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Privacy Notice

Kirkbymoorside Practice

Fair Processing Notice (Privacy Notice)

 

Protecting your confidentiality

 

This Privacy Notice explains why we collect information about you, how that information may be used and how we keep it safe and confidential.

 

Why we collect information about you

 

Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the pending Data Protection Act 2018 and its predecessor, the Data Protection Act 1998 (“DPA”) and is reflected throughout the EU General Data Protection Regulations 2018 (“GDPR”).

 

Healthcare professionals who provide your care are required by law to maintain records about your health and any treatment or care you have received within any NHS organisation.

 

We collect and hold data for the sole purpose of providing healthcare services to our patients.

Details we collect about you

Healthcare professionals who provide care to you maintain records about your health and any treatment or care you have received previously (eg. at local NHS Trusts, GP Surgery, Walk-in clinic, etc.). These records help to ensure that you receive the best possible healthcare.

 

All personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to your care.

 

We collect the following types of information from you or about you from third party (provider organisations) involved in the delivery of your care:

 

  • ‘Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data. This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS Number; and
  • ‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.

Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services).

How we keep your information confidential and safe

 

Everyone who works within the NHS is subject to a Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes discussed and with consent given by you unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information applies to all members of our staff and they are required to protect your information, inform you of how your information will be used and allow you to decide if and how your information can be shared. Each of our staff members is expected to ensure information is kept confidential and to complete relevant and regular training.

 

NHS health records may be electronic, paper-based or a mixture of both and we use a combination of working practices and technology to ensure that your information remains confidential and secure. Your records are backed up securely according to NHS standard procedures. We ensure that the information we hold about you is kept in secure locations, is protected by appropriate security and that access is restricted to authorised personnel. GP

We ensure that any external data processors that support our electronic systems are legally and contractually bound to operate and prove that security arrangements have been implemented where data that could or does identify a person are processed.

 

Your information will be collected either electronically using secure NHS mail or by secure electronic mail transferred over an NHS encrypted network connection. In addition, physical information will be sent to your practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.

 

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

 

  • The Data Protection Act 2018 (pending)
  • The General Data Protection Regulation 2018
  • The Human Rights Act 1998
  • The Common Law Duty of Confidentiality
  • NHS Codes of Confidentiality and Information Security
  • The Health and Social Care (Safety and Quality) Act 2015

 

All members of staff working within the NHS have a legal obligation to keep information about you confidential. We will continue to maintain our duty of confidentiality to you at all times. We will only ever use, share or pass on information about you to organisations and individuals that have a legitimate and specific legal basis for access to your information.

 

We will not disclose your information to any third party (e.g. Insurance Companies/Solicitors) without your permission unless there are exceptional circumstances (i.e. life or death situations) or where the law requires information to be passed on and/or in accordance with revised information sharing principles adopted following Dame Fiona Caldicott’s review (Information to share or not to share) which states that “The duty to share information can be as important as the duty to protect patient confidentiality”.

 

Dr Rachel Hodgson, our Information Governance lead, is our partner responsible for protecting the confidentiality of patient information. She is our Practice Caldicott Guardian and has been appointed as our Data Protection Officer (“DPO”) for the purposes of GDPR and DPA 2018.

 

How we use your information

 

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent. Developments in information technology have also enabled us to share data electronically with other healthcare providers with the objective of providing you with better, more efficient and less fragmented healthcare.

GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used. Where consent is used properly, it aims to build trust and enhance an organisation’s reputation.

However, consent is only one potential lawful basis for processing information for the purposes of GDPR. Your GP practice may not be required to seek your explicit consent for every instance of processing and sharing of your information, in so far as such processing is carried out in accordance with this notice and the specified legal basis outlined.

Your GP Practice will contact you if they are required to share your information for any purpose not contained within this notice. Your consent for such sharing will be explicitly sought and documented within your electronic patient record for the avoidance of doubt.

A full list of details of any Data Processor involvement involoving organisations other than those outlined in the “Sharing of Electronic Patient Records within the NHS” section below, the purposes for processing information and the legal basis for such processing under the terms of GDPR, can be found in Appendix A.

