth and preferred name or maiden name.

In addition to the above, we may hold sensitive personal information about you which could include:

  • Notes and reports about your health, treatment and care, including:
    • your medical conditions
    • results of investigations, such as x-rays and laboratory tests
    • future care you may need
    • personal information from people who care for and know you, such as relatives and health or social care professionals
    • other personal information such as smoking status and any learning disabilities
  • Your religion and ethnic origin
  • Whether or not you are subject to any protection orders regarding your health, wellbeing and human rights (safeguarding status).

It is important for us to have a complete picture of you as this will assist staff to deliver appropriate treatment and care plans in accordance with your needs.

What do we do with your personal information?

  • The new telephone system now includes the ability to record both the inbound and outbound calls made to and from the practice telephones
  • Practices use the recording of phone calls for a number of reasons, these include but are not limited to: investigating complaints, investigation of incidents, staff training, and prevention and detection of fraud
  • The recordings are stored for 3 years.
  • Within the practice, authorised users as requested by Practice Manager can access the call recordings, support can be accessed from the MMDA IT team in order to export a call or provide an extract from a call recording. The Practice Managers and Deputies can export calls if they have sufficient rights. This permission is granted on a per user basis.
  • Patients are entitled to a copy of their call recordings, The Data Protection Act 2018 allows individuals to access a copy of their information that is held about them, practices should process a request to access a call recording in the same way in which they process any other subject access request.

Your records are used to directly, manage and deliver healthcare to you to ensure that:

  • The staff involved in your care have accurate and up to date information to assess and advice on the most appropriate care for you.
  • Staff have the information they need to be able to assess and improve the quality and type of care you receive.
  • Appropriate information is available if you see another healthcare professional, or are referred to a specialist or another part of the NHS, social care or health provider.

The personal information we collect about you may also be used to:

  • Remind you about your appointments and send you relevant correspondence.
  • review the care we provide to ensure it is of the highest standard and quality, e.g. through audit or service improvement;
  • support the funding of your care, e.g. with commissioning organisations;
  • prepare statistics on NHS performance to meet the needs of the population or for the Department of Health and other regulatory bodies;
  • help to train and educate healthcare professionals;
  • report and investigate complaints, claims and untoward incidents;
  • report events to the appropriate authorities when we are required to do so by law;
  • review your suitability for research study or clinical trial
  • contact you with regards to patient satisfaction surveys relating to services you have used within our hospital so as to further improve our services to patients
  • Where possible, we will always look to anonymise/ pseudonymise your personal information so as to protect patient confidentiality, unless there is a legal basis that permits us to use it and we will only use/ share the minimum information necessary.

Who do we share your information with and why?

We may need to share relevant personal information with other NHS organisations. For example, we may share your information for healthcare purposes with health authorities such as NHS England, Public Health England, NHS trusts, other general practitioners (GPs), ambulance services, primary care agencies, etc. We will also share information with other parts of the NHS and those contracted to provide services to the NHS in order to support your healthcare needs.

We may need to share information from your health records with other non-NHS organisations from which you are also receiving care, such as social services or private care homes. However, we will not disclose any health information to third parties without your explicit consent unless there are circumstances, such as when the health or safety of others is at risk or where current legislation permits or requires it.

There are occasions where the practice is required by law to share information provided to us with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud.

There may also be situations where we are under a duty to share your information, due to a legal requirement. This includes, but is not limited to, disclosure under a court order, sharing with the Care Quality Commission for inspection purposes, the police for the prevention or detection of crime or where there is an overriding public interest to prevent abuse or serious harm to others and other public bodies (e.g. HMRC for the misuse of public funds in order to prevent and detect fraud).

For any request to transfer your data internationally outside the UK/EU, we will make sure that an adequate level of protection is satisfied before the transfer.

The practice is required to protect your personal information, inform you of how your personal information will be used, and allow you to decide if and how your personal information can be shared. Personal information you provide to the Practice in confidence will only be used for the purposes explained to you and to which you have consented. Unless, there are exceptional circumstances, such as when the health or safety of others is at risk, where the law requires it or there is an overriding public interest to do so. Where there is cause to do this, the Practice will always do its best to notify you of this sharing.

How we maintain your records

Your personal information is held in both paper and electronic forms for specified periods of time as set out in the NHS records management code of practice for health and social care and national archives requirements.

