Our staff are committed to providing quality healthcare for the benefit of all of our patients. View our policies to see how this is achieved.
Access to Medical Records Policy Including Subject Access Requests
The purpose of this document is to ensure that appropriate procedures are in place at Grosvenor House Surgery to enable individuals to apply for access to information held about them, and for authorised individuals, information held about other people. This policy is written in conjunction with the following government legislation:
- The Access to Health Records Act 1990
- The Access to Medical Reports Act 1988
- The General Data Protection Regulation
- The Data Protection Act 2018
- The Freedom of Information Act 2000
- The Data Protection (Subject Access Modification) (Health) Order 2000
This document and any procedures contained within it are contractual and therefore form part of your contract of employment. Employees will be consulted on any modifications or change to the document’s status.
Training and support
The practice will provide guidance and support to help those to whom it applies understand their rights and responsibilities under this policy. Additional support will be provided to managers and supervisors to enable them to deal more effectively with matters arising from this policy.
Who it applies to
This document applies to all employees of the practice and other individuals performing functions in relation to the practice, such as agency workers, locums and contractors.
Why and how it applies to them
In accordance with the General Data Protection Regulation individuals have the right to access their data and any supplementary information held by Grosvenor House Surgery; this is commonly known as a data subject access request (DSAR). Data subjects have a right to receive:
- Confirmation that their data is being processed
- Access to their personal data
- Access to any other supplementary information held about them
This policy will outline the procedure to access health records at Grosvenor House Surgery as follows:
- For an individual, for information about themselves
- For access to the health records of a deceased individual
- Access to health records of an individual by an authorised person (by a court), when the individual does not have the capacity to make such a decision
- Organisations requesting information about an individual for employment or insurance purposes (governed by The Access to Medical Reports Act 1988)
The practice aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have in regard to the individual protected characteristics of those to whom it applies.
Right to access
In accordance with the Access to Health Records Act 1990 individuals have the right to access health records held by a healthcare provider that has treated that individual, and/or to access a summary care record (SCR) created by the individual’s GP. The Data Protection Act (DPA 1998) gives individuals the right to ask for a copy of the information an organisation holds about them; this right is commonly known as a Data Subject Access Request (DSAR). In the case of health records, a request for information has to be made with the organisation that holds the individual’s health records, otherwise known as the data controller.
Grosvenor House Surgery has mechanisms in place to inform patients of their right to access the information held about them, and how long it will take for a DSAR process to be completed.
With effect from April 2016, NHS practices are, as part of their contractual obligation, to provide patients with access to coded information held within their health records. Such information includes:
- Other (ethnicity, QOF, etc.)
NHS England have published an information leaflet Patient Online which provides further detailed information about this obligation and how patients can access their health record online.
There are occasions when a GP may firmly believe that it is not appropriate to share all the information contained in the individual’s record, particularly if there is potential for such information to cause harm or distress to individuals, or when the record has information relating to a third party.
Patients may request paper copies of health records and, regardless of the preferred method of access, patients and authorised third parties must initially complete a DSAR form. However, patients may request access to their health records informally; any such requests should be annotated within the individual’s health record by the clinician dealing with the patient.
Requests may be received from the following:
Competent patients may apply for access to their own records or authorise third-party access to their records.
Children and young people may also apply in the same manner as other competent patients and Grosvenor House Surgery will not automatically presume a child or young person has capacity under the age of 16. However, those aged 12 or over are expected to have the capacity to consent to medical information being disclosed.
Parents may apply to access their child’s health record so long as it is not in contradiction to the wishes of the competent child.
Individuals with a responsibility for adults who lack capacity are not automatically entitled to access the individual’s health records. Grosvenor House Surgery will ensure that the patient’s capacity is judged in relation to particular decisions being made. Any considerations to nominate an authorised individual to make proxy decisions for an individual who lacks capacity will comply with the Mental Capacity Act in England and Wales and the Adults with Incapacity Act Scotland.
Next of kin have no rights of access to health records.
Police are not able to access health records without first obtaining a court order or warrant. However, health professionals at Grosvenor House Surgery may disclose relevant information to the police if the patient has consented or if there is overriding public interest. For detailed information, see section 4.1.6 of footnote 2.
