PRIVACY POLICY

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.

 

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received within any NHS organisation and Boathouse Physiotherapy Limited.  These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form. The records will include basic details about you, such as your name and address. They will also contain more sensitive information about your health and also information such as outcomes of needs assessments.

 

Details we collect about you

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP Surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

 Records which this Physiotherapy Practice will hold about you will include the following:

 

  • Details about you, such as your address and next of kin
  • Any contact the surgery/practice has had with you, such as appointments, clinic visits, emergency appointments, etc.
  • Notes and reports about your health
  • Details about your treatment and care
  • Results of investigations, such as laboratory tests, x-rays, etc.
  • Relevant information from other health professionals, relatives or those who care for you

 

How we keep your information confidential and safe

Everyone working for our organisation is subject to the Common Law Duty of Confidence.  Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law.  The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.  All our staff are expected to make sure information is kept confidential and receive regular training on how to do this. We also adhere to the standards set by the Chartered Society of Physiotherapy and are registered with the Information Commissioners Office.

 

The health records we use will be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure.  Your records are backed up securely in line with NHS standard procedures.  We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

 

  • Data Protection Legislation
  • General Data Protection Regulation
  • Human Rights Act
  • Common Law Duty of Confidentiality
  • NHS Codes of Confidentiality and Information Security
  • Health and Social Care Act 2015
  • And all applicable legislation

 

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

 

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care.  For example it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed.  This is explained further in the Local Information Sharing section below.

 

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.

 

You can choose to withdraw your consent to your personal data being shared for these purposes. When we are about to participate in a new data-sharing project we will display prominent notices in the Practice and on our website at least four weeks before the scheme is due to start. Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.

 

You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.

 

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS.

 

Clinical audit

Information will be used by the CCG or Boathouse Physiotherapy for clinical audit to monitor the quality of the service provided. When required, information will be held centrally and used for statistical purposes (e.g. clinical notes audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

 

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to identify which CCG is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

 

Private medical insurance invoicing is completed via post, email and online billing. We may need to share relevant information with your insurer to process your claim.

 

Local Information Sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a health professional such as an Emergency Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if relevant information from your GP record is available to them.

 

Where available, this information can be shared electronically with other local health and care providers via a secure system designed for this purpose. Depending on the service you are using and your health and care needs, this may involve the professional accessing a secure system that enables them to view relevant parts of your GP electronic patient record (e.g. Connected Care or your Summary Care Record).

 

In all cases, your information is only accessed and used by authorised health and social care professionals in Berkshire based organisations who are involved in providing or supporting your direct care. Your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).

 

National Fraud Initiative - Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under Data Protection legislation. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see:

https://www.gov.uk/government/publications/code-of-data-matching-practice-for-national-fraud-initiative

 

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

 

Safeguarding

To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in circumstances where it’s legally required for the safety of the individuals concerned.

 

 

Supporting Locally Commissioned Services

CCGs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality.  The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

 

Data Retention

We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.

 

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:

 

  • NHS Trusts
  • Specialist Trusts
  • GP Federations
  • Health Care Professions Council
  • Independent Contractors such as sports massage therapists
  • Private Sector Providers
  • Private Medical Insurance Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Clinical Commissioning Groups
  • Social Care Services
  • Local Authorities
  • Education Services
  • Fire and Rescue Services
  • Police
  • Other ‘data processors’

 

We will never share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function.

 

Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Invoice Validation, – we will assume you are happy for your information to be shared unless you choose to opt-out (see below).

 

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared where necessary. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as where a formal court order has been issued.  Our guiding principle is that we are holding your records in strictest confidence.

 

Your right to withdraw consent for us to share your personal information (Opt-Out)

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything.  If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.

If you wish to discuss or change your opt-out preferences at any time please contact:  Katherine Sanders or Jessica Pascall on 01189767189.

 

Access to your information

Under Data Protection Legislation everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions.  You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.  We may charge a reasonable fee for the administration of the request.

 If you wish to have a copy of the information we hold about you, please contact:   Katherine Sanders or Jessica Pascall on 01189767189.

 

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.

 

Mobile telephone number

If you provide us with your mobile phone number we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.

 

Notification

Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

 

We are registered as a Data Controller and our registration can be viewed online in the public register at:  http://ico.org.uk/what_we_cover/register_of_data_controllers

Any changes to this notice will be published on our website and in a prominent area at the Practice.

 

Complaints

If you have concerns or are unhappy about any of our services, please contact the  Katherine Sanders or Jessica Pascall on 01189767189. Or alternatively you could contact the Health Care Professions Council:

http://www.hcpc-uk.co.uk/complaints/

For independent advice about data protection, privacy and data-sharing issues, you can contact:

 

The Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Phone: 0303 123 1113     Website: www.ico.gov.uk

 

Further Information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found here:

 

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under Data Protection Legislation.

http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf

 

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to.  These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programmes available to you, confidentiality, information and your right to complain if things go wrong.

https://www.gov.uk/government/publications/the-nhs-constitution-for-england

 

NHS Digital

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

http://content.digital.nhs.uk/article/4963/What-we-collect

 

Reviews of and Changes to our Privacy Notice

We will keep our Privacy Notice under regular review. This notice was last reviewed in May 2018.

DIAGNOSE.

PLAN.

REHABILITATE.

Copyright © Boathouse Physiotherapy 2017. All Rights Reserved.

JESSICA PASCALL

KATHERINE SANDERS

 

The Boathouse Surgery

Whitchurch Road

Pangbourne

RG8 7DP

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0118 9767189

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