If you would like to request access to your medical records, please complete the attached form and post, e-mail or hand it in to the surgery. You will be required to show some proof of identity.

Subject Access Request Form

https://assets.practice365.co.uk/wp-content/uploads/sites/1089/2023/04/Subject-Access-Request-Form-for-Patient.pdf

The Surgery prides itself in maintaining professional standards. For certain examinations during consultations an impartial observer (a “Chaperone”) will be offered.

This impartial observer will be a practice Nurse or Health Care Assistant who is familiar with the procedure and be available to reassure and raise any concerns on your behalf. If a nurse in unavailable at the time of your consultation then your examination may be re-scheduled for another time.

You are free to decline any examination or chose an alternative examiner or chaperone. You may also request a chaperone for any examination or consultation if one is not offered to you. The GP may not undertake an examination if a chaperone is declined.

The role of a Chaperone:

• Maintains professional boundaries during intimate examinations.
• Acknowledges a patient’s vulnerability.
• Provides emotional comfort and reassurance.
• Assists in the examination.
• Assists with undressing patients, if required.

Child Safeguarding is the responsibility of all everybody and is highly regarded at the Surgery. We make every effort to recognise issues and address as they occur in the practice. By raising safeguarding children issues within the practice all staff will be aware of how they may access advice, understand their role in protection, and understand the importance of effective Inter-agency communication.

It is very important that all Practice staff understand the need for early identification, assessment and intervention when they have concerns about a child.  Case discussion and reflective practice is encouraged.  Child protection issues in general practice require a robust system of note-keeping and recording, message handling and communication of any concerns.

Key Factors to be aware of in safeguarding children

• The welfare of the child is paramount
• Be prepared to consult with colleagues
• Be prepared to take advice from local experts
• Keep comprehensive, clear, contemporaneous records
• Be aware of GMC guidance about sharing confidential information

Risk Factors and Identification – Child Sexual Exploitation

A child in need is defined as a child whose vulnerability is such that they are unlikely to reach or maintain a satisfactory level of health or development without the provision of services (section 17, Children’s Act 1989). This includes disabled children. The Children’s Acts 1984 and 2004 define a child as someone who has not reached their 18th birthday. The fact that a child has reached their 16th birthday and may be living independently, working, or be members of the armed forces does not remove their childhood status under the Acts.

Local authority social services departments working with other local authority departments and health services have a duty to safeguard and promote the welfare of children in their area who are in need. If you are considering making a referral to Social Services as a child in need, it is essential to discuss the referral with the child’s parents or carers and to obtain consent for the sharing of information. Social Services will then follow local procedures to undertake an assessment of the child and their family.

Child Protection Plan

Children judged to be at continuing risk have a child protection plan in place, this list is maintained by children’s social care (CSC).CSC, police and health professionals have 24 hour access to this. A child on the register has a “key worker” to whom reference can be made.

Recognising Child Abuse

(for full details please ref to Working Together to Safeguard Children 2013)

There are 4 main categories of child abuse:

• Physical abuse
• Sexual abuse
• Emotional abuse
• Neglect/failure to thrive

These are not however exclusive, and a number of abuse types can often coexist.

Physical abuse may include:

Injuries in children under 1 years of age or non-mobile children should be treated with a high degree of care

• Hitting, shaking, throwing, poisoning, burning or scalding, or other forms of physical harm

• Where a parent or carer deliberately causes ill-health of a child

• Single traumatic events or repeated incidents
• FGM

Sexual abuse may include:

• Forcing or enticing a child under 18 to take part in sexual activities where the child is unaware of what is happening
• May include both physical contact acts and non—contact acts

Emotional abuse may include:

• Persistent ill-treatment which has an effect on emotional development

• Conveyance of a message of being un-loved, worthlessness or inadequacy

• May instill a feeling of danger, being afraid

• May involve child exploitation or corruption
• Living in families where domestic violence is taking place

Neglect may include:

• Failure to meet the child’s physical or psychological needs

• Failure to provide adequate food or shelter

• Failure to protect from physical harm
• Neglect of a child’s emotional needs

Common presentations and situations in which child abuse may be suspected include:

