Everyone working for the NHS has a legal duty to keep information about you confidential

Sometimes the law requires the NHS to pass on information, for example, to notify a birth. The NHS Central Register for England and Wales contains basic personal details of all patients registered with a general practitioner. The register does not contain clinical information. You may be receiving care from other people as well as the NHS, so that we can all work together for your benefit we may need to share some information about you. The sharing of sensitive information is strictly controlled by law, and anyone who receives information from us also has a legal duty to keep it confidential.

As required by law, we are registered with the Data Protection Commissioner. You have a right of access to your records under the 2018 Data Protection Act. Please speak to any of the receptionists as there may be a charge for this service.

All patients registered with the practice are automatically offered online access to their medical records, please ask any of the receptionists for details.

The practice is committed to continuously improving its IT systems to enable us to maintain up-to-date information and accurate patient records. All stored data is subject to the data protection act. We only ever use or pass on information about you if people have a genuine need for it in your and everyone’s interests. Whenever we can we shall remove details which identify you. The sharing of some types of very sensitive personal information is strictly controlled by law. If your doctor is requested to report information to external agencies such as solicitors or insurance companies, he/she will only do so with your explicit consent.

This practice uses EMIS Web Software, a computerised medical record system. Storing records on the computer can help us to monitor and audit our performance so that we provide the best possible care. Your registration details are held on the computer, along with the medical information from consultations.

Anonymised health information is sent to NHS England to monitor quality standards and for post-payment verification purposes. All this information is covered by the Data Protection Act. We ask you for information so that you can receive proper care and treatment. We keep this information together with details of your care because it may be needed if we see you again. Everyone working for the NHS has a legal duty to keep information about you confidential.

The doctors and staff at this practice are committed to providing high quality healthcare and services to patients.

If you would like to give us any feedback or wish to make a complaint, please complete our Feedback and Complaints Form.

We operate a complaints procedure as part of the NHS system for dealing with complaints.

The practice complaints procedure meets national criteria.

What If My Complaint Is Personal?

We shall respect your confidentiality. If your concerns are about another person we will need their written permission before discussing anything personal with you.

Tell Us What You Think

It is helpful to have your views about how we run the practice.

If something concerns you or you think we should know about anything, please speak the operations manager. You can write down your comments and suggestions and give to a member of staff or put it in the suggestions box.

The doctors and staff are interested to know what you think about the services we offer here. Your compliments as well as complaints are equally welcomed.

We will provide high quality primary care response to the needs of the local community, to the mutual satisfaction of patients, clinicians and practice staff.

We will respect the needs and beliefs of patients without discrimination, in a supportive and friendly environment.

We will create an atmosphere of professionalised care and accessibility, and to work in partnership with patients and other health care professionals.

How To Complain

It is best to tell a member of staff about any concerns or problems as soon as they arise and we will try and sort them out.

If you wish to make a complaint, please complete our Feedback form as soon as possible so we can find out what happened.

You can ask for an appointment with the operations manager in order to discuss your concerns. She will explain the complaints procedure to you and make sure that your concerns are dealt with promptly. It helps us if you can give us as the full details about your complaint.

You need to make your complaint within 12 months of the incident that caused the problem OR within 12 months of discovering that you have a problem relating to a specific incident.

Complaining on Behalf of Someone Else

Medical records are protected by the Data Protection Act 2018. If you are complaining on behalf of someone else we need to know that you have their permission to do so. A note signed by the person concerned will be needed unless they are incapable (i.e. due to illness) of providing this.

Verbal Complaints

We believe that most problems can be sorted out easily and quickly, often at the time they occur with the individuals concerned. Please ask to speak with Sally Knapp, our reception manager, who will try to assist you. If you are unable to resolve your problem at step 1 then please follow step 2 below.

Local Resolution

As part of our resolution process, we wish to deal with complaints as soon as possible after the event. If not resolved in step 1, then a complaint must be made in writing, ideally within 1 year of the date on which the com-plaint occurred.

