How information about you helps us to provide better care

Confidential information from your medical records can be used by the NHS to improve the services offered so we can provide the best possible care for everyone.

This information along with your postcode and NHS number but not your name, are sent to a secure system where it can be linked with other health information.

This allows those planning NHS services or carrying out medical research to use information from different parts of the NHS in a way which does not identify you.

You have a choice

If you are happy for your information to be used in this way you do not have to do anything.

If you have any concerns or wish to prevent this from happening, please speak to practice staff or ask at reception for a copy of the leaflet “How information about you helps us to provide better care”.

More information can be found at www.nhs.uk/caredata.

Lead GP: Dr Kamalakshy

All staff and volunteers of this practice recognise they have a duty to safeguard children who present to this practice.

This practice will take all reasonable steps to ensure that any evidence of child maltreatment in relation to physical abuse, emotional abuse, neglect and sexual abuse is identified and acted on.

Any suspected cases of child maltreatment will be brought to the attention of the lead GP and practice manager within 24 hours.

The lead GP will:

• Listen to the concern and if appropriate, notify social care
• Seek advice from safeguarding colleagues in health and social care
• In cases of immediate serious threat the practice will inform the police and social care

The notification to social care will be by phone and in writing within 3 working days.

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
• 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 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).
• ‘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
• 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, GP hubs, local trusts/hospitals/health boards
• 111 and out of hours service
• Local Social Services and Community Care services

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 of 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 numbers, 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.
• 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 your local CCG/Health Board 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 by completing our online form 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 Vision, 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:

Practice manager,
Plumstead Health Centre,
Tewson Road,
Plumstead,
SE18 1BH

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:

Practice manager,
Plumstead Health Centre,
Tewson Road,
Plumstead,
SE18 1BH

You can also complain online by completing the Feedback and Complaints form.

If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at:

Wycliffe House,
Water Lane,
Wimslow,
Cheshire,
SK9 5AF

You can also call their enquiry line on 01625 545700 or contact them online at www.ico.org.uk.

We are continually looking to turn patient feedback into real improvements in the services we provide. We use it to focus on the things that matter most to our patients, carers and their families.

Giving feedback

To provide feedback:

• fill out a feedback form
• take part in the Friends and Family Test
• leave a review on the NHS website
• phone us on Plumstead Health Centre 020 8316 5472 or Garland Road Clinic 020 8305 7600

Complaints procedure

Let the practice know your views

Plumstead Health Centre is always looking for ways to improve the services it offers to patients. To do this effectively, the practice needs to know what you think about the services you receive. Tell us what we do best, where we do not meet your expectations plus any ideas and suggestions you may have. Only by listening to you can the practice continue to build and improve upon the service it offers.

Send your written complaint to: practice manager, Michele Leadsham.

Practice complaint procedure

If you have a complaint about the service you have received from any member of staff working in this practice, please let us know. The practice operates a complaints procedure as part of the NHS system for dealing with complaints. Our complaints system meets national criteria.

If you make a complaint it is practice policy to ensure you are not discriminated against, or subjected to any negative effect on your care, treatment or support.

How to complain

We hope that most problems can be resolved easily and quickly, often at the time they arise and with the person concerned. Where the issue cannot be resolved at this stage and you wish to make a complaint, please contact the practice manager, Michele Leadsham, who will try to resolve the issue and offer you further advice on the complaints procedure. If your problem cannot be resolved at this stage and you wish to make a formal complaint, please let us know as soon as possible, ideally within a matter of days. This will enable the practice to get a clear picture of the circumstances surrounding the complaint.

If it is not possible to raise your complaint immediately, please let us have details of your complaint within the following timescales:

• Within 12 months of the incident that caused the problem or
• Within 12 months from when the complaint comes to your notice

The practice will acknowledge your complaint within three working days and may arrange a meeting with you to discuss the complaint, to agree with you how the complaint is going to be investigated and the timescale for this to be completed.

To contact the practice manager to make a complaint, please email GRECCG.Plumsteadhcpms@nhs.net addressed for the attention of practice manager, Michele Leadsham.

What we will do

We shall acknowledge your complaint within three working days and aim to have looked into your complaint within 28 working days of the date when your complaint was acknowledge by us. We shall then be in a position to offer you an explanation, or a meeting with the people involved. If the practice feels more time is needed a request will be made to extend.

When we look into your complaint, we shall aim to:

• Ascertain the full circumstances of the complaint
• Make arrangements for you to discuss the problem with those concerned, if you would like this
• Make sure you receive an apology, where this is appropriate
• Identify what the Practice can do to make sure the problem does not happen again

Complaining on behalf of someone else

Please note that Plumstead Health Centre keeps strictly to the rules of medical confidentiality. If you are complaining on behalf of someone else, the practice needs to know that you have their permission to do so. A written and signed consent by the person concerned will be required, unless they are incapable of providing this due to illness or disability.

Advocacy and Ombudsman

The practice management team hope that if you have a problem you will use the practice complaints procedure.

