This privacy notice describes the data the practice holds about you, why we hold it, where and how we store it, how long for and how we protect it. It also tells you about your rights under the Data Protection Legislation and how the law protects you.

Who we are and what do we do? 

Coleridge Medical Centre, Canaan Way, Ottery St Mary, Devon EX11 1EQ. 

Coleridge Medical Centre is a Data Controller for the data we hold about you. We hold your data in order to provide you with health and social care.

What is personal data and what data do we use?

Your personal data is any information that can be connected to you personally. If you can be identified from the data, it is personal data. The types of personal data we use and hold about you are:

• Details about you: your name, address, contact number, email address, date of birth, gender and NHS number.
• We may also hold information about your emergency contact, next of kin and carer. 
• Details about your medical care: medical diagnosis, record of treatment received, referrals, history of prescribed medication, results of investigations such as x-rays etc.
• Information provided by you: this includes correspondence relating to feedback, concerns and complaints about the service you have received.
• Relevant information from other healthcare professionals, relatives or those who care for you.
• CCTV: CCTV is in place in our practice. It has been installed solely for the safety and security of our premises, patients and staff, to prevent and deter crime. 
• Telephone Call Recordings: all incoming and outgoing calls are recorded for training and monitoring purposes.  Call recordings are also used to investigate complaints and issues raised by patients and by staff.

We may also hold the following information about you:

• Religion or other beliefs of a similar nature
• Family, lifestyle and/or social circumstances
• Employment details
• Financial details

When we collect your mobile number, we may use it – with your consent – to remind you of appointments, and any other important notifications released from the practice. If you no longer wish to receive communication in this way, please let a member of staff know and they will be able to update your preferences.

When we collect your email address, we may use it – with your consent – to send you surveys about the practice, newsletters, and other information about changes within the practice. If you no longer wish to receive communication in this way, please let a member of staff know and they will be able to update your preferences.

Why do we process your data and what legal basis do we have to process your data?

In order to process your personal data or share your personal data outside of the practice, we need legal basis to do so. If we process or share special category data such as health data we will need an additional legal basis to do so.

We rely upon Article 6(1)(e) (public interest task) and Article 9(2)(h) (health and social care) for most of our processing and sharing, in particular to:

• Provide you with health and social care
• Share data from, or allow access to, you GP record, for healthcare professionals involved in providing you with health and social care
• Receive data from or access your data on other NHS organisation clinician systems
• Work effectively with other organisations and healthcare professionals who are involved in your care
• Ensure that your treatment and advice, and the treatment of others is safe and effective
• Participate in National Screening Programmes
• Use a computer program to identify patients who might be at risk from certain diseases or unplanned admissions to hospitals
• Help NHS Digital and the practice to conduct clinical audits to ensure you are being provided with safe, high quality care
• Support medical research when the law allows us to do so
• Supply data to help plan and manage services and prevent infectious diseases from spreading.

We rely upon Article 6(1)(d) (vital interest) and Article 9(2)(c) (vital interests) to share information about your with another healthcare professional in a medical emergency. We rely upon Article 6(1)(e) (public interest task) and Article 9(2)(g) (substantial public interest) to support safeguarding for patients who, for instance, may be particularly vulnerable to protect them from harm or other forms of abuse.

We rely upon Article 6(1)(c) (legal obligation) and Article 9(2)(h) to share your information for mandatory disclosures of information (such as NHS Digital, CQC and Public Health England).

We rely upon Article 6(1)(c) (legal obligation) and Article 9(2)(f) (legal claims) to help us investigate legal claims and if a court of law orders us to do so.

We rely upon Article 6(1)(a) (consent) and Article 9(2)(a) (explicit consent), in order to:

• Help the practice investigate any feedback, including patient surveys, complaints or concerns you may have about contact with the practice
• Help manage how we provide you with services from the practice, for example, when you nominate individuals to contact the practice on your behalf 
• Share information with third parties, for example, insurance companies and medical research organisations

We also use anonymised data to plan and improve health care services. Specifically, we use it to:

• Review the care being provided to make sure it is of the highest standard
• Check the quality and efficiency of the services we provide
• Prepare performance reports on the services we provide

 Healthcare staff will respect and comply with their obligations under the common law duty of confidence.

How do we collect your data?

The practice collects data that you provide when you:

• Receive treatment or care from the practice
• Contact the practice by telephone (all telephone calls received and made by the practice are recorded), online or in person
• Complete a form electronically or on paper
• Contact the practice via a social network (for example if your communication with the practice through Twitter or Facebook)
• Visit the practice’s website (if cookies are enabled).

