Practice Policies & Patient Information
Chaperone Policy
All patients are entitled to have a chaperone present for any consultation.
Please let us know at the time of requesting an appointment or speak to your GP.
Confidentiality
We appreciate that you have entrusted us with your medical care and therefore your medical records which may hold sensitive information. We would like you to know that we comply with the Data Protection Act 2018 and the Access to Health Records Act 1990, therefore any information we hold about you either within your paper records or electronically is securely kept. This information will only be shared with other healthcare professionals who are directly involved in your care.
We do not divulge any information about you to any other person unless we have your consent to do so. All the staff at Bannockburn Surgery adhere to this strict code of conduct.
It is within your legal right to access your medical records, however, please note that this requires a written request to Mrs Heather Mustafa. Please note that there is an administrative fee for this which is payable to reception on receipt of the paperwork.
Enhanced Access Privacy Notice
Privacy Notice: Enhanced Access
| Primary Care Networks (PCNs) are a key part of the NHS Long Term Plan, with all general practices being required to be in a network. This practice is part of the Heritage Primary Care Network.
Heritage PCN is made up of a number GP Practices created to work collaboratively to ensure the health care system within our area works effectively by sharing knowledge and resources.
As part of the PCN Network Contract DES, Heritage PCN will be delivering an Enhanced Access service that offers wider access to routine primary care services between the hours of 6:30-8pm on Weekdays and 9am-5pm on Saturdays.
The following services will be provided as part of Enhanced Access: • All core Primary Care services • Same Day GP Bookings • Advance GP Bookings • Minor Illness • Wound Care • Screening e.g. Smears • Immunisation e.g. Childhood immunisations, Flu • Long-Term Conditions e.g. Diabetes prevention, COPD • Health and Wellbeing e.g. Health checks, Baby checks • Sexual Health e.g. Contraceptive advice
All registered patients have availability of the appointment slots across the network.
Access will be provided to NHS111 to make use of any unused ‘on the same day’ slots within the service hours.
To enable us to provide our Enhanced Access Service to you, GPs from other local practices will at times have access to your full GP record but only when providing direct care to you.
People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments, the practice nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst the GP you see or speak to will normally have access to everything in your record.
Greenwich PCN Alliance Ltd will be providing all organisational support for this service. Note this does not include the provision of clinical hours, treatment or staff.
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| 1) Controller contact details
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| 2) Data Protection Officer contact details
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Danielle Gibbons
GP Data Protection Officer |
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| 3) Purpose of the processing | To provide our patients with direct care. | |||||
| 4) The Lawfulness Conditions and Special Categories | The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery 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…”
We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”*
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| 5) Recipient or categories of recipients of the shared data | The data will be shared with:
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| 6) Rights to object | You have the right under Article 21 of the GDPR to object to your personal information being processed. Please contact the Practice if you wish to object to the processing of your data. You should be aware that this is a right to raise an objection which is not the same as having an absolute right to have your wishes granted in every circumstance.
GP Practices process personal data under Article 6(1)(c) on a lawful and legitimate basis where the organisation is obliged under law to comply with
By complying with these laws, the Practice has compelling legitimate grounds for the processing which override the interests, rights and freedoms in the right to object. |
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| 7) Right to access and correct | Under GDPR and the Data Protection Act 2018, you have the right to see or be given a copy of any personal data we hold about you. To gain access to a copy of your information, you will need to make a Subject Access Request (SAR) to the Practice.
You also have the right to have incorrect data held about you corrected. |
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| 8) Retention period | The data will be retained for the period as specified in the national NHS records retention schedule. | |||||
| 9) 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) |
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Fair Processing and Privacy Notice
Your Information, Your Rights
Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR).
The following notice reminds you of your rights in respect of the above legislation and how your GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.
This notice reflects how we use information for:
- The management of patient records;
- Communication concerning your clinical, social and supported care;
- Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
- Participation in health and social care research; and
- The management and clinical planning of services to ensure that appropriate care is in place for our patients today and in the future.
Data Controller
As your registered GP practice, we are the data controller for any personal data that we hold about you.
What information do we collect and use?
All personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to the your care.
We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:
- ‘Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data. This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS number;
And
- ‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.
Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services). These records may be electronic, a paper record or a mixture of both. We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.
Why do we collect this information?
The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training. To do this we will need to process your information in accordance with current data protection legislation to:
- Protect your vital interests;
- Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
- Perform tasks in the public’s interest;
- Deliver preventative medicine, medical diagnosis, medical research; and
- Manage the health and social care system and services.
How is the information collected?
Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection. In addition physical information will be sent to your practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.
Who will we share your information with?
In order to deliver and coordinate your health and social care, we may share information with the following organisations:
- Local GP Practices in order to deliver extended primary care services
- NHS England
- 111 and Out of Hours Service
- Local Social Services and Community Care services
- Voluntary Support Organisations commissioned to provide services by South East London CCG
Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.
Your information will not be transferred outside of the European Union.
Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.
In addition we received data from NHS Digital (as directed by the Department of Health) such as the uptake of flu vaccinations and disease prevalence in order to assist us to improve “out of hospital care”.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information that has been collected lawfully. Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.
Information is not held for longer than is necessary. We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.
Consent and Objections
Do I need to give my consent?
The GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation. However consent is only one potential lawful basis for processing information. Therefore your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice. Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice. Your consent will be documented within your electronic patient record.
What will happen if I withhold my consent or raise an objection?
You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing. Please contact your GP Practice for further information and to raise your objection.
Health Risk Screening / Risk Stratification
Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health. By using selected information such as age, gender, [NHS number/HCN number/ CHI number], diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.
To summarise Risk Stratification is used in the NHS to:
- Help decide if a patient is at a greater risk of suffering from a particular condition;
- Prevent an emergency admission;
- Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
- Review and amend provision of current health and social care services.
