Coronavirus (COVID-19) pandemic and your information
The ICO recognises the unprecedented challenges the NHS and other health professionals are facing during the COVID-19 pandemic.
The ICO also recognise that 'Public bodies may require additional collection and sharing of personal data to protect against serious threats to public health.'
The Government have also taken action in respect of this and on 20th March 2020 the Secretary of State for Health and Social Care issued a notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 requiring organisations such as GP Practices to use your information to help GP Practices and other healthcare organisations to respond to and deal with the COVID-19 pandemic.
Please note that this notice has now been revised and extended by a further notice from 10 September 2021 until 31st March 2022.
In order to look after your healthcare needs during this difficult time, we may urgently need to share your personal information, including medical 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 could (amongst other measures) consist of either treating you or a member of your family and enable us and other healthcare organisations to monitor the disease, assess risk and manage the spread of the disease. Additionally, the use of your information is now required to support NHS Test and Trace.
Please be assured that we will only share information and health data that is necessary to meet yours and public healthcare needs.
The Secretary of State for Health and Social Care has also stated that these measures are temporary and will expire on 31st March 2022 unless a further extension is required. Any further extension will be provided in writing and we will communicate the same to you.
Please also 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.
It may also be necessary, where the latest technology allows us to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.
If you are concerned about how your information is being used, please contact our DPO using the contact details provided in this Privacy Notice.
At Trust Primary Care Ltd we are committed to ensuring the best standards of practice in all our activities. This extends beyond assuring the quality and safety of our clinical services, to ensuring high standards of quality and safety in the way we handle and manage personal data. We take a transparent approach to how we process personal data by being, open, honest and transparent.
In particular, our approach to data privacy and security is designed to protect the interests of:
- Our Patients
- Our Staff and Shareholders
- Individuals who interact with our website
Individuals from any of the above categories can be assured that the protection of privacy and confidentiality are given the highest priority, with all personal information being collected, held and used in strict compliance with the Data Protection Act 2018 and the General Data Protection Regulations (GDPR) 2018.
Type of data and the legal grounds on which data is processed
As a Healthcare organisation we have a legal duty to collect and process information relating to the creation of medical records (patients), personnel records (staff), shareholder records, as well as receiving enquiries (website) and conducting surveys. As such, we will ensure all personal data is collected, held and transferred (where required) in a lawful manner and in line with GDPR ‘good practice guidelines’.
Who controls the data we hold
Trust Primary Care Ltd will be the Data Controller for the information we gather from you. We use NHS approved systems to process patient data, the companies that operate these systems are data processors. In all cases we have confirmed that they are compliant with relevant legislation in relation to the management of your data. No data will be transferred outside of EU borders.
How long will the data we hold be kept for
The length of time we keep your personal data depends on what it is and whether we have an ongoing duty to retain it (for example, to provide you with ongoing care or to comply with legal and regulatory requirements).
We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing duty to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised.
How we use your data (Patients)
First and foremost, we use your personal data to support and manage your care. We also use your personal data for other purposes, which may include the following:
To communicate with you. This may include:
- Provide you with information about your care; such as appointments times and information about the care you will receive.
- To understand how you are responding to your care.
- To obtain feedback from you on the standard and quality of the care we have provided usually in the form of questionnaires.
The rights of the individuals whose data we process (Data Subjects)
GDPR regulations allow individual ‘data subjects’ particular rights, the key ones being:
- Right to be informed – of how we fairly process your data
- Right to access – the data that is held on you
- Right to rectification – of any data felt to be inaccurate or incomplete
- Right to erasure – of your data (otherwise known as ‘right to be forgotten’)
- Right to restrict processing – to ‘block’ or prevent further processing of existing data
- Right to data portability – transferring data to another provider/data controller
- Right to object – to processing (including profiling), direct marketing, and certain types of research
- Right to question automated decision making (eg for the purpose of profiling)
We will accommodate your wishes in line with your rights under GDPR as long as it is not contravened by any other relevant associated regulations.
Information collected through our website
We do not collect any personal information from visitors to our website other than information that is knowingly or voluntarily given. Anonymous information is collected, such as the number of visitors to the website in a given period but is purely statistical and cannot be used to identify an individual user.
Cookies are not used to collect any other information from visitors to the website. Visitors interested in requesting more information must provide contact details and the reason for their request. Visitors will not be contacted by us, unless such information is given, and contact is specifically requested.
Third Party Disclosure
We will never pass any personal information to any third party outside of our organisation (unless they are commissioned for data processing activities where we remain the ‘data controller’) without your consent.
Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.
Integrity of Data
We take all reasonable measures to ensure that the information we hold is accurate. In particular we use reliable collection methods and destroy or convert to an anonymous form, any out of date data. Individuals may request details of all personal information held by us so as to contest inaccurate or incomplete data, verify the information and have it corrected as appropriate.
Complaints & Concerns
Alternatively, you can raise an issue, if you feel we have in any way handled your personal data unfairly or inappropriately, with the Information Commissioners Office. Further details on GDPR and data protection laws can also be found at the ICO website.