We receive information about you from the other providers to ensure that we provide you with effective and comprehensive treatment. These providers may include:

• The GP practices within the HOSMS Primary Care Network
• Other GP practices
• NHS Trusts / Foundation Trusts
• NHS Commissioning Support Units (CSUs) Community Services (District Nurses, Rehabilitation Services and out of hours services)
• Ambulance or emergency services
• Independent contractors such as pharmacies, dentists and opticians
• NHS DevonIntegrated Care Board (ICB)
• NHS Digital
• NHS England
• Local authorities
• Health and Social Care Information Centre (HSCIC)
• Police and judicial services
• Educational services
• NHS 111
• Public Health England and screening
• Non-NHS healthcare providers
• Research providers

We also use AccuRx which is an online tool that allows you to get advice and treatment, request sick notes and results or self-help.

AccuRx is provided by a third-party organisation and by using AccuRx, you are submitting your information to them. This information is then provided to the practice to be reviewed. Further information on AccuRx can be found: https://www.accurx.com/privacy-policy

You can also use AccuRx via the NHSApp. Further information regarding the role of NHS England and the practice can be found: https://www.nhs.uk/using-the-nhs/nhs-services/the-nhs-app/privacy/online-consultations/

Who do we share your data with?

In order to deliver and coordinate your health and social care, we may sometimes share information with other organisations. We will only ever share information about you if other agencies involved in your care have a genuine need for it. Anyone who receives information from the practice is under a legal duty to keep it confidential and secure. 

Please be aware that there may be certain circumstances, such as assisting the police with the investigation of a serious crime, where it may be necessary for the practice to share your personal information with the external agencies without your knowledge or consent.

We may share information with the following organisations:

• The GP Practices within the HOSMS Primary Care Network
• Other GP practices
• NHS Trusts / Foundation Trusts
• NHS DevonIntegrated Care Board (ICB)
• One Devon Integrated Care System
• NHS Commissioning Support Units
• Community services (District Nurses, Rehabilitation Services and out of hours services)
• Ambulance and emergency services
• Independent contractors such as pharmacies, dentists, opticians
• Local authorities
• Multi-Agency Safeguarding Hub (MASH)
• Health and Social Care Information Centre (HSCIC)
• Police and judicial services
• Educational services
• Fire and rescue services
• NHS 111
• The Care Quality Commission, ICO and other regulated auditors
• Public Health England and Screening
• NHS England
• NHS Digital
• Non-NHS health care providers
• Research providers

In addition to sharing data with the above services, the practice will also use carefully selected third party service providers that process data on behalf of the practice. When we use a third party service provider, we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating responsibly to ensure the protection of your data. Examples of functions that may be carried out by third parties includes:

• Organisations that provide IT services and support, including our core clinical systems; systems which manage patient facing services (such as our website); data hosting service providers; systems which facilitate video consultation, appointment bookings or electronic prescription services; document management services etc
• Organisations who are delivering services on behalf of the practice (for example, conducting Medicines Management Reviews to ensure that you receive the most appropriate, up to date and cost-effective treatments or supporting practices in offering choices of providers and appointments to patients who are being referred via the NHS e-referral system)
• Delivery services (for example, if we were to arrange for delivery of any medicines to you)
• Payment providers (if, for example, you were paying for a prescription or a service such as travel vaccinations)  
• For further information of who we share your personal data with and our third-party processors, please contact the Practice

Where do we store your data?

We use a number of IT systems and tools to store and process your data, on behalf of the practice. Examples of tools we use include our Core Clinical System – TPP SystmOne, NHSmail, Office365, and AccuRx

For further information on this, please contact the Practice .

CCTV (Closed Circuit Television)  

We may record CCTV images of people entering, approaching, entering or passing our buildings to: 

• Help staff and visitors feel safer 
• Act as a deterrent to offenders 
• Allow the collection of evidence to help find and convict offenders 

There are clear signs within our premise to advise you CCTV is in operation.  

Our lawful basis is public task – the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

Under data protection legislation, we are permitted to use your information this way because we have a statutory duty to protect the public and staff. We also have a legitimate interest in securing our premises and reducing complaints against our staff

Your information may be shared with other organisations, but we will only do this when necessary or if they have a legal right to it. We will delete recordings 3 months after the CCTV footage was taken. This ensures that any subsequent investigations can be completed. 
 
You have the right to: 

• View a copy of the CCTV recording  
• Request that the CCTV recording be deleted if you believe the practice is processing it for longer than is necessary 

GPConnect/Interoperability/Enhanced Data Sharing Module

We may share your record using GPConnect / Interoperability / Enhanced Data Sharing Module to make sure that you are visiting the practice, attending hospital, or being seen in the community or at home by a care professional, everyone knows the care you need and how you want to be treated. Your electronic health record is available to the practices in HOSMS PCN and East Devon who are involved in your care. This includes the sharing of personal contact details, diagnoses, medications, allergies and test results. Your records will be treated with the strictest confidence and can only be viewed if you use their service. Please note that if you have previously dissented (opted-out) to sharing your records, this decision will be upheld, and your record will only be accessed by the practice. Should you wish to opt-out, please contact us so that we can update your personal preferences. Please note that by opting out of this sharing, other health professionals may not be able to see important medical information, which may impact on the care you receive.

