The Caldicott Guardian for Swallowfield Medical Practice is:

Dr Debbie Milligan

The term Caldicott refers to a review commissioned by the chief medical officer. A review committee, under the chairmanship of Dame Fiona Caldicott, investigated ways in which patient information is used in the NHS. The review committee also made a number of recommendations aimed at improving the way the NHS handles and protects patient information.

These are summarised by seven information management principles.

• Justify the purpose(s) of using confidential information.
• Only use it when absolutely necessary.
• Use the minimum that is required.
• Access should be on a strict need to know basis.
• Everyone must understand his or her responsibilities.
• Understand and comply with the law.
• The duty to share can be as important as the duty to protect patient confidentiality.

The practice complies with data protection and access to medical records legislation. Identifiable information about you will be shared with others in the following circumstances:

• To provide further medical treatment for you e.g. from district nurses and hospital services.
• To help you get other services e.g. social care. This requires your consent.
• When we have a duty to others e.g. in child protection cases anonymised patient information will also be used at local and national level to help the Health Board and Government plan services e.g. for diabetic care.

If you do not wish anonymous information about you to be used in such a way, please let us know.

Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.

Freedom of information

Information about the general practitioners and the practice required for disclosure under this act can be made available to the public. All requests for such information should be made to the practice manager.

Access to records

In accordance with the Data Protection Act 2018 and Access to Health Records Act, patients may request to see their medical records. To request access please complete and submit our online form this service will be subject to an access charge. No information will be released without the patient consent unless we are legally obliged to do so.

The average pay for GPs working in the Swallowfield Medical Practice in the last financial year was £54,081 before tax and national insurance. This is for three full time GPs, four part time GPs and no locum GP who worked in the practice for more than six months.

It should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time doctors spend working in the practice, and should not be used to form any judgement about GP earnings, nor to make any comparison with any other practice.

This annual statement will summarise:

• Any infection transmission incidents and any action taken (these will have been reported in accordance with our significant events procedure)
• Details of any infection control audits undertaken and any actions arising
• Details of staff training
• Any review and update of policies, procedures and guidelines

Background

Swallowfield Medical Practice leads for infection control are Dr Lucy Dugmore and Sister Julia Bourne.

Significant events

There have been no significant incidents in 2016.

Audits

An infection control audit was undertaken in May 2016 by Michaela Hooper, Sister Julia Bourne and Sister Anne Pragnell.

Actions

• Remove pillowcases on pillows and replace with wipeable option
• Replace taps in dispensary and kitchen area
• Replace patient chairs with wipeable material, included in ongoing business plan
• Wall mounted hand gel/soap dispensers to be provided in dispensary
• Recover/replace footstool from treatment room 1

Training

All new staff will receive infection control training as part of their induction programme

Policies and procedures

Policies are reviewed annually but will be amended on an on-going basis as current advice changes or the need arises.

Your local health and care services are working more closely together to provide a joined-up service to meet your needs.

Working together improves the quality of care because the clinicians and other professionals involved in your treatment and care provision have better, more timely and more complete information on which to base their decisions.

The local shared care record reduces the need for you to repeat your story in each different setting, thereby saving you time and frustration. It also makes the services themselves more efficient by enabling health and care professionals involved in your care to view the relevant records as and when appropriate.

The Health and Social Care Act 2012 places a legal requirement on health and social care organisations to share data with other health and social care organisations involved in your care or likely to be involved in your care.

There are also occasions where we have a legal duty to pass patient information to external organisations such as NHS Digital and NHS England that either provide national shared care records such as the NHS summary care record or that have a responsibility to oversee and address issues relating to the management of the NHS as a whole.

In addition, your data is also used in an anonymised form to manage the quality of the services you receive and to help monitor, manage and improve the provision of health and social care nationally and locally.

Together, the UK Data Protection Act 2018, the General Data Protection Regulation and our Common Law duties set out the rules we need to comply with when processing and sharing your data and we and our local partners have policies and procedures in place to ensure we comply.