• Disclosure by a child or young person

• Physical signs and symptoms giving rise to suspicion of any category of abuse

• The history is inconsistent or changes

• A delay in seeking medical help

• Extreme or worrying behaviour of a child, taking account of the developmental age of the child

• Accumulation of minor incidents giving rise to a level of concern, including frequent A&E attendances

Some other situations which need careful consideration are:

• Disclosure by an adult of abusive activities

• Girls under 16 presenting with pregnancy or sexually transmitted disease, especially those with learning difficulties

• Very young girls requesting contraception, especially emergency contraception

• Situations where parental mental health problems may impact on children

• Parental/ carer alcohol, drug or substance misuse which may impact on children

• Parents with learning difficulties

• Violence or domestic abuse in the family (please see separate document in safeguarding folder on domestic violence)
• Acuminous separation of parents with alleged allegation

If you have any special needs please let our staff know so that we can help and ensure you get the same support in the future.

Wheelchair access

Wheelchair access is available at the front of the surgery and we have toilets for the disabled.

Disabled Parking – Blue Badge Scheme

The Blue Badge scheme is for people with severe mobility problems. It allows Blue Badge holders to park close to where they need to go.

Loop System

We do not have a loop induction system at the reception desk to assist the hearing impaired. For more information on the loop hearing system visit Hearing Link website.

• British Deaf Association
• The Deaf Health Charity – SignHealth
• Action Hearing Loss
• Royal Association for Deaf People
• National Deaf Children’s Society

Blind/Partially Sighted

If you or family members are blind or partially sighted we can give you a CD or large print of our practice leaflet upon request. Please ask Reception for further information.

For more advice and support for blind people please see the following websites:

• Royal National Institute of Blind People (RIND)
• British Wireless for the Blind Fund
• British Blind Sport

Guide Dogs

Guide dogs are welcome at the surgery but we ask that you be aware of other patients and staff who may have an allergy or fear of dogs.

Further Information:

• Guide Dogs

Other Disability Websites

• BID Services
• Disability Go
• Disabled People, your Rights, Benefits, Carers and the Equality Act
• Disability Rights UK
• Living with a Disability NHS Choices
• Disability Action
• Mencap

We aim to provide you with the best possible medical service. At times you may feel that we have not achieved this and want to make your feelings known.

Please refer to our Complaints Policy:

https://assets.practice365.co.uk/wp-content/uploads/sites/1089/2023/04/Complaints-Policy.pdf

Information Leaflet for Patient:

https://assets.practice365.co.uk/wp-content/uploads/sites/1089/2023/04/Information-Leaflet-for-Patient-Complaints.pdf

Patient Complaint Third Party Consent Form:

https://assets.practice365.co.uk/wp-content/uploads/sites/1089/2023/04/Patient-Complaint-Third-Party-Consent-Form.pdf

The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:

• Have a publication scheme in place
• Allow public access to information held by public authorities.

The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.

Public authorities include government departments, local authorities, the NHS, state schools and police forces.

The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.

The Surgery publication scheme

A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:

• who we are and what we do
• what we spend and how we spend it
• what our priorities are and how we are doing it
• how we make decisions
• our policies and procedures
• lists and registers
• the services we offer

You can request our publication scheme leaflet at the surgery.

Who can request information?

Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use. 

How should requests be made?

Requests must:

• be made in writing (this can be electronically e.g. email)
• state the name of the applicant and an address for correspondence
• describe the information requested.

What cannot be requested?

Personal data about staff and patients covered under Data Protection Act.

For more information see these websites:

• Legislation GOV.UK
• Information Commissioners Office

All GP Practices are required to declare mean earnings (i.e. average pay) for GPs working to deliver NHS services to patients at each practice.

The average pay for GPs working in the practice of Greenford Avenue Family Health Practice in the last financial year was £80000.00 before tax and National Insurance.

This is for two GPs doing 8 session a week (salaried & locum gp), one GP doing 4 session (locum gp) and another doing 2 session (locum gp) worked in the practice for more than six months.

