Privacy Notice

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information may be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare and help us to protect your safety.
We collect and hold data for providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we may collect information about you which helps us respond to your queries. We may keep your information in written form and/or in digital form.

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments.

Information we hold about you

The purpose of The Confederation Hillingdon CIC is to provide and assist our member GP practices to provide healthcare services in our Borough. We keep records about you, your health and the care we have provided or plan to provide to you. 
Most of the time we use information that does not identify individuals, such as statistical or anonymous data.

• However, there are some areas where we may use identifiable data such as: 
• Evaluation and review of services such as checking their quality and efficiency
• Paying your GP for the care they provide or being paid for the care we have delivered  
• Checking NHS accounts and services 
• Working out what illnesses people will have in the future, so we can prioritise NHS services 
• Making sure our services can meet patient needs in the future 
• Preparing statistics on NHS performance 
• Reviewing the care we provide to you, making sure it is of the highest standard. 

Sometimes we use data with your NHS number only; this is only done under the current legal permissions of Section 251 of NHS Act 2006. 

Examples are: 

• Monitoring how care is delivered to patients 
• Making sure services are working well and using resources properly 
• Redesigning and modernising services 
• Understanding particular health needs in different geographic areas 

Enabling only clinicians who are involved in a patient’s care to identify and contact patients:

• who would benefit from active case management 
• who are at risk of needing hospital care in the future
• Supporting care service planning and commissioning 

There are some functions where we use small amounts of confidential information, this may include your name, date of birth, address, summary of health details or outcomes of needs assessments. 

This information may be kept in written form and/or on a computer; in most of these instances you would have given us consent while we were carrying out those functions or it is information you send directly to us. 

Some of those functions include:  

• Assessments for continuing healthcare (a package of care for those with complex medical needs) assessments 
• Securing specialist services  
• Responding to your queries, concerns or complaints 
• Assessment and evaluation of safeguarding concerns 

Keeping your information confidential

The Confederation Hillingdon CIC is committed to protecting your privacy, we will only use information collected lawfully in accordance with the General Data Protection Regulation 2016 (“GDPR”) and undertake not to use any information we may hold about you for any purpose other than that for which it was collected, unless we have obtained your consent. 

In addition, all staff are subject to the Common Law Duty of Confidence. Under the NHS Confidentiality Code of Conduct all our staff are also required to protect your information, inform you of how your information will be used and allow you to decide if and how your information can be shared unless there is a legal exemption. 

We ensure that our partner agencies handle our information under strict conditions and in line with the law. All staff have contractual obligations of confidentiality, enforceable through disciplinary procedures. Staff with access to patient identifiable information have received appropriate on-going training to ensure they are aware of their responsibilities and staff are granted access to personal data on a need-to-know basis only. 

Data collected will not be sent to countries where the laws do not protect your privacy to the same extent as the law in the UK. We do not send any data outside the EU.

Sharing information

In order for The Confederation Hillingdon CIC to perform its functions mentioned above, information that we may hold is shared from various organisations which include general practices, acute and mental health hospitals, community services, walk in centres, nursing homes, directly from service users and many others. 

Information may also need to be shared for your benefit with other non-NHS organisations, from which you are also receiving care, such as social services and other providers from which we commission services. Where information sharing is required with third parties, we will not disclose any health information without your explicit consent unless: 

• You ask us to do so 
• A court order has been served on us 
• To assist the police in the prevention and detection of crime 
• To protect children and vulnerable adults 
• We have special permission for health and research purposes (granted by the Health Research Authority) 
• For the health and safety of others, for example to report an infectious disease such as meningitis or measles 
• The law requires it or to carry out a statutory function

Third Party Sites and Services 

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any App) that is available through this Site or to which this Site contains a link.  The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates.

Social Media and Sharing Tools 

On some pages of our website, we may also feature embedded 'Share' buttons or widgets that enable you to share content with friends through a few popular social networking sites (e.g. Twitter and Facebook etc).

These sites may set cookies which can identify you as an individual when you are also logged in to their services. This means they may be collecting information about what you are doing online, including on our Sites. We do not control these cookies and you should check the relevant third-party website to see how your information is used and how to opt out.

Security

We use reasonable organisational, technical and administrative measure to protect personal information under our control and in accordance with this privacy policy.

Unfortunately, secure transmission of information via the internet cannot be guaranteed due to security threats outside our control and you acknowledge that transmission over the internet is at your own risk.

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the ‘Contact Us’ section.

Safeguarding

To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.

Mobile telephone number

If you provide us with your mobile phone number, we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.

Communicating with you about your care

We will use your information to communicate with you about your care, including but not limited to confirming appointments and reminding you about your appointments. At times we may communicate with you via SMS Message; will assume your consent to do this but if you do not wish for us to communicate with you in this way then please let us know.

Right to be informed 

You have the right to be informed of how your data is being used. The propose of this document is to advise you of this right and how your data is being used by the practice

The right of access 

You have the right of access. You have the right to ask us for copies of your personal information- this right always applies. There are some exemptions, which means you may not always receive all the information we process.

The right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

The right to erasure

You have the right to ask us to erase your personal information in certain circumstances. This will not generally apply in the matter of health care data.

The right to restrict processing

You have the right to ask us to restrict the processing of your information in certain circumstances. You have the right to limit the way in which your data is processed if you are not happy with the way the data has been managed.

The right to object

You have the right to object to processing if you disagree with the way in which part of your data is processed you can object to this. Please bear in mind that this may affect the medical services we are able to offer you

Your right to withdraw consent 

You have the right at any time, to refuse/ withdraw consent to information sharing. The possible consequences will be fully explained to you and could include delays in receiving care.