As an example, one such policy is a requirement for staff to be trained and tested regularly with respect to data protection and privacy.

The local shared care record

Local shared care records are used by the practice to share some key information from your records with other organisations and health and social care professionals who may be involved in your care.

Role based access controls are implemented within the local shared care record systems and these controls make certain that only those roles that have a legitimate reason to access your data can do so. In addition to the technical access controls, all organisations that have been granted access to the local shared care records have committed to perform regular audits to ensure that the controls are properly applied.

The various types of organisation that may be required to view relevant aspects of your data using the local shared care record include:

• NHS Trusts, including
  • Hospitals
  • Community healthcare services (when you have been referred to them)
  • Emergency services
  • Mental health services (when you have been referred to them)
  • Specialist service providers (when you have been referred to them)
• Local authorities
• Voluntary sector organisations (when you have agreed to be referred to them)
• Independent sector health care providers (when you have been referred to them)
• Independent sector social care providers (when you have been referred to them)

Practices contribute the following types of data to the local shared care record:

• Personal demographic details (e.g. address, date of birth, next of kin/emergency contact details, ethnicity, disability or language preferences)
• Allergies
• Events and episodes of care
• Health promotion information
• Medication data (current and past)
• Preventative procedures
• Problems
• Procedures
• Referrals
• Relevant social and family history
• Results from diagnostic procedures
• Test results

Other health and social care organisations contribute the following types of data to your local shared care record:

• Alerts, allergies, risks and warnings
• Admissions and discharges
• Ambulance, NHS 111 and Out of Hours calls
• Care plans
• Carer details
• Diagnostic tests, imaging, results and reports
• Electronic documents and letters
• Next of kin
• Referrals, appointments and consultations

There are three main local care records that are made available to support your care across the local health and social economy. These are:

• Share Your Care (which is also known as Connected Care) and for some patients a similar arrangement known as CHIE (formerly the Hampshire Health Record). This local shared care record consolidates your important local data from all sources for access by authorised professionals when you need it;
• The GP clinical system used in practices and other non-hospital settings that can provide near real-time access to your GP data when you are being cared for elsewhere in the local health care economy; and
• The local pathology and diagnostic system that can provide details of your tests and diagnostic reports to authorised professionals elsewhere in the local health care economy when you need it.

Your rights

Your rights in respect of these local shared records are summarised below:

• As required by law, you have a right to request a copy of your local shared care record
• You also have a right to request that errors in your records are corrected
• For some uses of your data, you also have the right to object to your data being processed

We aim to comply with these rights at all times.

For queries and requests regarding GP clinical system shared records, please contact the practice.

For queries and requests regarding Share Your Care and local pathology and diagnostic shared records, contact fhft.information.governance@nhs.net.

For more information on anonymised data processing please see the NHS: Your Data Matters.

The data is being processed for the purpose of delivery of a programme, sponsored by NHS Digital, to monitor urine for indications of chronic kidney disease (CKD) which is recommended to be undertaken annually for patients at risk of chronic kidney disease e.g., patients living with diabetes. The programme enables patients to test their kidney function from home.

We will share your contact details with Healthy.io to enable them to contact you and send you a test kit. This will help identify patients at risk of kidney disease and help us agree any early interventions that can be put in place for the benefit of your care. Healthy.io will only use your data for the purposes of delivering their service to you.

If you do not wish to receive a home test kit from Healthy.io we will continue to manage your care within the Practice. Healthy.io are required to hold data we send them in line with retention periods outlined in the Records Management code of Practice for Health and Social Care.

Further information about this is available at: www.lp.healthy.io/minuteful_info.

For patients aged 75 and over, the named accountable GP is responsible for:

• Working with health and social care professionals to deliver a care package that meets the needs of the patient
• Ensuring that these patients have access to a health check

Patients can still choose to see any GP in the surgery. We will make reasonable efforts to accommodate their preference.