Solicitors and insurance companies in most cases will provide the patient’s signed consent to release information held in their health record. Grosvenor House Surgery will ensure that patients are fully aware of the information being provided to the solicitor who is acting for that patient. In the case of a solicitor requesting information, the BMA has provided the following templates:
- Consent form to release information to solicitors in England & Wales
- Consent form to release information to solicitors in Scotland
Grosvenor House Surgery will ask solicitors to use the appropriate form when requesting information.
Deceased patients retain the right of confidentiality. There are a number of considerations to be taken into account prior to disclosing the health record of a deceased patient. Such considerations are detailed in the Access to Health Records Act 1990. Under the terms of this Act, Grosvenor House Surgery will only grant access if you are either:
- a personal representative (executor of the deceased person’s estate), or
- someone who has a claim resulting from the death
The medical records of the deceased will be passed to Primary Care Support England (PCSE) for storage. Grosvenor House Surgery can advise you of who you need to contact in such instances. PCSE will retain the GP records of deceased patients for ten years, after which time they will be destroyed. PCSE have provided an application form which can be used to request copies of a deceased patient’s record.
In the cases of any third-party requests, Grosvenor House Surgery will ensure that the patient has consented to the disclosure of this information by means of a valid signature of the patient.
In accordance with the GDPR, patients are entitled to receive a response within the maximum given time frame of one calendar month from the date of submission of the DSAR. In order to ensure full compliance regarding DSARs, Grosvenor House Surgery will adhere to the guidance provided in the GDPR. In the case of complex or multiple requests, the data controller may extend the response time by a period of two months. In such instances, the data subject must be informed and the reasons for the extension given.
Under The Data Protection (Subject Access Modification) (Health) Order 2000, Grosvenor House Surgery will ensure that an appropriate healthcare professional manages all access matters. At Grosvenor House Surgery there are a number of such professionals, and wherever possible the individual most recently involved in the care of the patient will review and deal with the request. If for some reason they are unable to manage the request, an appropriate professional will assume responsibility and manage the access request.
Furthermore, to maintain GDPR compliance, the data controller at Grosvenor House Surgery will ensure that data is processed in accordance with Article 5 of the GDPR and will be able to demonstrate compliance with the regulation (see GDPR policy for detailed information). Data processors at Grosvenor House Surgery will ensure that the processing of personal data is lawful and at least one of the following applies:
- The data subject has given consent to the processing of his/her personal data for one or more specific purposes
- Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract
- Processing is necessary for compliance with a legal obligation to which the controller is subject
- Processing is necessary in order to protect the vital interests of the data subject or another natural person
Procedure for access
A DSAR form (Annex A) must be completed and passed to the data controller; all DSARs should be processed free of charge unless they are either complex, repetitive or unfounded (see GDPR Policy). The GDPR states that data subjects should be able to make access requests via email. Grosvenor House Surgery is compliant with this and data subjects can complete an e-access form and submit the form via email.
Upon receipt of a DSAR Grosvenor House Surgery will record the DSAR within the health record of the individual to whom it relates, as well as annotating the DSAR log (template provided at Annex B). Furthermore, once processed, an entry onto the health record should be made, including the date of postage or the date the record was collected by the patient or authorised individual.
Individuals will have to verify their ID at Grosvenor House Surgery and it is the responsibility of the data controller to verify all requests from data subjects using reasonable measures. The use of the practice’s Data Subject Access Request (DSAR) form supports the data controller in verifying the request. In addition, the data controller is permitted to ask for evidence to identify the data subject, usually by using photographic identification, i.e. a driving licence or passport.
The process upon receipt of a DSAR form is clearly illustrated at Annex C, which is an aide-memoire/flow diagram.
Additional Privacy Information notice
Once the relevant information has been processed and is ready for issue to the patient, it is a requirement, in accordance with Article 15 of the General Data Protection Regulation (GDPR), to provide an Additional Privacy Information notice (APIn), the template for which can be found at Annex E.
Third-party requests will continue to be received following the introduction of the GDPR. The data controller must be able to satisfy themselves that the person requesting the data has the authority of the data subject.
