Privacy notice
1. Introduction
As part of the services we offer, we are required to process personal data about our staff, our service users and, in some instances, friends or relatives. “Processing” can mean collecting, recording, organising, storing, sharing or destroying data.
We are committed to being transparent about why we need your personal data and what we do with it. This information is set out in this privacy notice. It also explains your rights when it comes to your data.
If you have any concerns or questions, please contact us at ghn-tr.admin.
2. Service Users
What data do we have?
So that we can provide a safe and professional service, we need to keep certain records about you. We may process the following types of data:
- Your basic details and contact information e.g. your name, address, date of birth and next of kin.
- Your healthcare records.
- Health and social care data about you, which might include both your physical and mental health data.
- We may also record data about your race, ethnic origin, sexual orientation or religion to comply with NHS policy.
Why do we have this data?
We need this data so that we can provide high-quality care and support. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
- We have a legal obligation to do so – under the Health and Social Care Act 2012.
We process your special category data because:
- It is necessary due to social security and social protection law (generally this would be in safeguarding instances).
- It is necessary for us to provide and manage your healthcare safely and effectively.
- To comply with regulators such as the Care Quality Commission (CQC).
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent at any time.
Common law duty of confidentiality
When we use confidential health and care information, we must comply with the common law duty of confidentiality. We will only use or disclose confidential patient information where there is a lawful basis for doing so under the common law, such as:
- It is necessary to provide you with individual care and it is reasonable to rely on your implied consent.
- You have given explicit consent for a specific use or disclosure.
- We are required or permitted by law to use or disclose information.
- Where there is an overriding public interest, for example where a disclosure is necessary to safeguard an individual.
Where do we process your data?
So that we can provide you with high quality care and support we need specific data. This is collected from or shared with:
- You or your legal representative(s);
- Third parties.
We do this face to face, via phone, via email, via our website and via post.
Third parties are organisations we might lawfully share your data with. These include:
- Other parts of the health and care system such as local hospitals, the GP, the pharmacy, social workers, ICBs, Trusts, and other health and care professionals.
- The Local Authority.
- Your family or friends – with your permission.
- Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC.
- The police or other law enforcement agencies if we are required to by law or court order.
3. National Data Opt Out
We are applying the national data opt-out because we are using confidential patient information for purposes beyond individual care.
The information collected about you when you use health and care services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
- Improving the quality and standards of care provided.
- Research into the development of new treatments.
- Preventing illness and diseases.
- Monitoring safety.
- Planning services.
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this when allowed by law.
Most of the time, the data used for research and planning is anonymised, so that you cannot be identified and your confidential patient information is not accessed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care.
To find out more or to register your choice to opt out, please visit https://www.nhs.uk/your-nhs-data-matters/.
You can change your mind about your choice at any time.
4. Staff
So that we can provide a safe and professional service, we need to keep certain records about you. We may record the following types of data:
- Your basic details and contact information e.g. your name, address, date of birth, National Insurance number and next of kin.
- Your financial details e.g. details so that we can pay you, insurance, pension and tax details.
- Your training records.
We also record the following data which is classified as “special category”:
- Health and social care data about you, which might include both your physical and mental health data – we will only collect this if it is necessary for us to know as your employer, e.g. fit notes or in order for you to claim statutory maternity/paternity pay.
- We may also, with your permission, record data about your race, ethnic origin, sexual orientation or religion.
As part of your application, you may – depending on your job role – be required to undergo a Disclosure and Barring Service (DBS) check (Criminal Record Check). We do not keep this data once we’ve seen it.
Why do we have this data?
We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
- We have a legal obligation under UK employment law
- We are required to do so in our performance of a public task.
- We have a legitimate interest in processing your data – for example, we provide data about your training to Skills for Care’s Adult Workforce Data Set, this allows Skills for Care to produce reports about workforce planning.
- We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations.
We process your special category data because:
- It is necessary for us to process requests for sick pay or maternity pay.
- If we request your criminal records data, it is because we have a legal obligation to do this due to the type of work you do. This is set out in the Data Protection Act 2018 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975. We do not keep a record of your criminal records information. However, in line with employment law, we do record that we have checked this.