GP2GP – The Electronic Transfer of Patient Records

By the end of March 2015 your GP practice will able to send computer held patient records electronically to a patient’s new surgery so they arrive much quicker than the paper notes, helping the doctors and nurses know the best way to treat you. This is called the GP2GP electronic transfer of patient records. The paper notes will continue to be sent via an NHS delivery service.

With GP2GP, your medical record is available to your new doctor within a few minutes of registration, enabling much safer care.

For more information about GP2GP visit the HSCIC website.

We aim to keep our surgery clean and tidy and offer a safe environment to our patients and staff. We are proud of our modern, purpose built Practice and endeavour to keep it clean and well maintained at all times.

If you have any concerns about cleanliness or infection control, please report these to our Reception staff.

Our GPs and nursing staff follow our Infection Control Policy to ensure the care we deliver and the equipment we use is safe.

We take additional measures to ensure we maintain the highest standards:

• Encourage staff and patients to raise any issues or report any incidents relating to cleanliness and infection control.  We can discuss these and identify improvements we can make to avoid any future problems.
• Carry out an annual infection control audit to make sure our infection control procedures are working.
• Provide annual staff updates and training on cleanliness and infection control
• Review our policies and procedures to make sure they are adequate and meet national guidance.
• Maintain the premises and equipment to a high standard within the available financial resources and ensure that all reasonable steps are taken to reduce or remove all infection risk.
• Disposable materials are used for items such as couch rolls, modesty curtains, towels etc.
• Make Alcohol Hand Rub Gel available throughout the building

We have allocated a Named Accountable GP for all of our registered patients. If you do not know who your named GP is, please ask a member of our reception team. Unfortunately, we are unable to notify patients in writing of any change of GP due to the costs involved.

The practice complies with the Data Protection Act.  All information about patients is confidential: from the most sensitive diagnosis, to the fact of having visited the surgery or being registered at the Practice. All patients can expect that their personal information will not be disclosed without their permission except in the most exceptional of circumstances, when somebody is at grave risk of serious harm.

All members of the primary health care team (from reception to doctors) in the course of their duties will have access to your medical records. They all adhere to the highest standards of maintaining confidentiality.

As our reception area is a little public, if you wish to discuss something of a confidential nature please mention it to one of the receptionists who will make arrangements for you to have the necessary privacy.

Under 16s

The duty of confidentiality owed to a person under 16 is as great as the duty owed to any other person. Young people aged under 16 years can choose to see health professionals, without informing their parents or carers. If a GP considers that the young person is competent to make decisions about their health, then the GP can give advice, prescribe and treat the young person without seeking further consent.

However, in terms of good practice, health professionals will encourage young people to discuss issues with a parent or carer. As with older people, sometimes the law requires us to report information to appropriate authorities in order to protect young people or members of the public.

Useful Websites

• Confidentiality NHS Code of Practice
• Confidentiality and Mental Health
• Confidentiality Guidance

Privacy Notice

Your information, what you need to know

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

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received within any NHS organisation. These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for 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 may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form.

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments.

Details we collect about you

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP Surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

Records which this GP Practice may hold about you include the following:

• Details about you, such as your address and next of kin
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments,
• Notes and reports about your health
• Details about your treatment and care
• Results of investigations, such as laboratory tests, x-rays,
• Relevant information from other health professionals, relatives or your carers

How we keep your information confidential and safe

Everyone working for our organisation is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information applies to all NHS 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. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this.

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

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

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

• Data Protection Act 2018
• General Data Protection Regulation
• Human Rights Act
• Common Law Duty of Confidentiality
• NHS Codes of Confidentiality and Information Security
• Health and Social Care Act 2015
• And all applicable legislation

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for providing you, your family and your community with better 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 section below.

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 for a number of specific purposes, which are set out in law. These purposes are explained below.

You may choose to opt-out to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start.

Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.

You can object to your personal information being shared with other healthcare providers which will not affect your entitlement to care, but you should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS.