The responsibility for providing the required authority rests with the third party and is usually in the form of a written statement or consent form, signed by the data subject.
Having a robust system in place will ensure that access to health records is given only to authorised personnel. Patient confidentiality is of the utmost importance and any third-party requests must be accompanied by a valid patient signature. Staff are to adhere to this guidance at all times and where doubt exists, they are to discuss their concerns Grosvenor House Surgery.
Please see… https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/
Access to medical records policy inc SAR – inc. forms
 How do I access my medical records (health records)? http://www.nhs.uk/chq/pages/1309.aspx?categoryid=68
 Access to health records
 Parental responsibility
 Good Practice Guidance on ID Verification
The Surgery prides itself in maintaining professional standards. For certain examinations during consultations an impartial observer (a “Chaperone”) will be offered.
This impartial observer will be a practice Nurse or Health Care Assistant who is familiar with the procedure and be available to reassure and raise any concerns on your behalf. If a nurse in unavailable at the time of your consultation then your examination may be re-scheduled for another time.
You are free to decline any examination or chose an alternative examiner or chaperone. You may also request a chaperone for any examination or consultation if one is not offered to you. The GP may not undertake an examination if a chaperone is declined.
The role of a Chaperone:
- Maintains professional boundaries during intimate examinations.
- Acknowledges a patient’s vulnerability.
- Provides emotional comfort and reassurance.
- Assists in the examination.
- Assists with undressing patients, if required.
Child Safeguarding is the responsibility of all everybody and is highly regarded at the Surgery. We make every effort to recognise issues and address as they occur in the practice. By raising safeguarding children issues within the practice all staff will be aware of how they may access advice, understand their role in protection, and understand the importance of effective Inter-agency communication.
It is very important that all Practice staff understand the need for early identification, assessment and intervention when they have concerns about a child. Case discussion and reflective practice is encouraged. Child protection issues in general practice require a robust system of note-keeping and recording, message handling and communication of any concerns.
Key Factors to be aware of in safeguarding children
- The welfare of the child is paramount
- Be prepared to consult with colleagues
- Be prepared to take advice from local experts
- Keep comprehensive, clear, contemporaneous records
- Be aware of GMC guidance about sharing confidential information
Risk Factors and Identification – Child Sexual Exploitation
A child in need is defined as a child whose vulnerability is such that they are unlikely to reach or maintain a satisfactory level of health or development without the provision of services (section 17, Children’s Act 1989). This includes disabled children. The Children’s Acts 1984 and 2004 define a child as someone who has not reached their 18th birthday. The fact that a child has reached their 16th birthday and may be living independently, working, or be members of the armed forces does not remove their childhood status under the Acts.
Local authority social services departments working with other local authority departments and health services have a duty to safeguard and promote the welfare of children in their area who are in need. If you are considering making a referral to Social Services as a child in need, it is essential to discuss the referral with the child’s parents or carers and to obtain consent for the sharing of information. Social Services will then follow local procedures to undertake an assessment of the child and their family.
Child Protection Plan
Children judged to be at continuing risk have a child protection plan in place, this list is maintained by children’s social care (CSC).CSC, police and health professionals have 24 hour access to this. A child on the register has a “key worker” to whom reference can be made.
Recognising Child Abuse
(for full details please ref to Working Together to Safeguard Children 2013)
There are 4 main categories of child abuse:
- Physical abuse
- Sexual abuse
- Emotional abuse
- Neglect/failure to thrive
These are not however exclusive, and a number of abuse types can often coexist.
