Version 3.1

• Childrens Privacy Policy
• Data Protection Policy

Introduction

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you.
This privacy notice applies to personal information processed by or on behalf of the practice.

This Notice explains.

• Who we are, how we use your information and our Data Protection Officer
• What kinds of personal information about you do we process?
• What are the legal grounds for our processing of your personal information (including when we share it with others)?
• What should you do if your personal information changes?
• For how long your personal information is retained by us?
• What are your rights under data protection laws?

The UK General Data Protection Regulation (UK GDPR) became law on 24th May 2016. This is a regulation on the protection of confidential and sensitive information. It entered into force in the UK on the 25th May 2018, repealing the Data Protection Act (1998), being supplemented by the Data Protection Act 2018.

For the purpose of applicable data protection legislation (including but not limited to the UK General Data Protection Regulation (Regulation (UK) 2016/679) (the “UKGDPR”), and the Data Protection Act 2018 the practice responsible for your personal data is [Practice Name].

This Notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies to the personal data collected from members of the PPG.

What is the Patient Participation Group (PPG)?

Bedford Street Surgery & Furzton Medical centre have established a PPG to help us to gather views and experiences from people who use our services. The PPG aims to allow our service users to be actively engaged and involved in decision-making to help shape our services and culture, with the aim of supporting high-quality sustainable services.

How we use your information and the law.

Bedford Street will be what’s known as the ‘Controller’ of the personal data you provide to us.  Participation in the PPG is entirely voluntary. If you are interested in joining our PPG, you will need to email [E-mail Address] or speak to a member of staff.

If you have expressed an interest in attending our PPG, we will collect the following information about you:

• Name
• Contact number
• Email address
• Preferred contact method
• Age
• Ethnicity; and
• Area in which you live.

Your information will be used to

• Keep a register of current members
• Contact you with details of PPG meetings
• Progress any comments or suggestions; and
• Collect views and experiences from people from a range of equality groups.

You may be asked for your view and experiences in relation to;

• How the Practice can achieve its aims in providing best possible provision to its patients
• What developments in the community that may impact healthcare have occurred
• What other health services are doing and providing feedback to the Practice
• What patients and individuals who have not accessed our services think of the

Practice A standard PPG will be held every two months but we may hold additional PPGs for more bespoke topics. We will tell you whether the PPG will be held in person or via video conference. Where PPGs are held remotely, we will provide you instructions for joining ahead of the meeting.

Each PPG will usually have up to 12 participants in attendance plus relevant members of the Bedford Street Surgery Team. Your identity and any views or comments you express at the PPG will therefore be shared with the other attendees.

How do we lawfully use your data?

As a healthcare provider, we are regulated by the Care Quality Commission (CQC) and have established our PPG to support us to meet our CQC requirements. Specifically, the PPG assists us in responding to the CQC’s Key Lines of Enquiry relating to ‘well-led’ domain.
The output of the PPG will be used to help influence how we provide our healthcare services which we have been commissioned to provide under the NHS Act 2006 and the Health and Social Care Act 2012.

Article 6 (1) (e) – the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Article 9 (2) (h) -processing is necessary for…the provision of health or social care or treatment or the management of health or social care systems and services…”

Changing your mind

You can withdraw from the PPG at any time. We will remove your contact details from our PPG register, and you will not receive any further contact relating to our PPG.

If you wish to withdraw from the PPG, please email [e-mail address]
Your Direct Care will not be impacted in any way should you choose not to take part.

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• Data Protection Act 2018
• The UK General Data Protection Regulation 2016
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• NHS Codes of Confidentiality, Information Security and Records Management

We will only ever use or pass on information about you if others who have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e., life or death situations), where the law requires information to be passed on.

Our practice policy is to respect the privacy of our members and to maintain compliance with the UK General Data Protection Regulation (UK GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data will be protected.

All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement.

Where do we store your information Electronically?

All the personal data we process is processed in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.

No 3rd parties have access to your personal data unless the law allows them to do so, and appropriate safeguards have been put in place.  We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;

• NHS Commissioning Support Units
• Clinical Commissioning Groups
• NHS England (NHSE) and NHS Digital (NHSD)
• Local Authorities
• CQC
• Private Sector Providers providing employment services
• Other ‘data processors’ which you will be informed of

You will be informed who your data will be shared with and in some cases asked for consent for this happen when this is required.

We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.  All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for [Practice Name] an appropriate contract (art 24-28) will be established for the processing of your information.

How long will we store your information?

We are required under UK tax law to keep your information and data for the full retention periods as specified by NHS England, which currently is up to 6 years.

How can you access, amend move the personal data that you have given to us?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 1 Month (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller.

Access to your personal information

Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:

• Your request should be made in writing to the Practice
• There is no charge to have a copy of the information held about you
• We are required to respond to you within one month

What should you do if your personal information changes?

You should tell us so that we can update our records please contact the Practice Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up to date.

Objections / Complaints

Should you have any concerns about how your information is managed at the Surgery, please contact the GP Practice Manager or the Data Protection Officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.

Information Commissioner:
Wycliffe house
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 01625 545745
www.ico.org.uk/

If you are happy for your data to be extracted and used for the purposes described in this privacy notice, then you do not need to do anything.  If you have any concerns about how your data is shared, then please contact the Practice Data Protection Officer.

If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.
Data Protection Officer:

The Practice Data Protection Officer is Paul Couldrey of PCIG Consulting Limited. Any queries in regard to Data Protection issues should be addressed to him at: –

Email: Couldrey@me.com
Postal: PCIG Consulting Limited
7 Westacre Drive
Quarry Bank
Dudley
West Midlands
DY5 2EE

Changes

It is important to point out that we may amend this Privacy Notice from time to time.  If you are dissatisfied with any aspect of our Privacy Notice, please contact the Practice Data Protection Officer.