Devon & Cornwall Care Record

Health and social care services in Devon and Cornwall have developed a system to share patient data efficiently and quickly and, ultimately, improve the care you receive.

This shared system is called the Devon and Cornwall Care Record.

It’s important that anyone treating you has access to your shared record so they have all the information they need to care for you. This applies to your routine appointments and also in urgent situations such as going to A&E, calling 111 or going to an out-of-hours appointment.  

It’s also quicker for staff to access a shared record than to try to contact other staff by phone or email.  

Only authorised health and care staff can access the Devon and Cornwall Care Record and the information they see is carefully checked so that it relates to their job. Also, systems do not share all your data – just data that services have agreed is necessary to include.

For more information about the Devon and Cornwall Care Record, please go to https://www.devonandcornwallcarerecord.nhs.uk/

Summary Care Record (SCR)

NHS England have implemented the SCR which contains information about you; including your name, address, date of birth, NHS number, medication you are taking and any bad reactions to medication that you have had in the past. This information is automatically extracted from your records and uploaded onto a central system. Many patients who are seen outside of their GP practice are understandable not able to provide a full account of their care or may not be in a position to do so. The SCR means patients do not have to repeat their medical history at every care setting and the healthcare professional they are seeing is able to access their SCR. The SCR can only be viewed within the NHS smartcard-controlled screens or by organisations, such as pharmacies, contracted to the NHS.

As well as this basic record, additional information can be added to include further information. However, any additional data will only be uploaded if you specifically request it and with your consent. You can find out more about the SCR here: https://digital.nhs.uk/services/summary-care-records-scr

National Screening Programmes

The NHS provides national screening programmes so that certain diseases can be detected at early stages. These screening programmes include bowel cancer, breast cancer, cervical cancer, aortic aneurysms and a diabetic eye screening service. More information on the national screening programmes can be found at: Population screening programmes: detailed information - GOV.UK (www.gov.uk)

Risk Stratification

Your medical records will be searched by a computer program so that we can identify patients who might be at high risk from certain diseases, such as heart disease or unplanned admissions to hospital. This means we can offer patients additional care or support as early as possible. This process will involve linking information from your GP record with information from other health and social care services you have used. Information which identifies you will only be seen by this practice. More information can be found at https://www.england.nhs.uk/ig/risk-stratification

Population Health Analytics

One Devon Dataset

As well as using your data to support the delivery of care to you, your data may be used to help improve the way health and social care is delivered to patients and service users throughout Devon using Population Health Management methods.

We will use a pseudonymised extract (ie. not identifiable information) which will be sent securely to NHS Devon ICB (Integrated Care Board) and in partnership with the Local Authorities. Data will be used to support the Devon Integrated Care System to improve short-term and medium-term health outcomes for local populations. If you would benefit from some additional care or support, your information will be shared back to the practice, or another local provider involved in your care, so that they can offer you direct care.

Further information about Population Health Management can be found here:

https://www.england.nhs.uk/integratedcare/what-is-integrated-care/phm/

Further information about the One Devon Dataset can be obtained by calling One Devon general enquiries on  01392 205205

We will rely on public interest task as the legal basis for processing your data for this purpose. You have a right to object to your information being used in this way. If you wish to opt out, please write to us c/o The Practice Manager.

Research

We work with the National Institute of Health Research (NIHR), and the South West Peninsula Clinical Research Network (CRNSW), to deliver research studies and trials. Employees of the practice will access your information in order to determine whether you are suitable to be invited to participate in a study. We will only share your information with the research providers with your explicit consent. Further information regarding the research providers can be found here: NIHR and CRNSW. Clinical Practice Research Datalink (CPRD)

This practice contributes to medical research and may send relevant data to CPRD. CPRD collects de-identified patient data from a network of GP practices across the UK. Primary care data is linked to a range of other health related data to provide a longitudinal, representative UK population health dataset. Further information regarding CPRD can be found here: https://cprd.com/transparency-information

How long do we hold your data?

We only hold your data for as long as necessary and are required to hold your data in line with the NHS Records Management Code of Practice for Health and Social Care 2021 Retention Schedule. Further information can be found online at: 

Records Management Code of Practice - NHS Transformation Directorate (nhsx.nhs.uk)

CCTV is held for 3 months

All telephone calls in and from the Practice are recorded. We retain these recordings for 12 months.

What rights do you have?

