Data controller
Charlotte Medical Practice
Lochfield Road Primary Care Centre
12-28 Lochfield Road
Dumfries
DG2 9BH
01387 267626
For any data protection matters please contact Suzanne Robson, Practice Manager
Charlotte Medical Practice has a legal duty to explain how we use any personal information we collect about you, as a registered patient at the practice. Practice Staff and Health Board employed staff, (i.e. Pharmacists, Mental Health workers, District Nurses, Immunisation team Nurses) maintains records about your health and the treatment you receive in electronic and paper format.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
- Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of the health or social care or treatment or the management of health or social care systems and services on the basis of union or Member State law or pursuant to contract with a health professional and subject to specific condition and safeguards.
What information do we collect about you?
We will collect information such as personal details, including name, address, next of kin, records of appointments, visits, telephone calls, your health records, treatment and medications, test results, X-rays, etc. and any other relevant information to enable us to deliver effective medical care.
How we will use your information
Your data is collected for the purpose of providing direct patient care; however, we can disclose this information if it is required by law, if you give consent or if it is justified in the public interest. The practice may be requested to support research; however, we will always gain your consent before sharing your information with medical research databases such as the Information Services Division Scotland (ISD Scotland) or others when the law allows.
In order to comply with its legal obligations, this practice may send data to ISD Scotland when directed by the Secretary of State for Health under the The Public Health (Scotland) Act 2008. Additionally, this practice contributes to national clinical audits and will send the data that is required by ISD Scotland when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form; for example, the clinical code for diabetes or high blood pressure.
Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the GDPR.
Maintaining confidentiality and accessing your records
We are committed to maintaining confidentiality and protecting the information we hold about you. We adhere to the General Data Protection Regulation (GDPR), the NHS Codes of Confidentiality and Security, as well as guidance issued by the Information Commissioner’s Office (ICO). You have a right to access the information we hold about you, and if you would like to access this information, you will need to complete a Subject Access Request (SAR). Please ask at reception for a SAR form
We use a processor, iGPR Technologies Limited (“iGPR”), to assist us with responding to report requests relating to your patient data, such as subject access requests that you submit to us (or that someone acting on your behalf submits to us)and report requests that insurers submit to us under the Access to Medical Records Act 1988 in relation to a life insurance policy that you hold or that you are applying for.
iGPR manages the reporting process for us by reviewing and responding to requests in accordance with our instructions and all applicable
laws, including UK data protection laws. The instructions we issue to iGPR include general instructions on responding to requests and specific instructions on issues that will require further consultation with the GP responsible for your care. Furthermore, should you identify any inaccuracies; you have a right to have the inaccurate data corrected.
Risk stratification
Risk stratification is a mechanism used to identify and subsequently manage those patients deemed as being at high risk of requiring urgent or emergency care. Usually this includes patients with long-term conditions, e.g. cancer. Your information is collected by a number of sources, including SPIRE (NHS NATIONAL SERVICES SCOTLAND), NHS Dumfries and Galloway and Local Intelligence Support Team; this information is processed electronically and given a risk score which is relayed to your GP who can then decide on any necessary actions to ensure that you receive the most appropriate care.
Invoice validation
Your information may be shared if you have received treatment to determine which NHS Area Health Board is responsible for paying for your treatment. This information may include your name, address and treatment date. All of this information is held securely and confidentially; it will not be used for any other purpose or shared with any third parties.
Opt-outs
You have a right to object to your information being shared. Should you wish to opt out of data collection, please contact a member of staff who will be able to explain how you can opt out and prevent the sharing of your information; this is done by registering a Type 1 opt-out, preventing your information from being shared outside this practice.
Retention periods
In accordance with the NHS Codes of Practice for Records Management, your healthcare records will be retained for 10 years after death, or if a patient emigrates, for 10 years after the date of emigration. *Electronic Patient Records (EPRs) – GP only- must not be destroyed, or deleted, for the foreseeable future. See link for further clarification of retention periods:
http://www.gov.scot/Publications/2010/04/20142935/8
What to do if you have any questions
Should you have any questions about our privacy policy or the information we hold about you, you can:
- Contact the practice’s data controller via email at suzanne.robson@nhs.scot (GP practices are data controllers for the data they hold about their patients)
- Write to the data controller at: Charlotte Medical Practice, Lochfield Primary care Centre, Lochfield Road, Dumfries DG2 9BH
- Ask to speak to the practice manager Mrs Suzanne Robson
The Data Protection Officer (DPO) for Charlotte Medical Practice is Mr. Colin McClelland and he is based at NHS Dumfries & Galloway, I M & T – Floor 2, Mountainhall Treatment Centre, Dumfries, DG1 4AP.
Complaints
In the unlikely event that you are unhappy with any element of our data-processing methods, you have the right to lodge a complaint with the ICO. For further details, visit ico.org.uk and select ‘Raising a concern’.
Changes to our privacy policy
We regularly review our privacy policy and any updates will be published on our website, in our newsletter and on posters to reflect the changes. This policy is to be reviewed 01/06/2020.