Child Health Information

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS CLCH health visitors and school nurses, and with NEL Commissioning Support Unit, who provide the Child Health Information Service on behalf of NHS England.

Clinical audit

Information may be used by the Clinical Commissioning Group for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

Clinical Research

Sometimes anonymised data may be used for research purposes – but we will normally ask your permission before releasing any information for this purpose which could be used to identify you.

In some instances, the Confidentially Advisory Group, part of the Health Research Authority may allow for identifiable information to be shared with researchers without consent of individuals. You may however opt-out of this, details of which can be found below under the ‘National Data Opt-Out’.

Improving Diabetes Care and long-term condition management

Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led local diabetes and long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.

Individual Funding Request

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

consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition

who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and 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 Clinical Commissioning Group 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.

Local Information Sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a local health or care professional outside of your usual practice services, such as in an Evening and Weekend GP HUB services, Emergency Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent.

Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or EMIS remote consulting system).

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).

Enhanced Data Sharing Module for practices using TPP SystmOne

If your Practice uses the TPP SystmOne software, you can choose whether other health and care providers can access your information to help provide you with care. We have drawn up an “allowed list” of local organisations with whom we can share your data (when you register for their services and give them verbal permission to provide your care through a TPP clinical system). See the link below under Who are our partner organisations.

If your GP uses SystmOne clinical software, organisations outside of this allowed group who use the same software will require formal documented permission to see your records. Your GP system will send you an SMS or email which you can give to the organisation asking for access which will formally validate your consent.

It is possible for you to set your own specific permissions (as distinct from the allowed list we have provided). More information about this, and how to do so, can be found here.

National Fraud Initiative – Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see:

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

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.

Risk Stratification

‘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.

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the NWL Clinical Commissioning Groups. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from: https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification /

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.

Safeguarding

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

Summary Care Record (SCR)

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.

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and 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 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, fax or phone. If you wish to opt- out of having an SCR please return a completed opt-out form to the practice.

Supporting Medicines Management

NWL Clinical Commissioning Groups use pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the CCG medicines management team may provide relating to obtaining medications on behalf of your GP Practice to support your care.

Anticoagulation Data managed with INRstar

We use LumiraDx Care Solutions UK Ltd who manufacture INRstar which is the software used to support the monitoring of patients who are take Warfarin. They act as data processors on behalf of our practice for the anticoagulation data recorded on those patients. INRstar are moving these patient records to cloud based services on 25th – 27th June 2021. The data residency will remain in England in a UK Government approved data centre. Further details on their privacy policy and data protection impact assessment can be found at www.lumiradxcaresolutions.com/legal. 

Supporting Locally Commissioned Services

CCGs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality. 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.

Suspected Cancer

Data may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital NHS Foundation Trust, London North West Healthcare NHS Trust and University College London Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual patients.

Data Retention

We manage patient records in line 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.

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 types of organisations:

• NHS Trusts
• Specialist Trusts
• GP Federations
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police
• Other ‘data processors’

Specific details of the organisations with whom we share your data can be seen here:

https://www.healthiernorthwestlondon.nhs.uk/yourhealth/healthinformation

We will not share your full information outside of health partner organisations without your 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. No information will ever be shared where we do not have a lawful basis to do so.

Within the health partner organisations providing your care (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – your information will be shared unless you choose to opt-out (see below).

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. 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 which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence.

Right to withdraw consent to share personal information (Opt- Out)

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 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 do so, please let us know so we can code your record appropriately. 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.

There are two main types of opt-out.

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. Please talk to a member of staff at your Practice to initiate the type 1 opt-out.

National Data Opt-Out

NHS Digital have created a new opt-out system named the National Data Opt-Out which allows individuals to opt-out of their information being used for planning and research purposes. From 25 May 2018, NHS Digital has had to apply this opt-out for all their data flows, and from 2020 all health and care organisations will have to ensure the opt-out is respected. Individuals who previously opted out with a ‘Type 2’ objection will not have to do anything as you will be automatically be opted out.

