Privacy Notice and Policy

We have a legal duty to explain how we use any personal information we collect about you, as a registered patient, at the practice. Staff at Town Medical Centre maintain records about your health and the treatment you receive in electronic and paper format.    

What information do we collect about you?

We will collect information such as personal details, including name, address, next of kin, records of appointments, visits, telephone calls, your health records, treatment and medications, test results, X-rays, etc. and any other relevant information to enable us to deliver effective medical care.

How we will use your information

GP Data for Planning and Research Programme: GP data has a crucial role to play in research and planning which can improve public health, but it is important for patients and the public that this data is made available for appropriate purposes in a secure and trusted manner. This programme is a planned replacement for the GP Extraction Service (GPES) currently used to collect data for planning and research from general practices in England.

It is a legal obligation for the practice to comply with the Data Provision Notice ‘DPN’ for this programme as a result of a new direction from the secretary of state for health and social care as part of the Health and Care Act 2012. Once fully established, this new collection will replace multiple other data collections from general practices including the GPES in due course.

It is important to state that this new GPDPR programme is not a new processing of GP data in any way; what it does is to carry out an ongoing processing i.e. extraction of patients’ data by NHS Digital for planning and research purposes via a more efficient means. NHS Digital has set out that, whilst general practice will still retain data controllership over patient records within their practice, once data has been extracted from patient records and shared with NHS Digital, NHS Digital will be the responsible and accountable data controller under the UK GDPR for data access and dissemination for planning and research. Full details on the processing of patients’ data for this programme can be found in the NHS Digital’ privacy notice here.

Your data is collected for the purpose of providing direct patient care; however, we can disclose this information if it is required by law, if you give consent or if it is justified in the public interest. The practice may be requested to support research; however, we will always gain your consent before sharing your information with medical research databases such as the Clinical Practice Research Datalink and QResearch or others when the law allows.  

In order to comply with its legal obligations, this practice may send data to NHS Digital when directed by the Secretary of State for Health under the Health and Social Care Act 2012. Additionally, this practice contributes to national clinical audits and will send the data that is required by NHS Digital when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form; for example, the clinical code for diabetes or high blood pressure. 

NHS Digital has issued a Transparency Notice for this data collection. It is intended that General Practices should be able to link to the information included in the NHS Digital Transparency Notice to enable them to perform their legal duty in providing adequate fair processing information to their patients.

CVDprevent is a national primary care audit to support professionally led quality improvement in the prevention of cardiovascular events in people with and without pre-existing CVD through the detection and management of significant risk factors, including atrial fibrillation, high blood pressure, high cholesterol, diabetes, non-diabetic hyperglycaemia and chronic kidney disease (NHS RightCare CVD Prevention Pathway)

Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the GDPR. 

Maintaining confidentiality and accessing your records

We are committed to maintaining confidentiality and protecting the information we hold about you. We adhere to the General Data Protection Regulation (GDPR), the NHS Codes of Confidentiality and Security, as well as guidance issued by the Information Commissioner’s Office (ICO). You have a right to access the information we hold about you, and if you would like to access this information, you will need to complete a Subject Access Request (SAR). Please ask at reception for a SAR form and you will be given further information. Furthermore, should you identify any inaccuracies; you have a right to have the inaccurate data corrected.

Risk stratification

Risk stratification is a mechanism used to identify and subsequently manage those patients deemed as being at high risk of requiring urgent or emergency care. Usually this includes patients with long-term conditions, e.g. cancer. Your information is collected by a number of sources, including Town Medical Centre; this information is processed electronically and given a risk score which is relayed to your GP who can then decide on any necessary actions to ensure that you receive the most appropriate care.

Invoice validation

Your information may be shared if you have received treatment to determine which Kent & Medway Clinical Commissioning Group (CCG) is responsible for paying for your treatment. This information may include your name, address and treatment date. All of this information is held securely and confidentially; it will not be used for any other purpose or shared with any third parties.

Retention periods

In accordance with the NHS Codes of Practice for Records Management, your healthcare records will be retained for 10 years after death, or if a patient emigrates, for 10 years after the date of emigration.

What to do if you have any questions

Should you have any questions about our privacy policy or the information we hold about you, you can:

Contact the practice’s data controller via our secure online form. GP practices are data controllers for the data they hold about their patients

Write to the data controller at Town Medical Centre, 25a London Road, Sevenoaks, TN13 1AR

Ask to speak to the practice manager Katie Chambers

The Data Protection Officer (DPO) for Town Medical Centre is: Helen Foreman NHS Medway Clinical Commissioning Group, Unit A, Compass Centre North, Pembroke Road, Chatham Maritime, Kent, ME4 4YG. Tel: 03000 425100 Email: mccg.northkentgpdataprotection@nhs.net

Complaints

In the unlikely event that you are unhappy with any element of our data-processing methods, you have the right to lodge a complaint with the ICO. For further details, visit their website and select ‘Raising a concern’.