 

 

 

The areas where we regularly use your personal confidential information include:

  • your direct care needs
  • responding to your queries, compliments or concerns
  • where there is a specific provision permitting the use of confidential personal information under specified conditions, for example “Risk Stratification” (see below)

Sharing of Electronic Patient Records within the NHS

Electronic patient records are kept in most healthcare settings where you receive care. We share your information, subject to strict agreements on how it will be used, with the organisations listed below. Our local electronic systems (such as SystmOne, EMIS and Hospital CPD) enable your record to be shared with these organisations involved in your direct care:

  • GP practices
  • Community services including Community/District Nurses, Physiotherapy, Midwives, Respiratory Nurse Specialists, Heart Failure Nurse Specialists, Community Palliative Nurse Specialists, Tissue Viability Nurse Specialists, Diabetes Community and Outreach Specialist services (including Community Diabetes Service and Diabetes Specialist Outreach Team), Children’s Service (Health Visiting), Healthy Child Service, Podiatry, Rehabilitation services, Community Therapy Teams (including Occupational Therapists and Physiotherapy), Community Addiction Services (Horizons), Community Response Team, Integrated Care Hub (service provided by Nimbus), telehealth and out of hospital services.
  • Child health services that undertake routine treatment or health screening
  • Urgent care organisations, minor injury units or out of hours services
  • Community hospitals
  • Palliative care hospitals/hospices
  • Care Homes
  • Mental Health TrustsNHS Commissioning Support UnitsPrivate Sector ProvidersAmbulance TrustsSocial Care ServicesLocal AuthoritiesFire and Rescue ServicesAny other ‘Data Processors’ of which you will be informed
  • Police & Judicial Services
  • Education Services
  • National Diabetes Prevention Programme
  • Health and Social Care Information Centre (HSCIC)
  • Voluntary Sector Providers
  • Independent Contractors such as dentists, opticians, pharmacists
  • Hospitals (NHS Trusts / Foundation Trusts/ Specialist Trusts)

 

We will never share your information outside such health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function.

 

In addition, NHS England uses a national electronic record called the Summary Care Record (“SCR”) to support patient care. It contains key information from your GP record.

 

Your SCR provides authorised healthcare staff with secure and timely access to essential information about you in emergencies or during episodes of unplanned care, where such information would otherwise be unavailable or when patients may not be able to provide a full account of their care.

 

SCRs are designed to improve the speed, safety, continuity and quality of your care. SCR core information includes information about your allergies, adverse reactions and medications. An SCR with additional information can also include specific reasons for medication, your vaccination history, significant diagnoses/problems, past procedures, any anticipatory care information and relevant end of life care information.

 

Additional information can only be added to your SCR with your agreement.

Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery in an emergency may not be aware of your current medications, your allergies or any significant past adverse reactions to medication. Any limit to the access to information included in SCR may compromise the safety of your care.

 

Should you choose to opt out of SCR, your records would remain unchanged from their current form. Any information about your medical history relevant to the provision of care during an emergency or for out of surgery care would be shared during practice opening hours by letter, email, fax or phone.

 

If you wish to opt-out of having an SCR please request an opt-out form to be returned to the practice and your decision will also be recorded in your electronic record.

You can also reinstate your consent at any time by giving your permission to override your previous dissent.

 

What will happen if I withhold my consent or raise an objection?

You may choose to withdraw your consent to personal data being used in this way. If we intend to participate in a new data-sharing project we will make patients aware of this by displaying prominent notices in the Practice and on our website for a reasonable period before the scheme is due to start.

 

In such cases, we will provide information about how to ‘opt-out’ of each new scheme.

 

You can always object to your personal information being shared with other health care providers but, should this decision potentially compromise the treatment that you would otherwise receive, your doctor will explain this risk to you at the time.

 

Your records are used to facilitate the best possible care for you. Information held about you may be used to help protect the health of the public and to help us manage the NHS.

 

Clinical Audit

 

Information may be used for clinical audit to monitor the quality of services and care provided to you. Some of this information may be held centrally and used for statistical purposes. If your information is used in such a clinical audit, strict measures are taken to prevent individual patients information from being identifiable (e.g. the National Diabetes Audit).

 

Clinical Research

Your explicit consent will always be sought before any information is released for the purpose clinical research.

 

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

 

Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority pursuant to Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the terms of the DPA.

 

Data matching by the Cabinet Office is subject to a specific Code of Practice.

