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| Activity | Rationale |
|---|---|
| Commissioning and contractual purposes Planning Quality and Performance |
Purpose – Anonymous data is used by the Integrated Care Board (ICB) for planning, performance and commissioning purposes, as directed in the practices contract, to provide services as a public authority. Legal Basis – Patients may opt out of having their personal confidential data used for Planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to https://www.nhs.uk/your-nhs-data-matters/manage-your-choice to apply a National Data Opt Out Processor – Buckingham/Oxfordshire/Berkshire (BOB) |
| Summary Care Record Including additional information |
Purpose –The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable. Legal Basis – Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that by opting out of having your information shared with the Summary Care Record could result in a delay to care that may be required in an emergency. |
| Research |
Purpose – We may share anonymous patient information with research companies for the purpose of exploring new ways of providing healthcare and treatment for patients with certain conditions. This data will not be used for any other purpose. Where personal confidential data is shared your consent will be required. Where you have opted out of having your identifiable information shared for this Planning or Research your information will not be shared. Legal Basis – • Articles 6(1)(a) and 9(1)(a) – explicit consent; or Where identifiable data is required for research, patient consent will be needed, unless there is a legitimate reason under law to do so or there is support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales. Sharing of aggregated non identifiable data is permitted. Processor – Clinical Practice Research Datalink (CPRD) |
| Individual Funding Requests |
Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our standard NHS contract. Legal Basis – Data processor –Buckingham/Oxfordshire/Berkshire (BOB) |
| Safeguarding Adults |
Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of individuals. Consent is not required to share information for this purpose. Legal Basis – Direct Care under UK GDPR: Data Processor – Berkshire Safeguarding Team |
| Safeguarding Children |
Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children. Legal Basis – Consent may not be required to share this information. Data Processor –Berkshire County Council |
| Risk Stratification – Preventative Care |
Purpose - ‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops. Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health. Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data Legal Basis – Processors –Buckingham/Oxfordshire/Berkshire (BOB) Intregrated Care Board, Connected Care |
| Public Health Screening programmes (identifiable) Notifiable disease information (identifiable) Smoking cessation (anonymous) Sexual health (anonymous) Vaccination Programmes |
Purpose – Personal identifiable and anonymous data is shared. Patients may not opt out of having their personal information shared for Public Health reasons. Legal Basis – Data Processors – Berkshire County Council |
| Direct Care NHS Trusts Community Providers Pharmacies Enhanced care providers Nursing Homes Other Care Providers |
Purpose – Personal information is shared with other secondary care trusts and providers in order to provide you with individual direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service. Legal Basis - 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(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Processors –Buckingham/Oxfordshire/Berkshire (BOB) |
| Care Quality Commission |
Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data. More detail on how they ensure compliance with data protection law (including UK GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy-statement Legal Basis – Processors – Care Quality Commission |
| Population Health Management |
Purpose – Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data in order to: Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data. NB only organisations that provide your care will see your identifiable data. Legal Basis – Data Processors - Buckingham/Oxfordshire/Berkshire (BOB), Connected Care |
| Payments |
Purpose - Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amounts paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non-patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws. Legal Basis – Data Processors – NHS England, ICB, Public Health |
| Patient Record data base |
Purpose – Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date. Your record will follow you as you change surgeries throughout your life. Legal Basis – Processor –Egton Medical Information System (EMIS) & Primary Care Services England (PCSE) |
| Medical reports Subject Access Requests |
Purpose – Your medical record may be shared in order that: Solicitors/persons acting on your behalf can conduct certain actions as instructed by you. Insurance companies seeking a medical reports where you have applied for services offered by then can have a copy to your medical history for a specific purpose. Legal Basis – Processor – Solicitors, Insurance organisations, iGPR |