However, if you feel you cannot raise your complaint with us, you can contact any of the following bodies:

NHS Complaints Advocacy Service

This is a free and independent national service that supports people who want to make a complaint about their NHS care or treatment.

Your local NHS Complaints advocate support can be contacted on 0300 303 1660 or www.nhscomplaintsadvocacy.org.

The local healthwatch can be found at www.healthwatch.co.uk.

Parliamentary & Health Service Ombudsman

If you are not happy with the response from this practice, you can refer your complaint to the Parliamentary and Health Service Ombudsman who investigates complaints about the NHS in England.

You can call the Ombudsman’s Complaints Helpline on 0345 015 4033 or write to:

The Parliamentary & Health Service Ombudsman,
Millbank Tower,
30 Millbank,
London,
SW1P 4QP

Website
www.ombudsman.org.uk

NHS England

Complaints Team,
PO Box 16738,
Redditch,
B97 9PT

Phone
0300 311 22 33

Email
england.contactus@nhs.net

We assign all new and existing patients with a named accountable GP to oversee their care.

For patients aged 75 and over, the named accountable GP is responsible for:

• working with health and social care professionals to deliver a care package that meets the needs of the patient
• ensuring that these patients have access to a health check

Patients can still choose to see any GP in the surgery. We will make reasonable efforts to accommodate their preference.

If you have a preference or want to know who your named GP is, you can contact us for more information.

Patient responsibilities

• If you are unable to keep your appointment, please inform us early as we can offer this appointment to someone else. If you need to cancel your appointment, you can do so by completing the cancel an appointment form.
• If you are unsure of any aspect of your care, please ask for clarification.
• Please inform your doctor or a nurse of any significant family history that may have a bearing on your treatment/care.
• Please keep the practice up to date with changes to your name and/or address and/or telephone number. If you have a mobile number, please give it to reception as we will be able to remind you of any appointments you have at the surgery (see practice notice board) and involve you in our health promotions. You can change your personal details by completing the change personal details form.
• Please remember that an appointment is for one person only.
• We expect you to be courteous and respectful to doctors and practice staff. We employ a zero tolerance policy in this practice as set down by the NHS. If there is an incident of threatening or violent behaviour, the practice will seek to have the immediate removal of the patient from the practice. This will possibly impact on your future ability to freely register with another GP.
• We appreciate patient involvement and welcome suggestions of ways we can improve our services (polite suggestions only). If you are interested in joining our Patient Participation Group, please give your details to the receptionist who will pass them on to the practice manager. Alternatively, you can complete the Patient Participation Group registration form.

Practice responsibilities

• Your rights to confidentiality are paramount and we adhere to the Data Protection Act 2018 which states that: all information which has been obtained shall be adequate, relevant and used for the purpose for which it is held; all personal data held shall be accurate and where necessary kept up to date and surrounded by proper security.
• To improve the services that we and the Health Authority provide to patients, the contents of your health records may be used in an anonymous form during clinical audits. If you do not wish your records to be included in any way not relating directly to your health, please notify your GP or the practice manager who will ensure that your request is documented in your records. If you require further information please discuss with a clinician or the practice manager.
• The practice shall provide each individual the right to access data held about them, and where appropriate, to have the data corrected or deleted. To obtain access to personal data, the patient must apply in writing to either the GP or practice manager allowing up to 40 days for a response and there will be a charge for supplying information.
• Your religious and cultural beliefs will be respected.
• You will be treated in a friendly and courteous manner whenever you telephone or visit the surgery.

How we use your medical records

Important information for patients:

• This practice handles medical records in-line with laws on data protection and confidentiality.
• We share medical records with those who are involved in providing you with care and treatment.
• In some circumstances we will also share medical records for medical research, for example to find out more about why people get ill.
• We share information when the law requires us to do so, for example, to prevent infectious diseases from spreading or to check the care being provided to you is safe.
• You have the right to be given a copy of your medical record.
• You have the right to object to your medical records being shared with those who provide you with care.
• You have the right to object to your information being used for medical research and to plan health services.
• You have the right to have any mistakes corrected and to complain to the Information Commissioner’s Office.

Please see the Fair Processing Privacy Notice on the website or speak to a member of staff for more information about your rights.

The Data Protection Act requires that patient be informed, in general terms, how their information may be used, who will have access to it and the organisations it may be disclosed to. As a patient you will have the authority to withhold consent for your information to be shared with a third party except in certain circumstances (contact the practice for more details).

Plumstead Health Centre is committed to the delivery of a first class confidential service. This means ensuring that all patient information is protected and processed correctly. Patient information is held under legal and ethical obligations of confidentiality. Patient information is stored in GP records, and it is also stored electronically on our computer system.

Staff members will carry out their duties while adhering to guidance from:

• Caldicott Principles
  This outlines the conditions of how and when confidential patient information should be stored, used, and passed on to another person, department or organisation.
• Confidentiality: NHS Code of Practice
  This document focuses on confidentiality and patients’ consent to the use of their health records.