Information on the Cabinet Office’s legal powers and reasons why it matches particular information can be found at the following link:

 

https://www.gov.uk/government/publications/code-of-data-matching-practice-for-nationalfraud-initiative

 

Risk Stratification

 

Risk Stratification is a process for identifying and managing patients most likely to need hospital or other healthcare services. The risk stratification tools used in the NHS help to determine the individual risk of suffering from a particular condition and enable us to focus on the prevention of disease rather than focusing solely on the treatment of ill health. Information about you is collected from a number of sources including NHS Trusts and from this GP Practice.

Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information is available at the following link:

https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification/

 

If you do not wish information about you to be included in the risk stratification programme, please contact our Practice Administrator, Mrs Nicola Ward, and your record will be amended to prevent your information from being used for this purpose. However, you should be aware that this could have a negative impact on the timely and proactive provision of your direct care.

 

Individual Funding Requests

 

An ‘Individual Funding Request’ is a request made, on your behalf, with your consent, by a clinician, for the funding of specialised healthcare which falls outside the range of services and treatments that the Clinical Commissioning Group (the ”CCG”) has agreed to commission for the local population.

 

An Individual Funding Request is considered when a patient’s clinician submits a written argument outlining exceptional clinical circumstances that may make a particular patient’s case different from other patients with the same condition at the same stage of their disease or for a treatment that is regarded as new or experimental where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.

 

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to check which CCG is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

 

Supporting Medicines Management

 

CCGs support local GP practices with prescribing queries that generally do not require identifiable information. CCG pharmacists work with your practice to provide advice on medication and prescribing queries and review prescribing to ensure that it is safe, up-to-date and cost-effective.

 

Safeguarding

To ensure that adult and children’s safeguarding matters are managed appropriately access to identifiable information will be shared in some limited circumstances if legally required for the safety of the individuals concerned.

 

Data Retention

 

Our policy for management of patient records is aligned with the Records Management NHS Code of Practice for Health and Social Care which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.

 

As stated above, our guiding principle is that we are holding your records in strictest confidence.

 

How long do we hold your information for?

 

All records held by the Practice will be kept for the duration specified by national guidance from the Information Governance Alliance which can be found at the following link:

http://systems.digital.nhs.uk/infogov/iga/rmcop16718.pdf.

 

Right to withdraw consent for us to share your personal information

(Opt-Out)

 

In respect of the health partner organisations (NHS, Foundation and Specialist Trusts) and in relation to the headings above (Risk Stratification, Invoice Validation, Supporting Medicines Management and Summary Care Record), we will assume that you agree that your information can be shared unless you explicitly choose to complete an opt-out.

 

We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases that may endanger the safety of others, and where a formal court order has been issued.

 

As stated above, our guiding principle is that we are holding your records in strictest confidence.

If you are happy for your data to be extracted and used for the purposes described in this Fair Processing/Privacy Notice then you do not need to do anything. If you do not want your information to be used for any purpose beyond providing your care, you can choose to opt out.

 

If you wish to opt out, please contact one of our Patient Support Team at the surgery and we will amend your record to reflect this. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.

 

Under the previous legislative framework, there were two main types of opt-out, as follows:

 

Type 1 Opt-Out

 

If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease.

 

Type 1 Opt-Outs will remain unchanged by GDPR until 2020 when a consultation between the Department of Health and Social care and the National Data Guardian is planned.

 

Type 2 Opt-Out

 

NHS Digital collects information from a range of places where people receive care, such as hospitals and community services.

 

Before the implementation of GDPR on 25 May 2018, a Type 2 opt-out provided that if you did not want your personal confidential information to be shared by NHS Digital for purposes other than your direct care, you were able to register a ‘Type 2 Opt-Out’. For further information about Type 2 Opt-Outs, please contact NHS Digital contact centre at enquiries@hscic.gov.uk referencing ‘Type 2 Opt-Outs – Data Requests’ in the subject line; or call NHS Digital on (0300) 303 5678; or visit the website http://content.digital.nhs.uk/article/7092/Information-on-type-2-opt-outs.

 

National Data Opt-Out

 

Patients who registered such a Type 2 Opt-Out under previous legislation should be aware that these will be replaced by the National Data Opt-Out provisions and patients affected by the change will receive a letter explaining the new model following the implementation of the new legislation.

 

The letter will explain that the new National data opt-out is an automatic conversion of the previous Type 2 Opt-Out and that patients who wish to continue the right under the previous model do not need to do anything further.

