To Provide You with Treatment

Doctors need to make notes about any diagnosis, test results, treatments including drugs prescriptions, and other information that you may provide, that seems relevant to the treatment of your condition. We need to keep this information in order to provide proper care for you (for later treatment, or if you should be seen by another doctor) and to allow others to check the treatment that you have received.

Nurses and other health professionals also need access to these records, and will add their own notes, as part of the overall healthcare provision. Secretaries, receptionists, and other clerical staff need access to some of your records in order to do administrative tasks, such as: booking appointments and communicating with you and other parts of the NHS.

Your doctor may also need to provide information under certain Acts of Parliament (e.g. the Communicable Diseases Act 1978, which is necessary to prevent the outbreak of certain highly contagious diseases) to protect you and others.

The Health Service

In order to manage the NHS, some restricted information concerning treatments, drugs prescribed, numbers of patients seen etc. is needed, and hospitals and general practices must provide this information in returns to various central bodies. This information has personal details such as your name and address removed wherever possible.

It is necessary from time to time to check these returns to prevent fraud as part of the NHS’s statutory obligations. This may result in your being contacted by an NHS Fraud Office to see if you will consent to your records being checked. Only if you provide your consent will the auditors be allowed to access your records.

Teaching Clinicians

Some medical files are needed to teach student clinicians. Without such materials, new doctors and nurses would be not be properly prepared to treat you.

Planning

We need to be able to plan ahead about treatments, patient numbers, etc., but this uses summary information, not personal information.

Medical Research

Some medical research will require your direct involvement (especially if taking part in clinical trials) in which case the circumstances will be fully explained to you, and your express consent required. If you do not consent, then you will not be included in the trial.

Other researchers only require access to medical statistics, and can greatly improve our understanding of health, and how to treat patients more effectively. Generally, researchers only need information about groups of people, so that no individual information is apparent. In some cases, they need individual records, but wherever we can we will provide these in an anonymous form (so individuals cannot be identified). Sometimes, researchers need access to individual medical files.

We will contact you first for your consent (and before this the researchers must present their case before an Ethics Committee to check that their research is appropriate and worthwhile). Rarely, it may not be practicable (or even possible) to contact individuals for their consent, in which case the researchers must make their case before a Confidentiality Committee to show that there is enough benefit to the public at large to justify this.

How do we manage your information?

We need to be able to move electronic information from system to system, extracting the data and modifying it for the next system. Occasionally, tests will need to be made on the data to check that it has been transferred correctly.

This will only be done under carefully controlled conditions and all employees and contractors will be under strict contractual obligations to protect your confidentiality.

Primary Care Networks (PCNs) are a key part of the NHS Long Term Plan, with all general practices being required to be in a network. This practice is part of the Bromley Connect Primary Care Network.

Bromley Connect PCN is made up of Dysart Surgery, London Lane Clinic and South View Partnership to work collaboratively to ensure the health care system within our area works effectively by sharing knowledge and resources.

In developing the Bromley Connect PCN Enhanced Access Service the following key principles have been considered and addressed:

• Monday appointments will be offered between 18:30-20:00. Each surgery within the PCN will hold one in three Mondays.
• Tuesday appointments will be offered between 18.30-20:00 and will be run by London Lane Clinic practice.
• Wednesday appointments will be offered between 18.30-20:00 and will be run by Dysart Surgery.
• Thursday appointments will be offered between 18.30-20:00 and will be run by South View practice.
• Fridays will provide 3 hours of digital triage and digital appointments.
• On Saturday mornings, where all three member practices are offering appointments patients may prefer to attend the clinic at their own site but will have the option to attend at other sites if more convenient or appropriate.
• Saturday afternoon, one hour of digital appointments and triage and 3 hours of hub appointments will be available. Each surgery to host one in three hubs.

To enable us to provide our Enhanced Access Service to you, GPs from other local practices will at times have access to your full GP record but only when providing direct care to you.

Clinicians will have the ability to view your GP record at your registered practice and add in your consultation/appointment notes back into your record at your registered practice. This is to support your provision of care.

People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance 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 the GP you see or speak to will normally have access to everything in your record.

1) Controller contact details	London Lane Clinic: 37-39 London Lane, Bromley BR1 4HB Practice Manager: Victoria Reed selicb.londonlaneclinic@nhs.net
2) Data Protection Officer contact details	Danielle Gibbons gpdpo@selondonics.nhs.uk NHS South East London South East London Integrated Care System
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 the Bromley Connect PCN Workforce providing the Enhanced Access Service. Dysart Surgery:  https://dysartsurgery.co.uk/ London Lane Clinic: https://thelondonlaneclinic.nhs.uk/  South View Partnership: https://southviewpartnership.nhs.uk/
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 https://ico.org.uk/global/contact-us/ or by calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website)