If you wish to apply the National Opt-Out, please go to NHS Digitals website here https://www.nhs.uk/your-nhs-data-matters/

Access to your information

Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing or speak to a member of the Practice staff. Under special circumstances, some information may be withheld.

If you wish to have a copy of the information we hold about you, please contact the practice and you will be asked to fill the form.

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 so our records for you are accurate and up to date.

Mobile telephone number

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

Notification

The Digital Economy  2017 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal data

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.

ICO Registration reference for our organisation Healthcare 360 Limited is  Z9911398

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

Complaints

If you have concerns or are unhappy about any of our services, please contact the Practice Manager : Rakhee Parikh

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

Information we are required to provide you

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 Data Protection Act 2018.

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 programmes 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

NHS Digital

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

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

Reviews of and Changes to our Privacy Notice

We will keep our Privacy Notice under regular review. This notice was last reviewed in March 2019.

New contractual requirements came into force from 1 April 2014 requiring that GP Practices should make available a statement of intent in relation to the following IT developments:

• Summary Care Record (SCR)
• GP to GP Record Transfers
• Patient Online Access to Their GP Record
• Data for commissioning and other secondary care purposes

The same contractual obligations require that we have a statement of intent regarding these developments in place and publicised by 30 September 2014.

Please find below details of the practices stance with regards to these points.

Summary Care Record (SCR)

NHS England require practices to enable successful automated uploads of any changes to patient’s summary information, at least on a daily basis, to the summary care record (SCR) or have published plans in place to achieve this by 31st of March 2015.

Having your Summary Care Record (SCR) available will help anyone treating you without your full medical record. They will have access to information about any medication you may be taking and any drugs that you have a recorded allergy or sensitivity to.

Of course, if you do not want your medical records to be available in this way then you will need to let us know so that we can update your record. You can do this via the opt out form.
The practice confirms that your SCR is automatically updated on at least a daily basis to ensure that your information is as up to date as it can possibly be.

GP to GP Record Transfers

NHS England require practices to utilise the GP2GP facility for the transfer of patient records between practices, when a patient registers or de-registers (not for temporary registration).
It is very important that you are registered with a doctor at all times. If you leave your GP and register with a new GP, your medical records will be removed from your previous doctor and forwarded on to your new GP via NHS England. It can take your paper records up to two weeks to reach your new surgery.

With GP to GP record transfers your electronic record is transferred to your new practice much sooner.

The practice confirms that GP to GP transfers are already active and we send and receive patient records via this system.

Patient Online Access to Their GP Record

NHS England require practices to promote and offer the facility to enable patients online access to appointments, prescriptions, allergies and adverse reactions or have published plans in place to achieve this by 31st of March 2015.

We currently offer the facility for booking and cancelling appointments and also for ordering your repeat prescriptions and viewing a summary of your medical records on-line. If you do not already have a user name and password for this system – please register your interest with our reception staff.

Data for commissioning and other secondary care purposes

It is already a requirement of the Health and Social Care Act that practices must meet the reasonable data requirements of commissioners and other health and social care organisations through appropriate and safe data sharing for secondary uses, as specified in the technical specification for care data.

At our practice we have specific arrangements in place to allow patients to “opt out” of care.data which allows for the removal of data from the practice. Please see the page about care data on our website

The Practice confirm these arrangements are in place and that we undertake annual training and audits to ensure that all our data is handled correctly and safely via the Information Governance Toolkit.

About your Summary Care Record

Your Summary Care Record contains important information about any medicines you are taking, any allergies you suffer from and any bad reactions to medicines that you have previously experienced.

Allowing authorised healthcare staff to have access to this information will improve decision making by doctors and other healthcare professionals and has prevented mistakes being made when patients are being cared for in an emergency or when their GP practice is closed.

Your Summary Care Record also includes your name, address, date of birth and your unique NHS Number to help identify you correctly.

You may want to add other details about your care to your Summary Care Record. This will only happen if both you and your GP agree to do this. You should discuss your wishes with your GP practice.

Healthcare staff will have access to this information, so that they can provide safer care, whenever or wherever you need it, anywhere in England.

