Privacy Policy

(Privacy Notice) Fair Processing Notice for the Grove Medical Centre

 

Your Personal Information – what you need to know

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

We are required to provide you with this privacy notice by law. It provides information about how we use the personal and healthcare information we collect, store and hold about you. This information helps to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form.

 

The main things the law says we must tell you about what we do with your personal data are:

·         We must let you know why we collect personal and healthcare information about you

·         We must let you know how we use any personal and/or healthcare information we hold about you

·         We need to inform you in respect of what we do with it

·         We need to tell you about who we share it with or pass it on to and why

·         We need to let you know how long we can keep it for

 

Our Commitment to Data Privacy and Confidentiality Issues

As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation.  This includes the General Data Protection Regulation (EU) 2016/679  (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time.  The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.

Data we collect about you

Records which this GP Practice will hold or share about you will include the following:

 

·         Patient details (name, date of birth, NHS number)

·         Address and NOK information

·         Medical notes (paper and electronic)

·         Details of treatment and care, including medications

·         Results of tests (pathology, X-ray, etc.)

·         Any other pertinent information

 

 

·         Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

·         Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. 

 

·         Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence.  Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.

 

·         Pseudonymised - The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.

 

  • Anonymised –  Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place

 

·         Aggregated - Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care.  We will share relevant information from your medical record with other health or social care staff or organisations when they provide you with care. For example it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed.  This is explained further in the Local Information Sharing at Appendix A.

 

Healthcare staff working in A&E and out of hours care will also have access to your information. For example, it is important that staff who are treating you in an emergency know if you have any allergic reactions. This will involve the use of your Summary Care Record.

 

At the same time, whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these 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 provided

•             research into the development of new treatments

•             preventing illness and diseases

•             monitoring safety

•             planning services

 

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

 

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

 

A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.

 

Registering for NHS care

·        All patients who receive NHS care are registered on a national database (NHS Spine). The Spine is held and maintained by NHS Digital, a national organisation which has legal responsibilities to collect NHS data.

Identifying patients who might be at risk of certain diseases

·         Your medical records will be searched by a computer programme so that we can identify patients who might be at high risk from certain diseases such as heart disease or unplanned admissions to hospital. This means we can offer patients additional care or support as early as possible.

·         This process will involve linking information from your GP record with information from other health or social care services you have used. Information which identifies you will only be seen by this organisation.

Safeguarding

·         Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm. These circumstances are rare and we do not need your consent or agreement to do this.

·         Please see our Safeguarding Policy for more information.

Medical research

·         This organisation shares information from medical records to support medical research when the law allows us to do so, for example to learn more about why people get ill and what treatments might work best. We will also use your medical records to carry out research within the organisation.

·         The use of information from GP medical records is very useful in developing new treatments and medicines; medical researchers use information from these records to help to answer important questions about illnesses and disease so that improvements can be made to the care and treatment patients receive.

·         When we share information with medical research organisations we will ask for your explicit consent

·         You have the right to object to your identifiable information being used or shared for medical research purposes. Please speak to our admin team if you wish to object.

 

Checking the quality of care – national clinical audits

 

·         This organisation contributes to national clinical audits so that healthcare can be checked and reviewed. Information from medical records can help doctors and other healthcare workers to measure and check the quality of care that is provided to you.

·         The results of the checks or audits can show where organisations are doing well and where they need to improve. These results are also used to recommend improvements to patient care.

·         Data is sent to NHS Digital, a national body with legal responsibilities to collect data.

·         The data will include information about you, such as your NHS Number and date of birth, and information about your health which is recorded in coded form – for example the code for diabetes or high blood pressure.

·         We will only share your information for national clinical audits or checking purposes when the law allows.

·         For more information about national clinical audits see the Healthcare Quality Improvements Partnership website or phone 020 7997 7370.

·         You have the right to object to your identifiable information being shared for national clinical audits. Please speak to our admin team if you wish to object.

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for Health and Social Care 2016.

Your right to opt out of data sharing and processing

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

 

NHS Digital explains that the national data opt-out allows patients to choose if they do not want their confidential patient information to be used for purposes beyond their individual care and treatment.

NHS Digital provides detailed guidance for opt-outs, including those patients in secure settings. Additional information for patients is available from NHS England: “Make a choice about sharing data from your health records”.

You have the right to object to information being shared for your own care. Please speak to the admin team at the Grove Medical Centre if you wish to object. You also have the right to have any mistakes or errors corrected.

Under 16s

The law says that you can make your own decisions about having treatment. This includes getting contraception, and also discussing/having an abortion, without your parent’s permission.

This will generally be the case if:

  • You are regarded as ‘competent’ – This means that you have to clearly understand the treatment you will be receiving, and also how it will affect you.
  • Your health will suffer if you don’t receive this treatment, and that the treatment is in your best interests.