If you have a preference or want to know who your named GP is, you can contact us for more information.

As with all NHS care, once a patient is referred to a hospital or other healthcare provider, the responsibility for care for that episode passes to the chosen provider and they remain responsible for all service aspects, procedures and follow-ups until final discharge back to your GP. The same too applies to private providers.

All pre-treatment connected with your private care is the responsibility of the provider you have chosen, for example:

• All pre-operative checks
• Assessments
• Pathology (including all blood, biopsies and other tests)
• All physiological checks such as BPs, ECG etc. (related to any assessment or procedure triggered by the private referral).
• All diagnostic imaging (X-ray, ultrasound, CT and MRI)

You cannot elect to have some parts of these undertaken by the NHS and others by your private provider. Your provider must arrange these privately as part of your care package so it is important to make sure you have budgeted for them or that your personal medical insurance policy covers these costs. This is to ensure your safe, continuity of care for which they have become responsible.

All post-operative care for the episode is the responsibility of the health provider you have chosen. For example:

• You may need a prescription for medication during a period of post-operative recovery or as part of a longer term medication regime. It is your responsibility to obtain private prescriptions from the consultant in charge of your care. You may also be responsible for paying the drug costs even though you hold an exemption based upon medical or age grounds, particularly for those drugs not routinely available in the NHS. For safety and legal reasons, our GPs cannot simply issue repeat prescriptions for drugs initiated by another doctor.
• All suture removals, dressings and post-operative care checks need to be undertaken by your private provider.
• All post procedure reviews must be undertaken by the provider as they know exactly what procedure was performed, any difficulties or complications that occurred during surgery, and what post-operative complications might be expected, if any.

Any complaints relating to your care or the level of service you have received from a private provider, needs to be directed to them. We cannot become involved in dealing with third party complaints. Your provider should have their own complaints policy which should be readily available to you.

You are entitled to return to the NHS for treatment following the completion of an episode of private care; all you need to do is tell your GP who will make arrangements for any necessary onward NHS referrals.

We hope this guidance will help clarify some of the more common questions asked by patients when making a decision about choosing private care.

The collection of GP Data for Planning and Research in England has been deferred from 1 July to 1 September 2021. More information about how your data is being used by NHS Digital and how to opt out is available below:

• General Practice Data for Planning and Research (GPDPR) – NHS Digital

We hope you find this information useful and that you will choose not to opt out of sharing your data.

Your information, what you need to know

If you want to speak to us about your data, please see our contact us page. This notice describes why we collect information about you, how your information will be used and your rights in respect of your data.

Why we collect information about you

Your records are used to ensure you get the best possible care. Your information helps them to make the best decisions about your care and helps provide you with proactive advice and guidance. Important information is also collected to help us to remind you about specific treatment which you might need, such as health checks, immunisations for children and reminders for screening appointments. We work with other NHS services to co-ordinate these. Information held about you may be used to help protect the health of the public and to help us to improve NHS services. Information may be used within the GP practice to monitor the quality of the service provided (known as ‘clinical audit’).

What data do we collect and receive about you?

Records are stored electronically and on paper and include personal details about you such as your address, carers, legal representatives, emergency contact details, as well as:

• Any appointments, visits, emergency appointments
• Notes and reports about your health
• Details about your diagnosis, treatment and care
• Details about any medication you are taking
• Results of investigations such as laboratory tests, x-rays
• Relevant information from health  and care professionals, relatives or carers

We also receive information from other organisations that are caring for you that we hold in your record. This will include letters and test results.

How we use your information: For providing your care

Prescriptions

Where you have agreed we will send information on your prescriptions to pharmacies, either by electronic systems or by paper.

Test requests and results

Where we undertake tests on you, such as blood tests, we will send the sample and details of the tests we are requesting to the most appropriate pathology laboratory. The data shared with the laboratory will include your NHS number, name, the type of test requested and any health information relevant to doing the test and producing the result or report. We will receive the test results back from the laboratory electronically and these will be stored in your patient record.