 

For any queries about this, affected patients should contact the national call centre advice line included in the letter rather than the Practice. However, if you wish to discuss or change your opt-out preferences at any time please contact our on-site administrative Team Leader, Mrs Nicola Ward.

 

Access to your information

Under the new General Data Protection Regulation (GDPR) 2018, you have the right to see or have a copy of data held by us that could identify you with some limited exceptions. You do not need to give a reason to see such data. This is known as the “right of subject access”.

If you wish to access to or a copy of the information that we hold about you, please make a Subject Access Request in writing to our Practice Administrator, Mrs Nicola Ward. You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party.

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details are incorrect in order for this to be amended. Please inform us of any changes in a timely fashion to enable us to keep your records accurate and up-to-date.

 

Mobile Numbers & Email Addresses

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

 

If you provide us with your email address, we may use this to send you reminders to make an appointment for a review. Please let us know if you do not wish to receive correspondence by email.

 

Should you wish to take advantage of these services, please discuss with a member of our staff to ensure that we have the relevant contact details for you.

 

Notification

 

Kirkbymoorside Surgery is registered with the Information Commissioners Office (ICO) to describe the purposes for which they process personal and sensitive information.

Kirkbymoorside Surgery is a registered Data Controller and our registration can be viewed online in the public register at:

 

http://ico.org.uk/what_we_cover/register_of_data_controllers .

 

Complaints

We try to meet the highest standards when collecting and using any personal information. We take any complaints we receive about this very seriously. Should you have any concerns that the way in which we collect or use information is unfair, misleading or inappropriate, please contact our Practice Administrator, Mrs Nicola Ward.

 

Information Commissioners Office

 

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

 

The Information Commissioners Office,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire,

SK9 5AF

Phone: 0303 123 1113/01625 545 745

Website: www.ico.gov.uk .

 

Further Information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found here:

 

https://www.england.nhs.uk/contact-us/privacy/privacy-notice/your-information/

 

 

 

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under the DPA.

 

http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf

 

The NHS Constitution

 

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights to which patients, the public and staff are entitled. These rights cover how patients may access health services, the quality of care they should expect to receive, the treatments and programmes available to them, confidentiality and the right to complain if things do not meet patients’ expectations.

https://www.gov.uk/government/publications/the-nhs-constitution-for-england

 

NHS Digital

To promote better health and/or support improvements in the delivery of care services in England, NHS Digital collects health information from the records that health and social care providers maintain regarding the care and treatment they give.

http://content.digital.nhs.uk/article/4963/What-we-collect

 

Reviews of and Changes to our Privacy and Fair Processing Notice

This Privacy and Fair Processing Notice is subject to regular review and has been been most recently updated to take account of the implementation of GDPR.

 

 

Dr David Powell

May 2018

 

 

 

 

 

 

 

 

 

 

 

 

Definitions of information/data

 

  • Data Processor – An organisation or body that processors, reviews, updates or amends, or stores information about individuals
  • Personal Confidential Information – this term describes personal information or data about identified or identifiable individuals, which should be kept private or secret. For the purposes of this notice ‘personal’ includes the Data Protection Act definition of personal data, but it is adapted to include deceased as well as living people. ‘Confidential’ includes both information ‘given in confidence’ and ‘that which is owed a duty of confidence’ and is adapted to include ‘sensitive’ as defined in the Data Protection Act.
  • Pseudonymised – this is data that has undergone a technical process that replaces your identifiable information such as NHS number, postcode, date of birth with a unique identifier, which obscures the ‘real world’ identity of the individual patient to those working with the data
  • Anonymised – this is data about individuals but with identifying details removed so that there is little or no risk of the individual being re-identified
  • Aggregated – anonymised information that is grouped together so that it doesn’t identify individuals


 

Appendix A

 

Who do we share your information with and the legal basis for doing so?

 

 

Activity

Rationale

Clinical Commissioning Group

Purpose

Anonymous information is shared to plan and design care services within the locality.

 

Legal Basis

Non identifiable data only

 

Data Processor

Vale of York CCG

Individual Funding Requests

Purpose

We may need to share your information with the IFR team for the funding of treatment that is not normally covered in the standard contract.

 

Legal Basis

The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this.