Your GP will use computer based algorithms or calculations to identify their registered patients who are at most risk, with support from the local Commissioning Support Unit and/or a third party accredited Risk Stratification provider. The risk stratification contracts are arranged by South East London CCG/NHS England in accordance with the current Section 251 Agreement. Neither the CSU nor your local CCG will at any time have access to your personal or confidential data. They will only act on behalf of your GP to organise the risk stratification service with appropriate contractual technical and security measures in place.
Your GP will routinely conduct the risk stratification process outside of your GP appointment. This process is conducted electronically and without human intervention. The resulting report is then reviewed by a multidisciplinary team of staff within the Practice. This may result in contact being made with you if alterations to the provision of your care are identified.
A Section 251 Agreement is where the Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers.
As mentioned above, you have the right to object to your information being used in this way. However you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.
Sharing of Electronic Patient Records within the NHS
Electronic patient records are kept in most places where you receive healthcare. Our local electronic systems (such as SystmOne, EMIS and Eclipse) enables your record to be shared with organisations involved in your direct care, such as:
- GP practices
- Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
- Child health services that undertake routine treatment or health screening
- Urgent care organisations, minor injury units or out of hours services
- Community hospitals
- Palliative care hospitals
- Care Homes
- Mental Health Trusts
- Hospitals
- Social Care organisations
- Pharmacies
In addition, NHS England have implemented the Summary Care Record which contains information including medication you are taking and any bad reactions to medication that you have had in the past.
In most cases, particularly for patients with complex conditions and care arrangements, the shared electronic health record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health. Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so. The shared record means patients do not have to repeat their medical history at every care setting.
Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to disable this function or restrict access to specific elements of your record. This will mean that the information recorded by your GP will not be visible at any other care setting.
You can also reinstate your consent at any time by giving your permission to override your previous dissent.
Invoice Validation
If you have received treatment within the NHS, the local Commissioning Support Unit (CSU) may require access to your personal information to determine which Clinical Commissioning Group is responsible for payment for the treatment or procedures you have received. Information such as your name, address, date of treatment and associated treatment code may be passed onto the CSU to enable them to process the bill. These details are held in a secure environment and kept confidential. This information is only used to validate invoices in accordance with the current Section 251 Agreement, and will not be shared for any further commissioning purposes.
Your Right of Access to Your Records
The Data Protection Act and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format. This is known as the “right of subject access”. If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information. This can be your GP, or a provider that is or has delivered your treatment and care. You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party. If you would like access to your GP record please submit your request in writing to:
Triveni PMS. Escreet Grove, Woolwich SE18 5TE
Complaints
In the event that your feel your GP Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager at:
Triveni PMS, Escreet Grove, Woolwich SE18 5TE
If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wimslow, Cheshire SK9 5AF – Enquiry Line: 01625 545700 or online at www.ico.gov.uk
Freedom of Information
Information about the GPs and the practice required for disclosure under this act can be made available to the public. All requests for such information should be made to the practice manager.
There are seven classes of information:
- Who we are and what we do
- What we spend and how we spend it
- What our priorities are and how we are doing
- How we make decisions
- Our policies and procedures
- Lists and registers
- Services the practice offers
For more information, please review the Information Commissioner’s Office guide on the Freedom of Information Act 2000.
Suggestions, Comments and Complaints
Complaints
Although we aim to provide the highest standard of service for our patients, there may be a time where you are unhappy with the care you have received and in such cases, we ask you to put your complaint in writing to Mrs Heather Mustafa.
We comply with national policies and operate a comprehensive complaints procedure. All complaints will be dealt with efficiently and confidentially. Your complaint will be recorded and acknowledged within three working days and we shall provide a substantive response four weeks from receipt. Should any issue remain unresolved, you are at liberty to telephone Patient Advice and Liaison Service (PALS) on 02088 364694 or to take the matter further with Greenwich Teaching Primary Care Trust or the local Community Health Council.
Feedback
If you want to know what others think about our service please look at our profiles at:
You can share any feedback with us directly by completing our Feedback form. Alternatively, you can of course also let us know how we are doing on NHS Choices.
Summary Care Records
Summary Care Records
There is a central NHS computer system called the summary care record (SCR). It is an electronic record which contains information about the medicines you take, allergies you suffer from and any bad reactions to medicines you have had. Over time it will build to include information about other health issues considered important to your wellbeing.
Why do I need a summary care record?
Storing information in one place makes it easier for healthcare staff to treat you in an emergency, or when your GP practice is closed.
This information could make a difference to how a doctor decides to care for you, for example which medicines they choose to prescribe for you.
Who can see it?
Only healthcare staff involved in your care can see your summary care record.
How do I know if I have one?
Over half of the population of England now have a summary care record. You can find out whether summary care records have come to your area by asking the surgery directly.
Enhanced summary care record
If you wanted to ‘enhance’ your record it would include the following information:
- Significant medical history (past and present)
- Reason for medication
- Anticipatory care information (important in the management of long term conditions)
- Communication preferences
- End of life care information
- Immunisations
You can opt in for an enhanced summary care record at any time.
Children under the age of 16
Patients under 16 years will have an enhanced summary care record created for them unless their GP surgery is advised otherwise. If you are the parent or guardian of a child under 16 then you should make this information available to them if they are old enough to decide for themselves if they want a summary care record.
Whatever you decide, you can change your mind at any time.
If you are a family member or carer of a person and you have concerns that they may not have the mental capability to make this decision, please use our Contact the Practice form.
Do I have to have one?
No, it is not compulsory. If you choose to opt out of the scheme, then you will need to complete the Summary Care Record Opt Out form.
More information
For further information, please visit the HSCIC Website.