You have various rights under the UK GDPR and Data Protection Act 2018:

Right of access

You have the right to request access to view or request copies of the personal data, we hold about you; this is known as a Subject Access Request (SAR). In order to request access, you could write, email or verbally request access from the practice. Full details are also available on the Practice website.

Please note that you are entitled to a copy of your data that we hold free of charge; however, we are entitled to charge in certain circumstances where the law permits us to do so. We are also entitled to refuse a request, where the law permits us to do so. If we require a fee or are unable to comply with your request, we will notify you within 1 calendar month of your request. 

Right to restrict or object to the use of your information

There are certain circumstances in which you can object to your data being shared. Information regarding your rights to opt-out is detailed below:

Consent

If the practice is relying on consent as the basis for processing your data, you have the right to withdraw your consent at any time. Once you have withdrawn your consent, we may not be able to provide certain services to you. If this is the case, we will let you know.

Summary Care Record

The SCR improves care; however, if you do not want one, you have the right to object to sharing your data or to restrict access to specific elements of your records. This will mean that the information recorded by the practice will not be visible at any other care setting. If you wish to discuss your options regarding SCR, please speak to a member of staff at the practice. You can also reinstate your consent at any time by giving your permission to override your previous dissent.

National Screening Programmes

If you do not wish to receive an invitation to the screening programmes, you can opt out at Opting out of the NHS population screening programmes - GOV.UK (www.gov.uk)

Type 1 Opt-Out

You have the right to object to your confidential patient data being shared for purposes beyond your direct care by asking the practice to apply a Type 1 opt-out to your medical records. A Type 1 opt-out prevents personal data about you being extracted from your GP record and uploaded to any other organisations without your explicit consent. If you wish for a Type 1 opt-out to be applied to your record, please complete the form on our website.

National Data Opt-Out

You have the right to object to your data being shared under the national data opt-out model. The national data opt-out model provides an easy way for you to opt-out of sharing data that identifies you being used or shared for medical research purposes and quality checking and audit purposes.

To opt-out of your identifiable data being shared for medical research or to find out more about your opt-out choices, please ask a member of staff or go to NHS Digital’s website: 

https://digital.nhs.uk/services/national-data-opt-out-programme

Our organisation is compliant with the national data opt-out policy.

Cancer Registry

The National Cancer Registration and Analysis Service is run by Public Health England and is responsible for cancer registration in England to support cancer epidemiology, public health, service monitoring and research.

Further information regarding the registry and your right to opt-out can be found at: National Disease Registration Service (NDRS) - NHS Digital

Right to Rectification

You have the right to have any errors or mistakes corrected within your medical records. This applies to matters of fact, not opinion. If the information is of clinical nature, this will need to be reviewed and investigated by the practice. If you wish to have your records amended, please write to the Practice Manager.

If your personal information changes, such as your contact address or number, you should notify the practice immediately so that we can update the information on our system. We will also ask you from time to time to confirm the information we hold for you is correct.

Right to Erasure

The practice is not aware of any circumstances in which you will have the right to delete correct data from your medical record, which the practice is legally bound to retain. Although you are free to obtain legal advice if you believe there is no lawful purpose for which we hold the data and contact the practice if you hold a different view. 

Right to Complain

Please write to us if you wish to discuss how we have used your personal data, raise a concern, and make a complaint or compliment. 

You also have the right to complain to the Information Commissioner’s Office. If you wish to complain, follow this link: Contact us | ICO or call the helpline on 0303 123 1113.

Data outside EEA

We do not send personal data outside of the EEA. However if this is required, the practice would only do so with your explicit consent.

Data Protection Officer

The Data Protection Officer for the practice is Bex Lovewell, and she can be contacted via  d-icb.deltdpo@nhs.net or by post: Delt Shared Services Limited, BUILDING 2 – Delt, Derriford Business Park, Plymouth, PL6 5QZ.

Cookies

The practice’s website uses cookies. A cookie is a small file, typically of letters and numbers downloaded on to a device (like your computer or smartphone) when you access certain websites. Cookies allow a website to recognise a user’s device. Some cookies help websites to remember choices you make (eg which language you prefer if you use the Google Translate feature).

Analytical cookies are to help us measure the number of visitors to our website. The two types the practice uses are ‘session’ and ‘persistent’ cookies.

Some cookies are temporary and disappear when you close your web browser, while others may remain on your computer for a set period of time. We do not knowingly collect or intend to collect any personal information about you using cookies. We do not share your personal information with anyone.

What can I do to manage cookies on my devices?

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/

If you are concerned about cookies and would like to discuss this, please write to the Practice Manager.

Changes to privacy notice

The practice reviews this privacy notice regularly and may amend the notice from time to time. If you wish to discuss any elements of this privacy notice, please write to the Practice Manager