Extended services and out of hours

We work closely with neighbouring practices and ‘out of hours’ providers including NHS 111 to ensure that if you need care from a doctor outside of normal hours that they have access to your records when needed to give you the best possible care. This may be delivered over the phone or via video consultation as appropriate. Services may be run by ‘GP Federations’ and ‘Primary Care Networks’.

Patient referrals

With your agreement, your GP or nurse may refer you to other services not provided by the practice, or they may work with other services to provide your care in the practice. Information will be shared by letters, emails and shared record systems. Once you have been seen, the other care agency will tell us about the treatment they have provided for you and any support which your GP needs to provide. This information is then included in your record. Referrals can be to lots of different services, such as smoking cessation services, social prescribers, voluntary services and other health and care agencies, as appropriate, for your care.

Hospital, community or social care services

Sometimes the staff caring for you need to share some of your information with others who are also supporting you. This could include hospital or community based specialists, nurses, health visitors, therapists or social care services. Information will be shared to organisations where you receive care, whether that is local or further away, if you need specialist care or emergency care in another.

Shared computer systems

Health and Social care services are developing shared systems to share data efficiently and quickly. It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during 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 is also quicker for staff to access a shared record than to try to contact other staff by phone or email. Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job. Systems do not share all your data, just data which services have agreed is necessary to include. For more information about shared care records, please see the local shared care record statement.

Safeguarding of children or vulnerable adults

If we have significant concerns or hear about an individual child or vulnerable adult being at risk of harm, we may share relevant information with other organisations, such as local authorities and the Police, involved in ensuring their safety.

Ensuring medicines work well

We work with the local medicines management team of the ICB to help get the best out of medicines for patients and ensure they are effective in managing conditions. This generally uses anonymous data, but occasionally they will assist in reviews of medication for patients with complex needs. Doctors may also seek advice and guidance on prescribing queries.

Identifying health risks

Systems known as ‘risk stratification tools’ are used to help determine a person’s risk of suffering particular conditions and enable us to focus on preventing ill health before it develops. Information in these systems comes from a number of sources, such as hospitals and the practice. This can help us identify and offer you additional services to improve your health.

Multi-disciplinary team meetings

For some long term conditions, such as diabetes, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions.

National services (including screening programmes)

There are some national services like national diabetes audit and the national cancer screening programmes that collect and keep information from across the NHS. This is how the NHS knows when to contact you about services like cervical, breast or bowel cancer screening. You can find out more about how the NHS holds and shares your information for national programmes on the NHS screening website. Data may also be shared on anyone who contracts a ‘communicable disease’, such as Covid-19, in order to manage public health and safety.

How we use your information: beyond providing your care

The information collected about you when you use our services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• Improving the quality and standards of care
• Research into the development of new treatments
• Preventing illness and diseases
• Monitoring safety
• Planning new services
• Public health screening
• Assisting the Care Quality Commission with any investigations
• Investigating fraud

Wherever possible data used for these purposes is anonymised so that you cannot be identified. If information cannot be completely anonymous, then this may only take place when the law allows the information to be used. All these uses help to provide better health and care for you, your family and future generations.

This practice is supporting vital health and care planning and research by sharing your data with NHS Digital. For more information about this see the GP Practice Privacy Notice for General Practice Data for Planning and Research.

OpenSAFELY Data Analytics Service

NHS England has been directed by the government to establish and operate the OpenSAFELY COVID-19 Service and the OpenSAFELY Data Analytics Service. These services provide a secure environment that supports research, clinical audit, service evaluation and health surveillance for COVID-19 and other purposes.

Each GP practice remains the controller of its own GP patient data but is required to let approved users run queries on pseudonymised patient data. This means identifiers are removed and replaced with a pseudonym.