The complaint letter must be addressed to Operations Manager.

What We Will Do

We shall acknowledge your complaint in writing within 3 working days and shall then proceed to investigate your complaint within 10 working days. After investigating your complaint we should be in a position to offer you an explanation by writing to you. Or we may invite you to a meeting in the practice if this is appropriate. When we look into a complaint we aim to:

• Find out what happened and what went wrong
• Make it possible for you to discuss the problem with those concerned, if this is appropriate
• Make sure you receive an apology where appropriate
• Identify what we can do to make sure the problem does not arise again
• Introduce procedures to ensure that best practice is adopted where necessary.

A written response from the complaints manager will be sent within 30 working days of the complaint being made.

Useful Addresses

If you are not happy with our written response to your concerns, you can contact the NHS England Customer Contact Centre or The Parliamentary and Health Service Ombudsman.

NHS England Customer Contact Centre

NHS Commissioning Board
P.O. Box 16738
Redditch
B97 9PT

Tel: 0300 311 2233

Voice Ability: 0300 3305 454

Text Phone: 0786 002 2939

Email: england.contactus@nhs.net

The Parliamentary and Health Service Ombudsman

Millbank Tower
Millbank
London
SW1P 4QP

Tel: 0345 015 4033

Website: www.ombudsman.org.uk

NHS 111 Service

Medical help fast but not a 999 emergency.

Tel: 111

If you have difficulties communicating or hearing.

Text Phone: 18001 111

Remember

• We want you to let us know if you are unhappy or have a suggestion about how we can do things better
• All complaints are treated in the strictest confidence
• Making a complaint will not affect your treatment at the surgery

Streatham PCN is made up of a number of GP Practices and has been created for members practices to work collaboratively to deliver the requirements of the PCN Directed Enhanced Service Contract.

The following practices are part of Streatham PCN:

• Palace Road Surgery
• Streatham Hill Group Practice
• Valley Road Surgery
• The Exchange Surgery
• Streatham Common Practice
• The Vale Surgery

As part of the PCN DES service, we are required to provide Enhanced Access to patients registered with practices in the PCN. Enhanced Access is patient appointments outside core practice hours – that is between 18:30-20:00 on weekdays, and on Saturdays 09:00 till 17:00. We have chosen to also offer some appointments between 07:00-08:00 on weekdays. We have also chosen to subcontract some of the provision of these appointments to our local GP federation (Lambeth GP Federation), who have previously provided access hubs in the area.

The Enhanced Access service for our patients requires the following:

• An interoperable Clinical IT solution and
• Data Sharing between the PCN practices and the GP Federation

To enable us to provide our Enhanced Access Service to you, clinicians from other practices in our PCN and working for our local Federation will at times have access to your full GP record, but only when providing direct care to you.

People who have access to your information will only normally have access to information that they need to fulfil their roles. For example, admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments; the practice nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst any GP you see or speak to will normally have access to everything in your record.