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
Where do we process your data?
As your employer we need specific data. This is collected from or shared with:
- You or your legal representative(s);
- Third parties.
We do this face to face, via phone, via email, via post, via application forms and via apps.
Third parties are organisations we have a legal reason to share your data with. These include:
- His Majesty’s Revenue and Customs (HMRC).
- Our pension and healthcare schemes.
- Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC.
- The police or other law enforcement agencies if we have to by law or court order.
- The DBS Service. Our umbrella organisation is Mayflower DBS, also known as DBS direct.
5. Friends/Relatives
What data do we have?
As part of our work providing high-quality care and support, it might be necessary that we hold the following information on you:
- Your full name.
- Contact information.
- Address.
- Relationship to patient.
Why do we have this data?
By law, we need to have a lawful basis for processing your personal data.
We process your data because we have a legitimate business interest in holding next of kin and lasting power of attorney information about the individuals who use our service and keeping emergency contact details for our staff.
We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.
Where do we process your data?
So that we can provide high quality care and support we need specific data. This is collected from or shared with:
- You or your legal representative - We do this face to face, via phone, via email, via post, via application forms, via our website and via apps.
- Third parties – These are organisations that we have a legal basis to share your data with, such as other local hospitals, your GP, your pharmacy, social workers, and other health and care professionals.
- The Local Authority – This includes police and other law enforcement agencies. This is only done if we are required by law or a court order.
6. Personal Information Storage
Where do we store your (service users) personal information?
We store your personal information on our electronic patient record system Sunrise EPR. This is a 3rd party system which is controlled and secured by Gloucestershire NHS Foundation Trust. We ensure your data is stored for the timeframes set out in the Records Management Code of Practice 2023.
How do we dispose of your data?
We dispose of your data as per our Records Destruction Policy which adheres the NHS Records Management Code of Practice 2023, the Data Protection Act 2018, and the UK General Data Protection Regulation (UK GDPR). Our policy can be found on our website, alternatively contact us at ghn-tr.admin.
7. Website
Our website may contain links to other websites. We are not responsible for the privacy practices of third-party web sites should you visit them from a link.
What personal data do we collect?
If contacted via the email or phone number shown, we may collect various pieces of personal information such as your name, email address, postal address and telephone number.
Your personal data
Personal data submitted on this web site will be used for the following purposes only:
- To assist with the processing of any request you make to us via the web site.
- To review, develop and improve our website.
Your data will only be used within & between the staff of Cotswold Neurology Clinics and we will take all reasonable precautions to prevent the loss, misuse or theft of your personal information.
Contact
If you have any questions about this privacy policy, cookie information or treatment of your personal data please contact us on email at ghn-tr.admin.
Your Rights
The data that we keep about you is your data, we ensure it is kept confidential and that it is used appropriately. You have the following rights when it comes to your data:
- You have the right to request a copy of all the data we keep about you. We will not charge for this service.
- You have the right to ask us to correct any data we have which you believe to be inaccurate or incomplete. You can also request that we restrict all processing of your data while we consider your rectification request.
- You have the right to ask that we erase any of your personal data which is no longer necessary for the purpose we originally collected it for. We retain our data in line with the NHS Records Management Code of Practice 2023.
- You may also request that we restrict processing if we no longer require your personal data for the purpose we originally collected it for, but you do not wish for it to be erased.
- You can ask for your data to be erased if we have asked for your consent to process your data. You can withdraw consent at any time – please contact us to do so.
- If we are processing your data as part of our legitimate interests as an organisation or in order to complete a task in the public interest, you have the right to object to that processing. We will restrict all processing of this data while we look into your objection.
You may need to provide adequate information for our staff to be able to identify you, for example, a passport or driver’s licence. This is to make sure that data is not shared with the wrong person inappropriately. We will always respond to your request as soon as possible and at the latest within one month.
If you would like to complain about how we have dealt with your request, please contact:
Information Commissioner’s OfficeWycliffe HouseWater LaneWilmslowCheshireSK9 5AFhttps://ico.org.uk/global/contact-us/