FAQs

Who can see my Summary Care Record?

Healthcare staff who have access to your Summary Care Record:

• need to be directly involved in caring for you
• need to have an NHS Smartcard with a chip and passcode
• will only see the information they need to do their job and
• will have their details recorded every time they look at your record

Healthcare staff will ask for your permission every time they need to look at your Summary Care Record. If they cannot ask you (for example if you are unconscious or otherwise unable to communicate), healthcare staff may look at your record without asking you, because they consider that this is in your best interest.

If they have to do this, this decision will be recorded and checked to ensure that the access was appropriate.

What are my choices?

You can choose to have a Summary Care Record or you can choose to opt out.

If you choose to have a Summary Care Record and are registered with a GP practice, you do not need to do anything as a Summary Care Record is created for you.

If you choose to opt out of having a Summary Care Record and do not want a SCR, you need to let your GP practice know by filling in and returning an opt-out form (PDF, 245.9kB). Opt-out forms can be downloaded from the website or from your GP practice.

If you are unsure if you have already opted out, you should talk to the staff at your GP practice. You can change your mind at any time by simply informing your GP practice and either filling in an opt-out form (PDF, 245.9kB) or asking your GP practice to create a Summary Care Record for you.

Children and the Summary Care Record

If you are the parent or guardian of a child under 16, you should make this information available to them and support the child to come to a decision as to whether to have a Summary Care Record or not.

If you believe that your child should opt-out of having a Summary Care Record, we strongly recommend that you discuss this with your child’s GP. This will allow your child’s GP to highlight the consequences of opting-out, prior to you finalising your decision.

Where can I get more information?

For more information about Summary Care Records you can

• talk to the staff at your GP practice
• phone the Health and Social Care Information Centre on 0300 303 5678
• Read the Summary Care Record patient information

CONTEST, the Government’s national counter terrorism strategy, aims to reduce the risk to the United Kingdom and its interests overseas from international terrorism, so that people can go about their lives freely and with confidence.

The strategy has four main work streams:

• Pursue: to stop terrorist attacks
• Protect: to strengthen our protection against terrorist attack
• Prepare: where an attack cannot be stopped, to mitigate its impact
• Prevent: to stop people becoming terrorists or supporting terrorism

Prevent aims to stop people from becoming terrorists or supporting terrorism.

The Department of Health (DH) has worked with the Home Office to develop guidance for healthcare organisations to implement Prevent Locally; this is called “Building Partnerships Staying Safe”.  With more than 1 million consultations a day by the NHS it is an area that the DH needs to highlight to all NHS workers.

The Prevent Strategy addresses all forms of terrorism, including extreme right wing views, but continues to prioritise according to the threat posed to our national security.

The aim of Prevent is to stop people from becoming terrorists or supporting terrorism and operates in the pre-criminal space before any criminal activity has taken place. At present, the majority of effort is focused on stopping people from joining or supporting such groups as Al-Qaida and its related groups, and other extremist organisations actively recruit.

The three key objectives of the Prevent Strategy are to:

1. Challenge the ideology that supports terrorism and those who promote it.
2. Prevent vulnerable people from being drawn into terrorism and ensure that they are given appropriate advice and support.
3. Work with sectors and institutions where there are risks of radicalisation

(Health Organisations are expected to be involved in delivering objectives 2 and 3, only).

Why must health organisations engage in the Prevent Strategy?

The Department of Health is a key strategic partner in the Prevent Strategy as Healthcare professionals may meet and treat people who are vulnerable to radicalisation. People with mental health issues or learning disability may be more easily drawn into terrorism.

People Prevent is an on-going initiative and designed to become part of the everyday safeguarding routine for NHS staff.

It does not need new structures to be created but does require that members of staff are informed and have awareness of the Prevent Agenda and how to refer concerns.

