The Data Protection Regulations in the UK include two key pieces of law:
- The Data Protection Act 2018
- The UK GDPR which was adapted from the EU version at Brexit and now applies to processing for people based in the UK
There are other regulations in specific areas which need to be taken into account. This Privacy Notice has been written within the legislative framework as at July 2020. It will be revised as the framework and case law change.
What is this Privacy Notice about?
This Privacy Notice is part of the information to data subjects about how personal data is used. Being transparent and providing accessible information to individuals about how organisations will use their personal information is a key element of Data Protection Regulations.
This Privacy Notice is part of our programme to make the data processing activities we are carrying out in order to meet our healthcare obligations transparent.
The Privacy Notice tells you about information we collect and hold about you, the legal basis for collecting and holding the information, what we do with it, how we keep it secure (confidential), who we might share it with and what your rights are in relation to your information.
Who we are
[Insert comments about your organisation/Practice, for example, who you are, what you do and the services you provide]
Types of information we use
We use the following types of information/data:
- Personal data or sensitive personal/special categories of personal data such as:
- demographics – name, address, date of birth, postcode, NHS number
- racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, medical/health data, sexual life or sexual orientation data.
- Pseudonymised - about individuals but with identifying details (such as name or NHS number) replaced with a unique code.
- Anonymised - about individuals but with identifying details removed.
- Aggregated - anonymised information grouped together so that it doesn't identify individuals.
What we use your personal data and special categories of personal data (known as or sensitive personal) for
We use and share information about you in a number of ways. These include:
Primary uses - information from your GP medical record which can be made available to other NHS and public sector organisations, including doctors, nurses and care professionals in order to help them make the best informed decision, and provide you with the best possible direct care delivery.
Secondary uses - information from your GP medical record involves extracting identifiable data and (usually) sharing that data with other NHS organisations, for the purpose of indirect care. Examples include using your information for research, auditing, and healthcare planning (population health management).
A national opt-out for some secondary uses exists for your data – please see section 15 below.
Identity and Contact details of the Data Controller and Data Protection Officer
Practice Contact Details
[Insert Practice name, address and contact details]
Practice ICO Reference Number: [Insert your ICO Reference Number]
Data Protection Officer
You can contact the data protection officer by post at the practice address, addressed for the attention of the Data Protection Officer.
The Data Protection Officer service is provided across NCL practices by:
Name: Steve Durbin
Please quote the practice name in any communication.
Organisations we share your your personal information with
We share information about you with other GPs, NHS acute or mental health Trusts, local authorities, community health providers, pharmacists, commissioning organisations, medical research organisations and some specific non-NHS organisations for the purposes of direct and indirect care delivery of care.
We are required under the law to provide you with the following information how we process your personal data, the purpose of proposing, recipient/categories of your personal data, the identity of our Data Protection Officer (DPO), how long we retain personal information about you, the legal basis and justification for the processing, and your right to view, request access copies of your personal information, or object to the processing.
Included below is a table of the organisations we share information about you with split into the following categories. In all cases, the data controller and Data Protection Officer (DPO) are as listed in section 6 above:
a. Direct Medical Care and Administration
b. Other primary care services delivered for the purposes of direct care
c. Statutory Disclosures of Information
d. Processing for the Purposes of Commissioning, Planning, Research and Risk Stratification
e. Data Sharing Databases
f. Data Processors