The Jubilee Practice
Lowdham Medical Centre
Tel: 0115 9663633
Patient Privacy Notice
What is a privacy notice?
A privacy notice is a statement that describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
Why does the Practice need one?
To ensure compliance with the General Data Protection Regulation (GDPR), The Jubilee Practice must ensure that information is provided to patients about how their personal data is processed in a manner which is:
Written in clear and plain language, particularly if addressed to a child; and
What is the GDPR?
The GDPR replaces the Data Protection Directive 95/46/EC and is designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens’ data privacy and to reshape the way in which organisations across the region approach data privacy. The GPDR comes into effect on 25 May 2018.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), and the Data Protection Act 2018 (currently in Bill format before Parliament) the practice responsible for your personal data is The Jubilee Practice.
How do we communicate our privacy notice?
The practice privacy notice is displayed on our website, through signage in the waiting room, and in writing during patient registration (by means of this leaflet). This notice explains:
How do we use your information?
The Jubilee Practice will be what’s known as the ‘Controller’ of the personal data you provide to us.
Your data is collected for the purpose of providing direct patient care; however, we can disclose this information if it is required by law, if you give consent or if it is justified in the public interest. The practice may be requested to support research; however, we will always gain your consent before sharing your information with medical research databases.
In order to comply with its legal obligations, this practice may send data to NHS Digital when directed by the Secretary of State for Health under the Health and Social Care Act 2012. Additionally, this practice contributes to national clinical audits and will send the data that is required by NHS Digital when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form; for example, the clinical code for diabetes or high blood pressure. We will not provide information to them that allows you to be identified.
Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the GDPR.
Why do we need your information?
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which the Practice holds about you may include the following information;
• Details about you, such as your address, carer, legal representative, emergency contact details
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
• Notes and reports about your health
• Details about your treatment and care
• Results of investigations such as laboratory tests, x-rays etc
• Relevant information from other health professionals, relatives or those who care for you
To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.
How do we lawfully use your data?
We need to know your personal, sensitive and confidential data in order to provide you with Healthcare services as a General Practice, under the General Data Protection Regulation we will be lawfully using your information in accordance with: -
Article 6, 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;”
Article 9, (h) processing is necessary for the purposes of preventive 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
This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.
Risk stratification is a mechanism used to identify and subsequently manage those patients deemed as being at high risk of requiring urgent or emergency care. Usually this includes patients with long-term conditions, e.g. cancer. Your information is collected by a number of sources, including The Jubilee Practice; this information is processed electronically and given a risk score which is relayed to your GP who can then decide on any necessary actions to ensure that you receive the most appropriate care.
The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles.
Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.
All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary.If a sub-contractor acts as a data processor for The Jubilee Practice an appropriate contract (art 24-28) will be established for the processing of your information.
In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the practice in writing if you wish to withdraw your consent.If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.
Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose in an identifiable format.In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes.
We would however like to use your name, contact details and email address to inform you of services that may benefit you, with your consent only.There may be occasions where authorised research facilities would like you to take part on innovations, research, improving services or identifying trends.
At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:
• NHS Trusts / Foundation Trusts
• NHS Commissioning Support Units
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• NHS England (NHSE) and NHS Digital (NHSD)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Voluntary Sector Providers
• Private Sector Providers
• Other ‘data processors’ which you will be informed of
You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.
We may also use external companies to process personal information, such as for archiving purposes or for ordering dressings. These companies are bound by contractual agreements to ensure information is kept confidential and secure.All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for The Jubilee Practice an appropriate contract (art 24-28) will be established for the processing of your information.
Electronic storage of your information
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.
No third parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place.We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.
How long will we store your information?
We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.
More information on records retention can be found online at (https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016)
How can you amend & move the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), you may withdraw your consent at any time.
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.
What should you do if your personal information changes?
You should tell us so that we can update our records. Please contact reception as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.
Accessing your records
Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
Ideally you request should be made on one of our Subject Access Request forms. This form is available to download by clicking on the following link - Data Subject Access Request Form. If you are unable to complete a form then a verbal request can be taken.
There is no charge to have a copy of the information held about you
We are required to respond to you within one month
Objections / Complaints
Should you have any concerns about how your information is managed at the Practice, please contact the Practice Manager or the Data Protection Officer. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory authority as below:-
Tel: 01625 545745
If you are happy for your data to be extracted and used for the purposes described in this privacy notice, then you do not need to do anything.If you have any concerns about how your data is shared, then please contact the Practice.
Data Protection Officer
The Practice Data Protection Officer for The Jubilee Practice is Paul Couldrey of PCIG Consulting Limited. Any queries in relation to Data Protection Issues which you feel could not be resolved by the Practice should be addressed to him at: -
Postal: PCIG Consulting Limited
7 Westacre Drive
It is important to point out that we may amend this Privacy Notice from time to time.If you are dissatisfied with any aspect of our Privacy Notice, please contact the Practice.
From time to time it is helpful for us to be able to share information about your health and care requirements with other health organisations that are responsible for some of your health care. Across Nottinghamshire the Clinical Commissioning Group are introducing a new system called MIG (Medical Interoperability Gateway) which will enable us to share relevant medical information, on a view only basis, with clinicians in other healthcare organisations who are involved with your care; for example the NEMS Out of Hours team and local A&E departments.
Sharing of information in this way is designed to ensure that the healthcare professional looking after you has the most relevant information to enable them to provide you with the most appropriate care. The type of information shared is restricted and includes a summary of current problems, current medication, allergies, recent tests, diagnosis, procedures, investigations, risks and warnings – all this information is currently held in your GP system record.
Whenever a clinician from another healthcare organisation wishes to view your record they will always seek your permission before doing so; if you say “NO” they will not be able to see any information. We have automatically set up the sharing facility to allow your information to be shared. However, if you do not wish us to share your information in this way please let us know and we will ensure that your information is not shared.
Please click on the following link https://vimeo.com/124915322 to watch a short video about sharing your detailed healthcare record.
The Jubilee Practice
Lowdham Medical Centre
Tel: 0115 9663633
Monday: 08:30 – 18:30
Tuesday: 08:30 – 18:30
Wednesday: 08:30 – 18:30
Thursday: 08:30 – 12.30
Friday: 08:30 – 18:30
Closed from 13.00 – 14.00 daily.
Please note that there is NO surgery on Thursday afternoons