Privacy – Salisbury Avenue GP Surgery

Privacy notice

As data controllers, GPs have fair processing responsibilities under the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). This means ensuring that your personal confidential data (PCD) is handled in ways that are safe, transparent and what you would reasonably expect. Please find documents and links below.

Salisbury Avenue Surgery Practice Privacy Notice Document

Practice privacy notice

Salisbury Avenue Surgery has a legal duty to explain how we use any personal information we collect about you at the organisation. We collect records about your health and the treatment you receive in both electronic and paper format.

Why do we have to provide this privacy notice?

We are required to provide you with this privacy notice by law. It provides information about how we use the personal and healthcare information we collect, store and hold about you. If you have any questions about this privacy notice or are unclear about how we process or use your personal information or have any other issue regarding your personal and healthcare information, then please contact our Data Protection Officer Pardeep Chibber – drsgupta.chibber@nhs.net.

The main things the law says we must tell you about what we do with your personal data are:

We must let you know why we collect personal and healthcare information about you
We must let you know how we use any personal and/or healthcare information we hold about you
We need to inform you in respect of what we do with it
We need to tell you about who we share it with or pass it on to and why
We need to let you know how long we can keep it for

Using your information

We will use your information so that we can check and review the quality of care we provide. This helps us improve our services to you.

We will share relevant information from your medical record with other health or social care staff or organisations when they provide you with care. For example, your GP will share information when they refer you to a specialist in a hospital or your GP will send details about your prescription to your chosen pharmacy.
Healthcare staff working in A&E and out of hours care will also have access to your information. For example, it is important that staff who are treating you in an emergency know if you have any allergic reactions. This will involve the use of your Summary Care Record For more information see: NHS Digital’s Summary Care Record or alternatively speak to this organisation.
You have the right to object to information being shared for your own care. Please speak to this organisation if you wish to object. You also have the right to have any mistakes or errors corrected.

Registering for NHS care

All patients who receive NHS care are registered on a national database (NHS Spine). The Spine is held and maintained by NHS Digital, a national organisation which has legal responsibilities to collect NHS data.
More information can be found at NHS Digital - Spine

Identifying patients who might be at risk of certain diseases

Your medical records will be searched by a computer programme so that we can identify patients who might be at high risk from certain diseases such as heart disease or unplanned admissions to hospital. This means we can offer patients additional care or support as early as possible.
This process will involve linking information from your GP record with information from other health or social care services you have used. Information which identifies you will only be seen by this organisation.
Please speak to the organisations if you require further information – organisation details provided upon request.

Safeguarding

Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm. These circumstances are rare and we do not need your consent or agreement to do this.
Please see our local safeguarding policies for more information.

Medical research

This organisation shares information from medical records to support medical research when the law allows us to do so, for example to learn more about why people get ill and what treatments might work best. We will also use your medical records to carry out research within the organisation.
The use of information from GP medical records is very useful in developing new treatments and medicines; medical researchers use information from these records to help to answer important questions about illnesses and disease so that improvements can be made to the care and treatment patients receive.
We occasionally share information with certain medical research organisations with your explicit permission or when the law allows.
Sometimes your information may be requested to be used for research purposes. You will always be asked by the “data processor“ for your consent to participate in any research study.
You have the right to object to your identifiable information being used or shared for medical research purposes. Please speak to the organisation if you wish to object.

Checking the quality of care – national clinical audits

This organisation contributes to national clinical audits so that healthcare can be checked and reviewed. Information from medical records can help doctors and other healthcare workers to measure and check the quality of care that is provided to you.
The results of the checks or audits can show where organisations are doing well and where they need to improve. These results are also used to recommend improvements to patient care.
Data is sent to NHS Digital, a national body with legal responsibilities to collect data.
The data will include information about you, such as your NHS Number and date of birth, and information about your health which is recorded in coded form – for example the code for diabetes or high blood pressure.
We will only share your information for national clinical audits or checking purposes when the law allows.
For more information about national clinical audits see the Healthcare Quality Improvements Partnership website or phone 020 7997 7370.
You have the right to object to your identifiable information being shared for national clinical audits. Please contact the organisation if you wish to object.

AI in General Practice

We are starting to use Artificial Intelligence such as AccuRx AI scribe. These AI Tools can be standalone products or can be embedded into other services. They are used to simplify processes to improve the efficiency, quality and speed of our business processes so valuable clinical staff time can be better used in delivering patient care. Ownership and accountability will always remain with our staff members who use and double check the product generated by AI. As time progresses, we may continue to expand the use of AI but each use case will be subject to the same high level of scrutiny.

AccuRx AI - is an advanced, secure digital assistant designed to support clinicians during consultations. It uses artificial intelligence to document medical notes, ensuring your clinician can focus on actively listening to your concerns and delivering personalised care, rather than spending time manually recording the notes. Clinicians review and approve the notes that have been captured prior to adding to the patient record.