| Medicines Management Team Medicines Optimisation |
Purpose – your medical record is shared with the medicines management team pharmacists, in order that your medication can be kept up to date and any necessary changes to medication can be implemented. Legal Basis – Processor – BOB ICB Medicines Management Team |
| GP Federation |
Purpose – Your medical record will be shared with the A34PCN in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics. The Federation will be acting on behalf of the GP practice. Legal Basis – Processor – A34PCN, BWPCA |
| Primary Care Network (PCN) |
Purpose – Your medical record will be shared with the A34PCN in order that they can provide direct care services to the patient population. Legal Basis – Processor – Downland Practice / Eastfield House Medical Centre / Strawberry Hill Medical Centre |
| Smoking cessation |
Purpose – personal information is shared in order for the smoking cessation service to be provided. Only those patients who wish to be party to this service will have their data shared Legal Basis – Processor –Berkshire Country Council, Solutions4Health |
| Social Prescribers |
Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their health social care needs. They may refer you to foodbank, smoking cessation, sports centres/gyms, weight management services, exercise classes and similar. Only those patients who wish to be party to this service will have their data shared. Legal Basis – Processor – Strawberry Hill Medical Centre / A34PCN |
| Police |
Purpose – Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared consent will not always be required. The Police will require the correct documentation in order to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime. Or where the information is necessary to protect a person or community. Legal Basis – UK GDPR Processor – Police Constabulary |
| Coroner |
Purpose – Personal health records or information relating to a deceased patient may be shared with the coroner. Legal Basis – UK GDPR: Processor – The Coroner, Medical Examiner |
| Medical Examiner Service |
Purpose: Purpose: Medical records associated with deceased patients are outside scope of the UK GDPR. However, next of kin details are within the scope of the UK GDPR. We will share specified deceased patient records and next of kin details with the Medical Examiners within BOBICB
Processor: Medical Examiners service – BOB ICB |
| Non-commissioned, private healthcare providers (e.g. BUPA, Virgin Care, etc.) |
Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with Private Providers. Legal Basis – Articles 6(1)(a) and 9(2)(a) consent by the patient given under contract to the provider. Provider –Private Health Care Providers |
| Messaging Service |
Purpose – Personal identifiable information shared with the messaging service in order that messages including; appointment reminders; results; campaign messages related to specific patients health needs; and direct messages to patients, can be transferred to the patient in a safe way. Legal Basis – Provider - AccuRX – NHSAPP, TreeView Website |
| Remote consultation Including – Video Consultation Clinical photography |
Purpose – Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice. Legal Basis – Patients may be videoed or asked to provide photographs with consent. There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children. Processor – Accurx |
| MDT meetings |
Purpose – For some long term conditions, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions. Personal data will be shared with other agencies in order that mutual care packages can be decided. Legal Basis – Processor – Sue Ryder, Social Services, Care Homes, Health Visitors, Community Nursing Teams |
| General Practice Extraction Service (GPES) 1. At risk patients data collection Version 3 2. CVDPREVENT Audit 3. Physical Health Checks for people with Severe Mental Illness 4. National Obesity Audit |
Purpose – GP practices are required to provide data extraction of their patients personal confidential information for various purposes to NHS England. The objective of this data collection is on an ongoing basis to identify patients registered at General Practices who fit within a certain criteria, in order to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction, by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work: 3. GPES Physical Health Checks for people with Severe Mental Illness (PHSMI) data collection. 4. National Obesity Audit - NHS Digital Legal Basis - All GP Practices in England are legally required to share data with NHS England for this purpose under section 259(1)(a) and (5) of the The Health and Social Care Act 2012 |
| Medication/Prescribing |
Purpose: Prescriptions containing personal identifiable and health data will be shared with organisations who provide medicines management including chemists/pharmacies, in order to provide patients with essential medication regime management, medicines and or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Pharmacists may be employed to review medication, Patients may be referred to pharmacists to assist with diagnosis and care for minor treatment, patients may have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver care and medication Legal Basis – Processor – Pharmacy of choice |