Defination of Terms

• Terrorism is defined in the Terrorism Act of 2000 (TACT 2000) as an action that endangers or causes serious violence to a person or people, causes serious damage to property or seriously interferes or disrupts an electronic system. The use of threat must be designed to influence the government or to intimidate the public and is made for the purpose of political, religious or ideological gain.
• Radicalisation in this protocol refers to the process by which people come to support terrorism and forms of extremism leading to terrorism.
• Extremism: is vocal or active opposition to fundamental values including democracy, the rule of the law, individual liberty, and mutual respect and tolerance of different beliefs and faiths.
• A Prevent Concern does not have to be proven beyond reasonable doubt; it should however be based on something that raises concern which is assessed by using exiting professional judgement of a health or social care member of staff.
• Vulnerability in the context of Prevent is a person who is susceptible to extremists’ messages and is at risk of being drawn into terrorism or supporting terrorism at a point in time. The definition of vulnerable individual from No Secrets (2000) is “who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation”.

The local CCG should have polices in place and should advise practices of their obligations, however it is up to practices to decide when an issue needs to be reported on in the same way as Safeguarding Adults, Children and even Domestic violence.

Patient confidentiality is always key and so disclosing fears and suspicions have to be taken in a responsible manner weighing up the evidence and the person of concern.

Introduction

The purpose of this document is to set out the policy of the Practice in relation to the protection of vulnerable adults. Further guidance may be available on local inter-agency procedures via the Primary Care Organisation and / or Social Services.

What is a vulnerable adult?

The definition is wide, however this may be regarded as anyone over the age of 18 years who may be unable to protect themselves from abuse, harm or exploitation, which may be by reason of illness, age, mental illness, disability or other types of physical or mental impairment.

Those at risk may live alone, be dependent on others (care homes etc.), elderly, or socially isolated.

Forms of Abuse

• Neglect – ignoring mental or physical needs, care, education, or basic life necessities or rights
• Bullying – family, carers, friends
• Financial – theft or use of money or possessions
• Sexual – assault, rape, non-consensual acts (including acts where unable to give consent), touching, indecent exposure
• Physical – hitting, assault, man-handling, restraint, pain or forcing medication
• Psychological – threats, fear, being controlled, taunts, isolation
• Discrimination – abuse based on perceived differences and vulnerabilities
• Institutional abuse – in hospitals, care homes, support services or individuals within them, including inappropriate behaviours, discrimination, prejudice, and lack of essential safeguards

Abuse may be deliberate or as a result of lack of attention or thought, and may involve combinations of all or any of the above forms. It may be regular or on an occasional or single event basis, however it will result in some degree of suffering to the individual concerned. Abuse may also take place between one vulnerable adult and another, for example between residents of care homes or other institutions.

Indications

• Bruising
• Burns
• Falls
• Apparent lack of personal care
• Nervousness or withdrawn
• Avoidance of topics of discussion
• Inadequate living conditions or confinement to one room in their own home
• Inappropriate controlling by carers or family members
• Obstacles preventing personal visitors or one-to-one personal discussion
• Sudden changes in personality
• Lack of freedom to move outside the home, or to be on their own
• Refusal by carers to allow the patient into further care or to change environs
• Lack of access to own money
• Lack of mobility aids when needed

Action Required

Where abuse of a vulnerable adult is suspected the welfare of the patient takes priority. In deciding whether to disclose concerns to a third party or other agency the GP will assess the risk to the patient.

•  Ideally the matter should be discussed with the patient involved first, and attempt made to obtain consent to refer the matter to the appropriate agency. Where this is not possible, or in the case of emergency where serious harm is to be prevented, the patient’s doctor will balance the need to protect the patient with the duty of confidentiality before deciding whether to refer.
• The patient should usually be informed that the doctor intends to disclose information, and advice and support should be offered.
• Where time permits, the medical defence organisation will be telephoned before any action is taken.

Due regard will be taken of the patient’s capacity to provide a valid consent.