So if you are 16 or under, the GP will have a chat with you about the problem, the treatment and will try to make an assessment through this discussion as to whether you are ‘competent’ to make the decision yourself. They will probably ask you why you don’t want your parents or care givers to know, and may suggest talking it through with them first. It is worth remembering however that no doctor can persuade or force you to tell your parents about the treatment that you are having.

Doctors also cannot tell your parents about your treatment (even if you are under 16) if you don’t want them to, apart from in very exceptional circumstances. This is called doctor-patient confidentiality, and all doctors and nurses are legal bound by it.

Please see children’s privacy policy.

Option 1: Type 1 Opt Out

This is an objection that prevents an individual's personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. It applies at organisational level and you can opt-out at any time. Opting out will mean that no further extractions will be taken from your medical record.

 

For a Type 1 Opt-out, you need to contact the us by phone, email or post to let us know that you wish to opt-out.

Option 2: National data opt-out

 

The national data opt-out (NDO-O) was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.

You can opt-out at any time.

NDO-O – you need to inform NHS England. Unfortunately, this cannot be done by the Grove for you. You can opt in or out at any time and complete this by any of the following methods:

 

Online service – You will need to know your NHS number or your postcode as registered at this organisation via Make your choice about sharing data from your health records

 

Telephone service 0300 303 5678 which is open Monday to Friday between 0900 and 1700

 

NHS App – For use by patients aged 13 and over (95% of surgeries are now connected to the NHS App). The app can be downloaded from the App Store or Google Play

 

“Print and post” Manage your choice

1.       Photocopies of proof of the applicant’s name (e.g., passport, UK driving licence etc.) and address (e.g., utility bill, payslip etc.) need to be sent with the application.

2.       It can take up to 14 days to process the form once it arrives at NHS, PO Box 884, Leeds. LS1 9TZ

Further information on NDO-O is available here.

 

On this web page you will:

•             See what is meant by confidential patient information

•             Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care

•             Find out more about the benefits of sharing data

•             Understand more about who uses the data

•             Find out how your data is protected

•             Be able to access the system to view, set or change your opt-out setting

•             Find the contact telephone number if you want to know any more or to set/change your opt-out by phone

•             See the situations where the opt-out will not apply

 

NHS Digital

  • NHS Digital is a national body which has legal responsibilities to collect information about health and social care services.
  • It collects information from across the NHS in England and provides reports on how the NHS is performing. These reports help to plan and improve services to patients.
  • This practice must comply with the law and will send data to NHS Digital, for example, when it is told to do so by the Secretary of State for Health or NHS England under the Health and Social Care Act 2012.
  • More information about NHS Digital and how it uses information can be found at:

https://digital.nhs.uk/home

NHS Digital sometimes shares names and addresses of patients suspected of committing immigration offences with the Home Office. More information on this can be found here: https://www.gov.uk/government/publications/information-requests-from-the-home-office-to-nhs-digital

Videos – Training Practice

The Grove Medical Centre is a training practice involved in the training of both Foundation Doctors and also ST Doctors. As part of their training, these doctors may be required to video some of their consultations. If this is taking place, you will be asked to sign a consent form before and after the consultation. Your consultation will not be videoed without your written consent. If you do consent to this, then the videos will be viewed by the trainee and the trainees supervisor, currently Dr Warwicker and partners .  Once viewed, the videos are deleted immediately.  

Right of Access to your information (Subject Access Request)

Under Data Protection Legislation everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access and you may find information has been redacted or removed for the following reasons;

·         Does not cause harm to the patient

·         That legal confidentiality obligations for the non-disclosure of third-party information are adhered to

You do not need to give a reason to see your data. And requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require.

Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the extra copies.

You will need to provide proof of identity to receive this information. For more information see our Patient Access to online services Policy.

Change of Details

It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.

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, with your consent 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. 

Notification

Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

 

We are registered as a 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

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Data Protection Officer

 

If you have any questions about this privacy notice or are unclear about how we process or use your personal information or have any other issue regarding your personal and healthcare information, then please contact our Data Protection Officer Dr Linsey Leach via our online admin form: https://accurx.nhs.uk/patient-initiated/h81066

 

For further queries you can also contact our Integrated Care Board Partnership team via:

Email: syheartlandsicb.informationgovernance@nhs.net

What is the right to know?            

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector.  You can request any non-personal information that the GP Practice holds, that does not fall under an exemption.  You may not ask for information that is covered by the Data Protection Legislation under FOIA.  However you can request this under a right of access request – see section above ‘Access to 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 Data Protection Legislation.

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 patients, the public and staff are entitled to.  These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong.

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

 

 

Appendix A – The Practice will share your information with these organisations where there is a legal basis to do so.

