Subject Access Request
Please read this guidance to assist in your request
- We can only provide you with information we hold. This will mostly consist of data that has been entered into the GP record by WHMC or GP practices that you have previously been registered with (provided with have been sent these records).
- If you wish to obtain the reports or images for scans or investigations organised by hospital departments / clinics please make a separate Subject Access Request directly to the Hospital in question. Typically the only information sent to Practices after a hospital attendance is an outpatient clinic letter or discharge summary. These are typically also sent to or provided to the patient therefore we are unlikely to hold additional information relating to activity occurring outside of the Practice.
- If there is significant third party information held within your medical record we are legally required to redact this information.
- We are only able to provide information through the “Patient Access” if it is already currently part of your electronic medical record. If the record contains third party information it may not be possible to provide the record via Patient Records Access App like NHS App/Patient Access- in this situation a PDF of the redacted dataset will be sent via e-mail (even if the preference was for this information to be accessed through channel)
- We are required to not share information that can potentially cause harm to a patient or others.
- We are not able to retrospectively change or remove data already held within the medical record unless it is obviously incorrect (e.g. if it related to a different patient). Diagnoses are by definition an opinion. In cases where a diagnosis has changed or a patient disagrees with a diagnosis the Information Commissioner’s Office confirms that the “right to rectification” does not apply. The medical record has to be a contemporaneous record of opinion. Therefore if a diagnosis has changed we have to retain both the original diagnosis and the subsequent correction / change. When a patient disagrees with a recorded entry we can record (in the medical record) this disagreement however it is not possible to amend an entry unless (as above) it is clearly false.
- We will normally respond to a Subject Access Request within one calendar month or receipt. This period commences once we have received the SAR and have confirmed the identity and authority of the applicant.
- We may have to seek further information from the application to clarify details relating to the specific information requested. During this time the one calendar month response time period will be suspended until the required information is received.
- If the dataset requested includes data from before the start data of the electronic medical record (IE only exists in paper form) we will need to manually request for these records to be sent from our high security NHS approved and commissioned storage facility. These notes then have to be photocopied, manually redacted and photocopied/scanned before being sent out. Please allow additional time for these manual processes which may delay provision of the full dataset until after the usual response time period.
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