1) Controller contact details	The controller of your data when it is in your practice clinical record will be your registered GP practice.  The controller of your data when it is in the GP Federation clinical record system is Lambeth GP Federation, 1 Alleyn Park, London, SE21 8AU
2) Data Protection Officer contact details	Danielle Gibbons  GP Data Protection Officer gpdpo@selondonics.nhs.uk
3) Purpose of the processing	To provide our patients with direct care.
4) The Lawfulness Conditions and Special Categories	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…’. 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…” We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”*
5) Recipient or categories of recipients of the shared data	The data will be shared with:  Palace Road Surgery www.palaceroadsurgery.co.uk Streatham Hill Group Practice www.shgp.co.uk Valley Road Surgery www.valleyroadsurgery.co.uk The Exchange Surgery www.theexchangesurgery.com Streatham Common Practice www.streathamcommonpractice.co.uk The Vale Surgery www.thevalesurgery.co.uk Lambeth GP Federation www.lambethgpfederations.nhs.uk/access-hubs
6) Rights to object	You have the right under Article 21 of the GDPR to object to your personal information being processed. Please contact the Practice if you wish to object to the processing of your data. You should be aware that this is a right to raise an objection which is not the same as having an absolute right to have your wishes granted in every circumstance.  GP Practices process personal data under Article 6(1)(c) on a lawful and legitimate basis where the organisation is obliged under law to comply with The General Data Protection Regulations (GDPR) The Freedom of Information Act The NHS Constitution The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009 By complying with these laws, the Practice has compelling legitimate grounds for the processing which override the interests, rights and freedoms in the right to object.
7) Right to access and correct	Under GDPR and the Data Protection Act 2018, you have the right to see or be given a copy of any personal data we hold about you. To gain access to a copy of your information, you will need to make a Subject Access Request (SAR) to the Practice you are normally registered with.  You also have the right to have incorrect data held about you corrected.
8) Retention period	The data will be retained for the period as specified in the national NHS records retention schedule.
9)  Right to Complain.	You have the right to complain to the Information Commissioner’s Office. You can use this link www.ico.org.uk/global/contact-us  or call their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

The General Data Protection Regulation (GDPR) is a law that determines how your personal data is processed and kept safe, and the legal rights that you have in relation to your own data.

What GDPR Means For Patients

The GDPR sets out the key principles about processing personal data, for staff or patients:

• Data must be process lawfully, fairly and transparently
• It must be collected for specific, explicit and legitimate purposes
• It must be limited to what is necessary for the purposes for which it is processed
• Information must be accurate and kept up to date
• Data must be held securely
• It can only be retained for as long as is necessary for the reasons it was collected

There are also stronger rights for patients regarding the information that practices hold about them. These include:

• Being informed about how their data is used
• Patients to have access to their own data
• Patients can ask to have incorrect information changed
• Restrict how their data is used
• Move their patient data from one health organization to another
• The right to object to their patient information being processed (in certain circumstances)

What is GDPR?

GDPR stands for General Data Protection Regulations and is a piece of legislation that superseded the Data Protection Act. It not only applies to the UK and EU; it covers anywhere in the world in which data about EU citizens is processed.

The GDPR is similar to the Data Protection Act (DPA) 2018 (which the practice already complies with), but strengthens many of the DPA’s principles. The main changes are:

• Practices must comply with subject access requests
• Where we need your consent to process data, this consent must be freely given, specific, informed and unambiguous
• There are new, special protections for patient data
• The Information Commissioner’s Office must be notified within 72 hours of a data breach
• Higher fines for data breaches

What Is ‘Patient Data’?

Patient data is information that relates to a single person, such as his/her diagnosis, name, age, earlier medical history etc.

What Is Consent?

Consent is permission from a patient – an individual’s consent is defined as “any freely given specific and informed indication of his wishes by which the data subject signifies his agreement to personal data relating to him being processed.”

The changes in GDPR mean that we must get explicit permission from patients when using their data. This is to protect your right to privacy, and we may ask you to provide consent to do certain things, like contact you or record certain information about you for your clinical records.

Individuals also have the right to withdraw their consent at any time.

Who to contact regarding data protection matters:

Taofik Adigun (General Practice Administrator)
Email: LAMCCG.PalaceRoadSurgery@nhs.net

For more information about how your data can be used please visit: www.understandingpatientdata.org.uk/what-you-need-know.

There are occasions when the doctor or nurse needs to give you a full examination.

• All patients are entitled to have a chaperone with them for any physical examination.
• The chaperone can be a family member, friend or a member of staff.
• If you want a member of staff to accompany you during the visit please let the receptionist know when you arrive for your appointment.

All patients are entitled to have a chaperone present for any consultation, examination or procedure. If you would like a chaperone, however have not been offered one, please ask your GP, nurse or enquire at reception.

If we can’t provide someone straight away, you may need to return for the examination.