Only approved users are allowed to run these queries, and they will not be able to access information that directly or indirectly identifies individuals.

Patients who do not wish for their data to be used as part of this process can register a type 1 opt out with their GP.

Here you can find additional information about OpenSAFELY.

Statutory disclosures

Sometimes we are duty bound by laws to disclose information to organisations such as the Care Quality Commission, the Driver and Vehicle Licencing Agency, the General Medical Council, Her Majesty’s Revenue and Customs and Counter Fraud services. In these circumstances we will always try to inform you before we are required to disclose and we only disclose the minimum information that the law requires us to do so.

• What else might information be used for?

Objecting to the of use of data for purposes beyond your care

The NHS constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’. For further information please visit: The NHS Constitution

National data opt-out

The national data opt-out enables patients to opt-out from the use of their personal confidential data for research or planning purposes. To find out more or to register to opt out, please visit the NHS website: Your data matters. If you have any concerns about use of your data not covered by the National Data opt out, please contact the practice.

How long do we hold information for?

Records are kept for the lifetime of the patient. If you move to a new practice, your record will be transferred. If the practice you have left need to access your record, for example to deal with a historic complaint, they will let you know. When information has been identified for destruction or deletion it will be disposed of using approved confidential disposal procedures.

Your rights:

Data Protection laws give you a number of rights, including access to your data, correction, erasure, objection and restriction of use of your data. Details on how to request access to your data are set out below. If you have any concerns about the accuracy and use of your records, please contact us.

Right of access to your information (Subject access request)

You have the right to have a copy of the information we hold about you. There are some safeguards regarding what you will have access to and you may find information has been removed for the following reasons.

• Where your doctor has decided that some information may cause significant harm to you or someone else
• Where the information is about someone else (third party) and is confidential to them

You can make a request by asking or writing to the practice. We may ask you to complete a form so that we have a record of your request. You will need to provide proof of identity. If you would like to access your GP record online, please visit Patient Access.

Lawful basis for processing

The use of personal data for providing care is supported under the following Article 6 and 9 conditions of the GDPR:

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”

Change of details

It is important that you tell us as soon as you can if any of your details such as your name or address, email address or mobile number have changed. This is to make sure no information about you is sent to an old address.

Mobile telephone number

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

Email address

Where you have provided us with your email address we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email, please let us know. Any changes to this notice will be published on our website and in a prominent area at the practice.

Data Protection Officer

Should you have any questions or concerns about your data, please contact our Data Protection Officer via the details on our contact us page.

Right to complain

If you have concerns or are unhappy about any of our services, please contact the practice manager.

For independent advice about data protection, privacy and data-sharing issues, you can contact:

The Information Commissioner Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Website
Contact us | ICO

Phone
0303 123 1113

• To provide high quality, safe, professional primary health care services to our patients
• To be a learning organisation that continually improves what we are able to offer patients
• To focus on prevention of disease by promoting health and wellbeing, and by offering care and advice to our patients
• To work in partnership with our patients, their families and carers towards a positive experience and understanding, involving them in decision making about their treatment and care
• To treat patients as individuals and with the same respect we would want for ourselves or members of our families, listening and supporting people to express their needs and wants and enabling people to maintain the maximum possible level of independence, choice and control
• To work in partnership with other agencies to tackle the causes of ill health as well as to provide the treatment for ill health and, where appropriate, involve other professionals in the care of our patients
• To encourage our patients to communicate with us by joining our Patient Participation Group and/or our Patient Reference Group, talking to us, participating in surveys and feeding back on the services that we offer
• To ensure all staff have the competency and motivation to deliver the required standards of care ensuring that all members of the team have the right skills and training to carry out their duties
• To take care of our staff offering support to do their jobs and to protect them against abuse – we have a zero tolerance of all forms of abuse
• To provide our patients and staff with an environment which is safe and friendly
• To act with integrity and confidentiality
• To operate on a financially sound basis