We hold and process your information in accordance with the Data Protection Act 2018 (subject to Parliamentary approval) as amended by the GDPR 2016, as explained above.  In addition, everyone working for the NHS must comply with the common law duty of confidentiality and various national and professional standards and requirements.

We have a duty to:

  • maintain full and accurate records of the care we provide to you;
  • keep records about you confidential and secure;
  • provide information in a format that is accessible to you.

Use of Email – Some services in the Practice provide the option to communicate with patients via email. Please be aware that the Practice cannot guarantee the security of this information whilst in transit, and by requesting this service you are accepting this risk.

Further information can be found in our Information Governance policies, which are available at: www.sthk.nhs.uk – Our policies and procedures.

Sharing patient data with NHS Digital and opting out

How sharing patient data with NHS Digital helps the NHS and you:

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 for Planning and Research data collection will help the NHS to improve health and care services for everyone by collecting patient data that can be used to do this. For example patient data can help the NHS to:

  • monitor the long-term safety and effectiveness of care
  • plan how to deliver better health and care services
  • prevent the spread of infectious diseases
  • identify new treatments and medicines through health research

GP practices already share patient data for these purposes, but this new data collection will be more efficient and effective.

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 coronavirus 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.

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.

To view further information please visit www.digital.nhs.uk – General Practice Data for Planning and Research: NHS Digital Transparency Notice which provides up to date information on the Data Collection.

Opting out of NHS Digital collecting your data

At present the NHS has not set a specific start date for the collection of data and have paused future plans for at least the next 12 months – this will allow them to work in collaboration with a range of partners including the Royal College of General Practitioners (RCGP) and the British Medical Association (BMA). The want to reassure you that they have heard your concerns loud and clear and will continue to listen and provide the best and safest possible care for patients.

Opt-outs

If you wish to register a type 1 opt-out with your GP practice before data sharing starts with NHS Digital, this should be done by returning the Type 1 Opt-out form to your GP practice.

If you do not want NHS Digital to share your identifiable patient data with anyone else for purposes beyond your own care, then you can also register a national data opt-out.

What are your rights?

If we need to use your personal information for any reasons beyond those stated above, we will discuss this with you and ask for your explicit consent. The Data Protection Act 2018 (subject to parliamentary approval) gives you certain rights, including the right to:

  • Request access to the personal data we hold about you, e.g. in health records.  The way in which you can access your own health records is further explained in our ‘subject access request policy’.
  • Request the correction of inaccurate or incomplete information recorded in our health records, subject to certain safeguards.  This is also explained in our ‘subject access request policy’.
  • Refuse/withdraw consent to the sharing of your health records: Under the Data Protection Act 2018 (subject to parliamentary approval), we are authorised to process, i.e. share, your health records ‘for the management of healthcare systems and services’. Your consent will only be required if we intend to share your health records beyond these purposes, as explained above (e.g. research).  Any consent form you will be asked to sign will give you the option to ‘refuse’ consent and will explain how you can ‘withdraw’ any given consent at a later time. The consent form will also warn you about the possible consequences of such refusal/withdrawal.
  • Request your personal information to be transferred to other providers on certain occasions.
  • Object to the use of your personal information: In certain circumstances you may also have the right to ‘object’ to the processing (i.e. sharing) of your information where the sharing would be for a purpose beyond your care and treatment (e.g. as part of a local/regional data sharing initiative). This so called ‘‘data opt-out’ initiative, developed by Dame Caldicott, is set to commence in March 2018 and conclude in March 2020. Further information can be found on the following website: www.digital.nhs.uk – National data opt-out.
  • We will always try to keep your information confidential and only share information when absolutely necessary.

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

Practice information governance lead

Georgina Lopes

01744 734128

Data Protection Officer

Name
Mr Malcolm Gandy

Role
Deputy Director of Informatics
Address: St Helens & Knowsley Teaching Hospital Trust
Health Informatics Services
Alexandra Business Park
Prescot Road
St Helens
WA10 3TP

Phone
0151 676 5698

Email
IG@sthk.nhs.uk

Information Commissioner’s Office

The Information Commissioner’s Office (ICO) is the body that regulates the practice under data protection and freedom of information legislation. www.ico.org.uk. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the ICO at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone
0303 123 1113 (local rate)
or
01625 545 745 if you prefer to use a national rate number

Email
casework@ico.org.uk