 

Activity

Rationale

ICB (Integrated Care Board)

Purpose – Anonymous data is used by the ICB for planning and performance as directed in the practices contract.

 

Legal Basis – Contractual

 

Processor – Surey Heartlands ICB

Summary Care Record

Purpose - The NHS in 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 faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

 

Legal Basis – Direct Care

 

Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, phone. If you wish to opt-out of having an SCR please return a completed opt-out form to the practice.

 

Processor – NHS England and NHS Digital

Research

Purpose – We many share personal confidential or anonymous information with research companies. Where you have opted out of having your identifiable information shared for this purpose your information will be removed.

 

Legal Basis – consent is required to share confidential patient information for research, unless there is have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales

Individual Funding Requests

Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our contracts.

 

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. You have the right to withdraw your consent at any time

 

Data processor – Practice Manager

Safeguarding Adults

Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns.

 

Legal Basis - Because of public Interest issues, e.g. to protect the safety and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.

 

Data Processor – Dr J Curtis

Safeguarding Children

Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns.

 

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 – Dr J Curtis

Risk Stratification – Preventative Care

Purpose -  ‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.

Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information.  This can help us identify and offer you additional services to improve your health.

                                                         

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.

 

Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data

 

Legal Basis

GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2020 NHS England Risk Stratification  which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.

 

 Data Processor: Integrated Care Board Partnership team via:

Email: syheartlandsicb.informationgovernance@nhs.net

Public Health

Screening programmes (identifiable)

Notifiable disease information (identifiable)

Smoking cessation (anonymous)

Sexual health (anonymous)

 

 

Purpose – Personal identifiable and anonymous data is shared.

The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.

More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes [Or insert relevant link] or speak to the practice

Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below.

 

Public Health Surrey County Council

Purpose –  Pseudonymised data is used by Public Health Surrey County Council to monitor locally commissioned services, measure prevalence and support data quality and statistics required for planning services.  The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

 

NHS Trusts

Purpose – Personal information is shared with other secondary care trusts in order to provide you with direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.

 

Legal Basis - The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions as stated below:

 

Processors – Ashford and St Peters Hospital

Care Quality Commission

Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.

 

More detail on how they ensure compliance with data protection law (including GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy-statement

 

Legal Basis - Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below

 

Processors – Care Quality Commission

 

Payments, Invoice validation

Purpose -  Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QUOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.

 

Legal Basis - Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below

 

Data Processors – NHS England, ICB, Public Health

 

Patient Record data base

Purpose – Your medical record will be shared, in order that a data base can be maintained and managed in a secure way

 

Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

 

Processor – EMIS

iGPR

Purpose – Your medical record will be shared in order that a report can be provided to agencies such as insurance companies or solicitors

 

Legal Basis – Your consent will be required to share your record for this purpose

 

Processor - iGPR

AccurRX

Purpose – Your anonymous information will be shared in order to optimise your medication within your record. This will enable your GP to provide a more efficient medication regime.

 

Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

 

Processor - Accurx

Medicines Management Team

Purpose – your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes can be implemented.

 

Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

 

Processor – Dr R Verma

GP Federation

 

GP Extended Access

Video consultations

Minor injuries services

Purpose – Your medical record will be shared with the NICS Federation in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics, first contract physio appointments and home visiting.

 

Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

 

Processor – NICS Federation

PCN

Purpose – Your medical record will be shared with the SASSE2 Primary Care Network in order to provide direct care services to the patient population.

 

Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

 

Processor – Packers (Virginia Water), Knowle Green, Orchard, Fordbridge Medical Centre.

Smoking cessation

Purpose – personal information is shared in order for the smoking cessation service to be provided.

 

Legal Basis – consented

 

Processor – One U Clinics

Police

Purpose – We will share personal confidential information with the police where there is a need to assess and evaluate any safeguarding or welfare concerns.

 

Legal Basis - Because of public Interest issues, e.g. to protect the safety and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.

 

Data Processor – Surrey Police

Technical solutions for analytics

 

SCW CSU

Oberoi Consulting Disease Management: CKD and Diabetes

Purpose - Oberoi consulting is a third party provider who will be processing data to enable The Grove Medial Centre to identify, optimise and manage patients with chronic kidney disease and diabetes mellitus.

 

Legal basis – The GMC is engaged in a legal contract which contains data processing terms in place.

 

Processor – Oberoi Consulting

Novartis Pharmaceuticals UK Limited & Apodi Limited

Cholesterol Management

Purpose - Novartis is a third party provider who will be processing data to enable The Grove Medial Centre to identify, optimise and manage patients with high cholesterol and eligible for inclisiran injections.

 

Legal basis – The GMC is engaged in a legal contract which contains data processing terms in place.

 

Processor – Novartis and Apodi

 

Lawful basis for processing:

The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere 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...”

Rights to Object

You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.