Privacy Notice – COVID-19

Our contact details

Organisation NameShore Medical
Address7 Poole Road, BH2 5QR
Phone number01202 767271
Emailenquiries.shore@dorsetgp.nhs.uk
Data Protection OfficerEmily Hutchings and Helen Williams (CCG)
Data Protection Registration NumberZ6503704

Update: Covid-19 and the use of your information

To look after your healthcare needs during the current coronavirus pandemic, we may need to share your personal information including health and care records with clinical and non-clinical staff who belong to organisations that are permitted to use your information and need to use it to help deal with the Covid-19 pandemic. This means that we may need to share your personal information for the purposes of treating you or a member of your family, and to allow us and other healthcare organisations to monitor the disease, assess risk, track and manage the spread of the disease. We may also need to use your information and health data to enable digital consultations and diagnoses, although we will always do this with your security in mind. We will only share your personal information when it is necessary to meet your needs or to meet public healthcare needs. It may also take us longer to respond to Subject Access requests whilst we focus our efforts on responding to the outbreak. During this period of emergency, opt-outs will not generally apply to the data used to support the Covid-19 outbreak, due to the public interest in sharing information. This includes National Data Opt-Outs. However, in relation to the Summary Care Record, existing choices will be respected.

Some of our staff may need to work from home during this time and may have access to any necessary personal and/or medical information in order to look after your healthcare needs. All staff are required to follow the necessary security policies of the Practice to ensure that all information is kept safe, secure and confidential.

NHS England and Improvement and NHSX have developed a single, secure store to gather data from across the health and care system to inform the Covid-19 response. This includes data already collected by NHS England, NHS Improvement, Public Health England and NHS Digital. New data will include 999 call data, data about hospital occupancy and A&E capacity data as well as data provided by patients themselves. All the data held in the platform is subject to strict controls that meet the requirements of data protection legislation.

These are temporary measures introduced by the Secretary of State for Health and Social Care under Regulation 3(4) of The Health Service (Control of Patient Information) Regulations 2002 to enable organisations to respond to and deal with the Covid-19 pandemic. Unless a further extension is required, these measures will expire on 30 September 2021.

If you are experiencing Covid-19 symptoms we may need to collect specific health data about you. Where we need to do so, we will not collect more information than we require and we will ensure that any information collected is treated with the appropriate safeguards.

Please note that the data protection and electronic communication laws do not stop us from sending public health messages to you, either by phone, text or email, as these messages are not direct marketing.

GP Connect

GP Connect is a programme run by NHS Digital that makes information held in GP practice IT systems available across health and social care. This allows other health organisations such as the new NHS 111 service, Covid-19 Clinical Assessment Service (CCAS), to see a ‘read only’ view of your record at this practice, and based on this information they will be able to directly book you a patient assessment at the Practice. The CCAS service has been set up to assess suspected COVID-19 patients needing further assessment from primary care, but not requiring hospital treatment.

Online Consultations

This Practice has reduced the number of face to face consultations available and during this period of emergency we may offer you a consultation via telephone or via video-conferencing using AccuRx . By accepting the invitation and entering the consultation you are agreeing to this. As part of the clinical assessment during these electronic consultations, patients may be asked to show intimate areas either during a video consultation, or by sending an image to the GP. Your personal/confidential patient information will be safeguarded in the same way it would be with any other consultation. AccuRx is secure, encrypted and approved for use by NHS England. It is also fully auditable and is held on hardware devices that are also encrypted and password protected.

The Practice does not record video consultations or store images received, unless your GP would ordinarily have taken an image during a face to face appointment. If your GP deems it necessary to take an image of your symptoms during a video consultation for your medical record, or to share with a specialist for a second opinion, they will ask your permission, as they would usually do during a face to face consultation. In this instance the image will be included in your record and shared securely if necessary. Images are retained as part of the medical record in line with standard retention periods for GP records. If your GP would normally have described your symptoms in writing for your medical record during the course of a face to face consultation, they will continue to do so from the video and/or image and then securely dispose of any video and/or images received.

Patients should not feel pressured into providing medical consent for the use of video consultations and/or images in place of face to face consultations and can request a face to face appointment instead. Refusal to take part in a video consultation or provide an image will not affect the care that you receive. Your GP may also request that a face to face appointment is made if it is felt that circumstances are not suitable for a video consultation, or provision of an image.

Update: General Practice Extraction Service (GPES) Data

This practice is supporting coronavirus (COVID-19) planning and research by sharing your data with NHS Digital, the national safe haven for health and social care data in England. This information will be vital in researching, monitoring, tracking and managing the coronavirus outbreak. NHS Digital has been legally directed by the Secretary of State for Health and Social Care to collect and analyse patient data from all GP Practices in England under the COVID-19 Public Health Directions 2020 to support the coronavirus response for the duration of the outbreak. NHS Digital will become the controller under the UK GDPR of the personal data collected and analysed jointly with the Secretary of State for Health and Social Care. More information about this requirement is contained in the data provision notice issued by NHS Digital to GP Practices. Under the UK GDPR our legal basis for sharing this personal data with NHS Digital is Article 6(1)(c) – legal obligation. Our legal basis for sharing personal data relating to health is Article 9(2)(g) – substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the COVID-19 Direction.

The data being shared with NHS Digital will include information about patients who are currently registered with a GP practice or who have a date of death on or after 1 November 2019 whose record contains coded information relevant to coronavirus planning and research. The data contains NHS Number, postcode, address, surname, forename, sex, ethnicity, date of birth, and date of death for those patients. It will also include coded health data which is held in your GP record such as details of diagnoses and findings, medications and other prescribed items, investigations, tests and results, treatments and outcomes, vaccinations and immunisations. NHS Digital will analyse the data they collect and securely and lawfully share data with other appropriate organisations, including health and care organisations, bodies engaged in disease surveillance and research organisations for coronavirus response purposes only. These purposes include protecting public health, planning and providing health, social care and public services, identifying coronavirus trends and risks to public health, monitoring and managing the outbreak and carrying out of vital coronavirus research and clinical trials. The British Medical Association, the Royal College of General Practitioners and the National Data Guardian are all supportive of this initiative.

NHS Digital has various legal powers to share data for purposes relating to the coronavirus response. It is also required to share data in certain circumstances set out in the COVID-19 Direction and to share confidential patient information to support the response under a legal notice issued to it by the Secretary of State under the Health Service (Control of Patient Information) Regulations 2002 (COPI Regulations). Legal notices under the COPI Regulations have also been issued to other health and social care organisations requiring those organisations to process and share confidential patient information to respond to the coronavirus outbreak. Any information used or shared during the outbreak under these legal notices or the COPI Regulations will be limited to the period of the outbreak unless there is another legal basis for organisations to continue to use the information.

Data which is shared by NHS Digital will be subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the coronavirus purpose will be shared. Organisations using your data will also need to have a clear legal basis to do so and will enter into a data sharing agreement with NHS Digital. Information about the data that NHS Digital shares, including who, with, and for what purpose will be published in the NHS Digital data release register. The application of the National Data Opt-Out to information shared by NHS Digital will be considered on a case by case basis and may or may not apply depending on the specific purposes for which the data is to be used. This is because during this period of emergency, the National Data Opt-Out will not generally apply where data is used to support the coronavirus outbreak, due to the public interest and legal requirements to share information.

For more information about how NHS Digital will use your data please see the NHS Digital Transparency Notice for GP Data for Pandemic Planning and Research (COVID-19), the NHS Digital Coronavirus (COVID-19) Response Transparency Notice, the NHS Digital General Transparency Notice, and how NHS Digital looks after your health and care information.