In assessing the risk to the individual, the following factors will be considered:

• Nature of abuse, and severity
• Chance of recurrence, and when
• Frequency
• Vulnerability of the adult (frailty, age, physical condition etc.)
• Those involved – family, carers, strangers, visitors etc.
• Whether other third parties are also at risk (other members of the same household may being abused at the same time)

Subject to the local procedures in force, consideration will be given to;

• Report to Social Services Mental Health team
• Report to Police
• Report to PCT lead

Patient’s Rights

We are committed to giving you the best possible service. This will be achieved by working together. Help us to help you. You have a right to, and the practice will try to ensure that:

• You will be treated with courtesy and respect
• You will be treated as a partner in the care and attention that you receive
• All aspects of your visit will be dealt with in privacy and confidence
• You will be seen by a doctor of your choice subject to availability
• In an emergency, out of normal opening hours, if you telephone the practice you will be given the number to receive assistance, which will require no more than one further call
• You can bring someone with you, however you may be asked to be seen on your own during the consultation
• Repeat prescriptions will normally be available for collection within two working days of your request
• Information about our services on offer will be made available to you by way of posters, notice boards and newsletters
• You have the right to see your medical records or have a copy subject to certain laws.

Patient’s Responsibilities

With these rights come responsibilities and for patients we would respectfully request that you:

• Treat practice staff and doctors with the same consideration and courtesy that you would like yourself. Remember that they are trying to help you
• Please ensure that you order your repeat medication in plenty of time allowing 2 working days.
• Please ensure that you have a basic first aid kit at home and initiate minor illness and self-care for you and your family.
• Please attend any specialist appointments that have been arranged for you or cancel them if your condition has resolved or you no longer wish to attend
• Please follow up any test or investigations done for you with the person who has requested the investigation
• Attend appointments on time and check in with Reception
• Patients who are more than 10 minutes late for their appointment may not be seen.
• If you are unable to make your appointment or no longer need it, please give the practice adequate notice that you wish to cancel. Appointments are heavily in demand and missed appointments waste time and delay more urgent patients receiving the treatment they need
• An appointment is for one person only. Where another family member needs to be seen or discussed, another appointment should be made
• Patients should make every effort to present at the surgery to ensure the best use of nursing and medical time. Home visits should be medically justifiable and not requested for social convenience
• Please inform us when you move home, change your name or telephone number, so that we can keep our records correct and up to date
• Read the practice leaflets and other information that we give you. They are there to help you use our services. If you do not understand their content please tell us
• Let us have your views. Your ideas and suggestions whether complimentary or critical are important in helping us to provide a first class, safe, friendly service in pleasant surroundings.

NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. For more information see these websites:

• UK – The NHS Constitution for England
• NHS Choices – NHS Constitution

The practice fully supports the NHS Zero Tolerance Policy. The aim of this policy is to tackle the increasing problem of violence against staff working in the NHS and ensures that doctors and their staff have a right to care for others without fear of being attacked or abused.

We understand that ill patients do not always act in a reasonable manner and will take this into consideration when trying to deal with a misunderstanding or complaint. We ask you to treat your doctors and their staff courteously and act reasonably.

All incidents will be followed up and you will be sent a formal warning after a second incident or removed from the practice list after a third incident if your behaviour has been unreasonable.

However, aggressive behaviour, be it violent or verbal abusive, will not be tolerated and may result in you being removed from the Practice list and, in extreme cases, the Police will be contacted if an incident is taking place and the patient is posing a threat to staff or other patients.

A good patient-doctor relationship, based on mutual respect and trust, is the cornerstone of good patient care. The removal of patients from our list is an exceptional and rare event and is a last resort in an impaired patient-practice relationship. When trust has irretrievably broken down, it is in the patient’s interest, just as much as that of The Surgery, that they should find a new practice. An exception to this is on immediate removal on the grounds of violence e.g. when the Police are involved.

Removing other members of the household

In rare cases, however, because of the possible need to visit patients at home it may be necessary to terminate responsibility for other members of the family or the entire household. The prospect of visiting patients where a relative who is no longer a patient of the practice by virtue of their unacceptable behaviour resides, or being regularly confronted by the removed patient, may make it too difficult for the practice to continue to look after the whole family. This is particularly likely where the patient has been removed because of violence or threatening behaviour and keeping the other family members could put doctors or their staff at risk.