Improved Interaction: Allows clinicians to focus solely on the patient during the consultation.
Accurate Documentation: Helps create precise, clear, and detailed medical notes for the patient record.
Time Efficiency: Streamlines administrative tasks, giving clinicians more time to spend with their patients.

Your privacy is our top priority. AccuRx AI Scribe only processes information discussed during your appointment and operates within strict privacy and data protection regulations. Before using Heidi Health AI Scribe, your clinician will explain its role and seek your verbal consent. You have the right to decline its use at any time.

Data Security: AccuRx AI Scribe complies with UK data protection laws, including GDPR, ensuring that your information is handled securely and confidentially.
Data Protection Officer: AccuRx Data Protection Impact Assessment has been reviewed and approved by our DPO.
Your Control: If you prefer not to have AccuRx AI Scribe involved, please do let your clinician know. This will not affect the quality of care you receive.

Medicines Management Teams

ICB Pharmacy Medicines Management Teams may access certain data to provide expert advice on medication management.
The data accessed by these teams is limited to information necessary for medication management purposes. This may include details about your current medications, medical history, and relevant clinical information.
Access is strictly controlled and monitored to ensure it is used appropriately.
Their role includes identifying opportunities for cost-effective medication switches, ensuring optimal therapeutic outcomes, and supporting the safe prescribing of medicines.

Individual Funding Request

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a doctor, for funding of specialised healthcare which falls outside the range of services and treatments that the 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 doctor 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 your GP.

We are required by law to provide you with the following information about how we handle your information:

Data Controller

Salisbury Avenue Surgery

Tel: 0203 675 7127

Caldicott Gaurdian - Pardeep Chibber

Data Protection Officer

Pardeep Chibber - drsgupta.chibber@nhs.net

Purpose of the processing

To give direct health or social care to individual patients.
For example, when a patient agrees to a referral for direct care, such as to a hospital, relevant information about the patient will be shared with the other healthcare staff to enable them to give appropriate advice, investigations, treatments and/or care.
To check and review the quality of care. (This is called audit and clinical governance).
Medical research and to check the quality of care that is given to patients (this is called national clinical audit)

Lawful basis for processing

These purposes are supported under the following sections 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…’; and

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...”

The following sections of the GDPR mean that we can use medical records for research and to check the quality of care (national clinical audits)

Article 6(1)(e) – ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’.

For medical research: there are two possible Article 9 conditions.

Article 9(2)(a) – ‘the data subject has given explicit consent…’

Article 9(2)(j) – ‘processing is necessary for… scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member States law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject’.

Healthcare staff will also respect and comply with their obligations under the common law duty of confidence.

Recipient or categories of recipients of the processed data

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 Sector Providers
Voluntary Sector Providers
Ambulance Trusts
Integrated Care Boards
Social Care Services
Local Authorities
Education Services
Fire and Rescue Services
Police
Other ‘data processors’ such as Research Organisations

For national clinical audits that check the quality of care, the data will be shared with NHS Digital.

Within the health partner organisations and in relation to the above mentioned we will assume you are happy to for your information to be shared unless you choose to opt out.

Right to object and the national data opt-out

You have the right to object to information being shared between those who are providing you with direct care. This may affect the care you receive – please speak to the practice.
You are not able to object to your name, address and other demographic information being sent to NHS Digital. This is necessary if you wish to be registered to receive NHS care.
You are not able to object when information is legitimately shared for safeguarding reasons. In appropriate circumstances, it is a legal and professional requirement to share information for safeguarding reasons. This is to protect people from harm. The information will be shared with the local safeguarding service.
The national data opt-out allows people to opt out of their confidential patient information being used for research and planning. It was introduced on 25 May 2018, providing a facility for individuals to opt-out from the use of their data for research or planning purposes.
The national data opt-out model provides an easy way for you to opt-out of information that identifies you being used or shared for medical research purposes and quality checking or audit purposes.

Right to access and correct

You have the right to access your medical record and have any errors or mistakes corrected. Please speak to a member of staff or register on the NHS App to view your records online.

We are not aware of any circumstances in which you will have the right to delete correct information from your medical record although you are free to obtain your own legal advice if you believe there is no lawful purpose for which we hold the information and contact us if you hold a different view.

Retention period

Records will be kept in line with the law and national guidance. Information about how long records are kept can be found in the Records Management Code of Practice.

Right to complain

In the unlikely event that you are unhappy with any element of our data-processing methods, do please contact the Practice Manager in the first instance. If you feel that we have not addressed your concern appropriately, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

Further details, visit https://ico.org.uk/for-the-public/ and select “Make a complaint” or telephone: 0303 123 1113.

Data we get from other organisations

We receive information about your health from other organisations that are involved in providing you with health and social care. For example, if you go to hospital for treatment or an operation the hospital will send us a letter to let us know what happened. This means your GP medical record is kept up-to date when you receive care from other parts of the health service.