| Professional Training |
Purpose – We are a training surgery. Our clinical team are required to be exposed to on the job, clinical experience, as well as continual professional development. On occasion you may be asked if you are happy to be seen by one of our GP registrars, pharmacists or other clinical team to assist with their training as a clinical professional. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE. Legal Basis – Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required. Processor – RCGP, HEE, Lead Employer, |
| Telephony |
Purpose – The practice use an internet based telephony system that records telephone calls, for their own purpose and to assist with patient consultations. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients. Legal Basis – While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way. Provider – Surgery Connect – X-ON, |
| Learning Disability Mortality Programme LeDer |
Purpose: The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with this criteria will be shared with NHS England. Legal Basis: It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information who fit within a certain criteria. Processor : ICB, NHS England |
| Shared Care Record |
Purpose: In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP connect, which is managed by NHS England, to enable a shared care record, which will assist in patient information to be used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population. Where data is used for secondary uses no personal identifiable data will be used. Where personal confidential data is used for Research explicit consent will be required. Legal Basis – Processor: NHS England |
| Local shared care record Connected Care |
Purpose: Health and Social care services are developing shared systems to share data efficiently and quickly. It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment. It is also quicker for staff to access a shared record than to try to contact other staff by phone or email. Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job. Systems do not share all your data, just data which services have agreed is necessary to include. Legal Basis – Processor: Connected Care Analytics |
| Anticoagulation Monitoring |
Purpose: Personal Confidential data is shared with LumiraDX in order to provide an anticoagulation clinic to patients who are on anticoagulation medication. This will only affect patients who are within this criteria. Legal Basis – Processor : LumiraDX INRStar |
| Mindful Kidney service for patients with diabetes (and/or other conditions) |
Purpose : The data is being processed for the purpose of delivery of a programme, sponsored by NHS Digital, to monitor urine for indications of chronic kidney disease (CKD) which is recommended to be undertaken annually for patients at risk of chronic kidney disease e.g., patients living with diabetes. The programme enables patients to test their kidney function from home. We will share your contact details with Healthy.io to enable them to contact you and send you a test kit. This will help identify patients at risk of kidney disease and help us agree any early interventions that can be put in place for the benefit of your care. Healthy.io will only use your data for the purposes of delivering their service to you. If you do not wish to receive a home test kit from Healthy.io we will continue to manage your care within the Practice. Healthy.io are required to hold data we send them in line with retention periods outlined in the Records Management code of Practice for Health and Social Care. Further information about this is available at: https://lp.healthy.io/minuteful_info Legal Basis: The legal basis for this activity under UK GDPR is Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below Processor: Healthy IO |
| Joy App | Purpose: The Joy App is a database of local services which the Social Prescriber can refer in to. It keeps a referral record and outcomes record which can read back notes into the patient GP records. |
| Whzan – Community Health Checks |
Purpose: Processor: Solcom Limited - Whzan |
| Child Health Information Services (CHIS) |
Purpose: Processor: Apollo medical. SCW CHIS |
| Diagnostic Tests and test results |
Purpose: Processor: BSPS ICE, Frimley Health NHS Foundation Trust, Surrey and Sussex Healthcare Foundation Trust |
| Off Site Records Storage |
Purpose: Processor: Oasis group |
| Prescription Pricing Claims | Purpose: To help the practice claim the processing fees for practice administered medicines and items. Processor: Enhanced Primary Care |
| Care Homes/Nursing Homes | Purpose: To share medical conditions and treatments with the care or nursing home the patient is residing in. Processor: Newbury Grove, Bayford House, Birchwood, Winchcombe Place, Donnington Care Home, Newdale Court, The Willows |
| Human Resources Records and Payroll | Purpose: To manage the staff HR records, contracts, salaries, tax and pensions. Processor: BrightHR, JC Payroll. HMRC, NHS Pensions |
We keep our Privacy Notice under regular review. This notice was last reviewed in June 2024