 

Data processor

Vale of York CCG

Summary Care Records

Purpose

Limited Personal identifiable data is shared with the Summary Care Record to help with emergency doctors and nurses help you when you contact them when the surgery is closed.

 

Legal Basis

This is for your direct care and in an emergency – you can opt out of your record being shared.

 

Data Processor

Central NHS database

Other GP practices within Vale of York CCG in relation to the GP Extended Access Service (GPEAS)

Purpose

We will enable other GP’s and staff in other GP practices to have access to your medical record to allow you to receive acute medical care within that service.

 

Legal Basis

This service is for your direct care and is fully consented, permission to share your medical record will be gained prior to an appointment being made in the service and again once you are in the consultation.

 

Data processor

Your registered surgery will continue to be responsible for your full medical record

Pharmacists from the CCG/Medicines Management Team

Purpose

To provide monitoring and advice in line with the national directive for prescribing. Anonymous data is collected by the CCG.

 

Legal Basis

Direct care

 

Data Processor

Vale of York CCG

Multi Agency Safeguarding Board

Safeguarding Children

Safeguarding Adults

Purpose

We share information with health and social care authorities for safeguarding issues

 

Legal Basis

Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.

 

Data Processor

Multi Agency Safeguarding Authorities

Risk Stratification

Purpose

Risk stratification is a process for identifying and managing patients who are at high risk of emergency hospital admission.

Risk stratification tools use various combinations of historic information about patients, for example, age, gender, diagnoses and patterns of hospital attendance and admission and primary care data collected from GP practice record systems.

GPs will be able to identify which of their patients are at risk in order to offer a preventative service to them.

 

Legal Basis

Risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority

NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help and prevent avoidable hospital admissions and to promote quality improvement in GP practices.

 

Data Processors

() to assist us with providing Risk Stratification tools.

 

Data Processing activities for Risk Stratification

The GP practice instructs its GP IT system supplier to provide primary care data identifiable by your NHS Number.

 

Opting Out

If you do not wish information about you to be included in our risk stratification programme, please contact the Practice. We will add a code to your records that will stop your information from being used for this purpose. Further information about risk stratification is available from: https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification/

 

 

Quality monitoring, concerns and serious incidents

 

Purpose

We need to ensure that the health services you receive are safe, effective and of excellent quality. Sometimes concerns are raised about the care provided or an incident has happened that we need to investigate. You may not have made a complaint to us directly but the health care professional looking after you may decide that we need to know in order to help make improvements.

 

Legal Basis

The health care professional raising the concern or reporting the incident should make every attempt to talk to you about this and gain your consent to share information about you with us. Sometimes they can do this without telling us who you are. We have a statutory duty under the Health and Social Care Act 2012, Part 1, Section 26, in securing continuous improvement in the quality of services provided.

 

Data processor

We share your information with health care professionals that may include details of the care you have received and any concerns about that care. In order to look into these concerns we may need to talk to other organisations such as Vale of York CCG as well as other Public bodies and Government agencies such as NHS Improvement, the Care Quality Commission, NHS England as well as the Providers of your care.

 

 

Commissioning, planning, contract monitoring and evaluation

 

Purpose

We share aggregated, anonymous, patient data about services we have provided.

 

Legal Basis

Our legal basis for collecting and processing information for this purpose is statutory. We set our reporting requirements as part of our contracts with NHS service providers and do not ask them to give us identifiable data about you.

 

If patient level data was required for clarity and extensive evaluation of a service, consent will be gained for the surgery to share this information.

 

Data Processor

Various organisations, CCG, third party organisations commissioned by the NHS to perform actuarial services, NHS England.

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

Surveys and asking for your feedback

Purpose

Sometimes we may offer you the opportunity to take part in a survey that the practice is running. We will not generally ask you to give us any personal confidential information as part of any survey.

 

Legal Basis

You are under no obligation to take part and where you do, we consider your participation as consent to hold and use the responses you give us.

 

Data Processor – My Surgery Website (MSW)

Research

Purpose

To support research oriented proposals and activities in our commissioning system

 

Legal Basis

Your consent will be obtained by the organisation holding your records before identifiable information about you is disclosed for any research. If this is not possible then the organisation wishing to use your information will need to seek formal approval from The Independent Group Advising on the Release of Data (IGARD) http://content.digital.nhs.uk/IGARD

 

 

 

 



 
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