Privacy Notice

Direct Care (routine care and referrals)

The records we keep to enable us to look after you.

This practice keeps data on you relating to who you are, where you live, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care.

When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS.

GPs have always delegated tasks and responsibilities to others that work with them in their surgeries, on average an NHS GP has between 1,500 to 2,500 patients for whom he or she is accountable. It is not possible for the GP to provide hands on personal care for each and every one of those patients in those circumstances, for this reason GPs share your care with others, predominantly within the surgery but occasionally with outside organisations.

If your health needs require care from others elsewhere outside this practice we will exchange with them whatever information about you that is necessary for them to provide that care. When you make contact with healthcare providers outside the practice but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all of those reports. Normally we will receive equivalent reports of contacts you have with non NHS services but this is not always the case.

Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law.

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.

You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests. Please see below.

We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.

1) Data Controller contact details

Sea Mills Surgery
2 Riverleaze
Sea Mills
Bristol
BS9 2HL
Tel: 0117 968 1182
Contact us online

2) Data Protection Officer

Contact details:

Diane Douglas

Tel: 0117 968 1182

Direct Care is care delivered to the individual alone, most of which is provided in the surgery. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.

3) Purpose of the processing

Direct Care is care delivered to the individual alone, most of which is provided in the surgery. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.

4) Lawful basis for processing

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...”

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

5) Recipient or categories of recipients of the processed data

The data will be shared with Health and care professionals and support staff in this surgery and at hospitals, diagnostic and treatment centres who contribute to your personal care.

6) Rights to object

You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.

7) Right to access and correct

You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.

8) Retention period

The data will be retained in line with the law and national guidance. Speak to the practice to find out more.

9) Right to Complain.

You have the right to complain to the Information Commissioner's Office.

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).

SMS Texting Privacy Policy

We are increasingly using text messaging for appointment reminder, invites and also results. We aim to keep your consent for this current so will continue to ask you for this, and if you opt in, also asking you to confirm your mobile number.

Mobile phones have opened up a new avenue for communication between the Practice and its patients. The immediate delivery of SMS messages gives it an advantage over other forms of communication and text messaging has wide accessibility.

Text messaging is covered by the Data Protection Act and if you supply us with a mobile phone number we will ask for your consent to OPT IN to messaging. This will be both when you register with us (for new patients) and at the point of care. We will routinely check consent for text messaging for example if we are in the process of organising tests for you.

There are a number of reasons where an SMS message can be very useful:

• Appointment reminders
• Flu vaccination reminders
• Child immunisation reminders
• Making patients aware of changes to clinics or services in the Surgery
• Opportunity to receive feedback on Surgery services
• Informing patients of test results or other information relevant to their care
• Sending self- care information and links

We will not send you text messages for other reasons.

Confidentiality and security of text messaging is extremely important and we will check mobile telephone numbers as often as we can but we ask that patients let the surgery know as soon as their mobile telephone number changes. Mobile telephone numbers can be updated by calling reception or talking to the receptionists in the Surgery; they will be updated immediately. Let us know as soon as a mobile telephone number has changed.

Professional Use

We ask all our staff to minimise the amount of personal and sensitive data that they use in text messaging, and to consider carefully whether using a text message is appropriate. Our GP’s can use text messaging for sending messages to patients (such as when looking at results).

Each text message is stored in the patient’s medical record, should be clear and avoid use of abbreviations. Our messages are sent from our IT system so are not sent from a mobile phone.

Opting Out

We understand that some patients will not want to receive SMS text messages from the Practice. We ask that patients carefully consider the advantages of receiving these messages before choosing to opt-out. If patients are clear they wish to opt out, we ask them to notify the surgery in writing (by letter or by email) indicating their name and mobile telephone number.

One Way Communication

It is not possible to reply to text messages from the Practice but you can cancel appointments via the link if you receive a reminder and you can no longer attend.

Children and Young People

We will actively ask young people if they wish to OPT IN to text messaging once they are 16, and re-checking this with 16-20 year olds regularly. Young people aged 13 – 18 will be opted out by default until we can ensure that we have their own mobile number on their records, and have agreed the use of text messaging with them.

Review and Evaluation

As use of text messaging is a new and growing area, we will continually review our policy on an annual basis as well as in the event of any incident or complaint.