Physical abuse may include:
Injuries in children under 1 years of age or non-mobile children should be treated with a high degree of care
- Hitting, shaking, throwing, poisoning, burning or scalding, or other forms of physical harm
- Where a parent or carer deliberately causes ill-health of a child
- Single traumatic events or repeated incidents
Sexual abuse may include:
- Forcing or enticing a child under 18 to take part in sexual activities where the child is unaware of what is happening
- May include both physical contact acts and non—contact acts
Emotional abuse may include:
- Persistent ill-treatment which has an effect on emotional development
- Conveyance of a message of being un-loved, worthlessness or inadequacy
- May instill a feeling of danger, being afraid
- May involve child exploitation or corruption
- Living in families where domestic violence is taking place
Neglect may include:
- Failure to meet the child’s physical or psychological needs
- Failure to provide adequate food or shelter
- Failure to protect from physical harm
- Neglect of a child’s emotional needs
Common presentations and situations in which child abuse may be suspected include:
- Disclosure by a child or young person
- Physical signs and symptoms giving rise to suspicion of any category of abuse
- The history is inconsistent or changes
- A delay in seeking medical help
- Extreme or worrying behaviour of a child, taking account of the developmental age of the child
- Accumulation of minor incidents giving rise to a level of concern, including frequent A&E attendances
Some other situations which need careful consideration are:
- Disclosure by an adult of abusive activities
- Girls under 16 presenting with pregnancy or sexually transmitted disease, especially those with learning difficulties
- Very young girls requesting contraception, especially emergency contraception
- Situations where parental mental health problems may impact on children
- Parental/ carer alcohol, drug or substance misuse which may impact on children
- Parents with learning difficulties
- Violence or domestic abuse in the family (please see separate document in safeguarding folder on domestic violence)
- Acuminous separation of parents with alleged allegation
If you have any special needs please let our staff know so that we can help and ensure you get the same support in the future.
Wheelchair access is available at the front of the surgery and we have toilets for the disabled.
Disabled Parking – Blue Badge Scheme
The Blue Badge scheme is for people with severe mobility problems. It allows Blue Badge holders to park close to where they need to go.
We have a loop induction system at the reception desk to assist the hearing impaired. For more information on the loop hearing system visit Hearing Link website.
- British Deaf Association
- The Deaf Health Charity – SignHealth
- Action Hearing Loss
- Royal Association for Deaf People
- National Deaf Children’s Society
If you or family members are blind or partially sighted we can give you a CD or large print of our practice leaflet upon request. Please ask Reception for further information.
For more advice and support for blind people please see the following websites:
- Royal National Institute of Blind People (RIND)
- British Wireless for the Blind Fund
- British Blind Sport
Guide dogs are welcome at the surgery but we ask that you be aware of other patients and staff who may have an allergy or fear of dogs.
Other Disability Websites
Fair Processing Notice
The Fair Processing Notice is intended to inform you about the type of patient information that GP Practices hold, how that information might be used, with whom we may share that information, and how we ensure it is kept secure.
Fair Processing Notice
- Fair Processing Notice
- Fair Processing Notice – Whole Systems Integrated Care
- “Sharing Vaccination Data during the COVID Pandemic:
During the COVID pandemic we have signed an agreement with our Local Authorities to allow trained Public Health personnel access to a limited amount of patient information. This has been restricted to the contact details of North West London patients over 50 years old, who do not live in the Grenfell area, who are eligible for but have not received COVID vaccination. The purpose is to provide those patients with direct care and to save lives by increasing the update of COVID vaccination. The legal basis for sharing is the short term COPI legislation (introduced by the secretary of state for health for just this purpose) and when the COPI legislation expires the data will be deleted. We have taken measures to ensure this data is safely transmitted and managed securely and that PH personnel are trained to understand their professional responsibilities of confidence.”
- Whole Systems dashboard programme – healthiernorthwestlondon.nhs.uk
- Your Personal information Choices – content.digital.nhs.uk/yourinfo
- How information is used – content.digital.nhs.uk/article
- Review of health and care data security and consent – www.gov.uk
- Records management code of practice for health and social care – www.gov.uk
- Fair Processing NHS England – www.england.nhs.uk
- The information Governance Review – www.gov.uk
- NHS Choices – Your health and care records – www.nhs.uk
Feedback and Complaints
We aim to provide you with the best possible medical service. At times you may feel that we have not achieved this and want to make your feelings known. Most problems can be sorted out quickly and easily, often at the time they arise with the person concerned and this may be the approach you try first.
Where you are not able to resolve your complaint in this way and wish to make a formal complaint you should do so, preferably within writing, as soon as possible after the event and ideally within a few days as this helps us to establish what happened more easily.
The period for making a complaint is normally:
- 12 months from the date on which the event which is the subject of the complaint occurred or
- 12 months from the date on which the event which is the subject of the complaint comes to the complainant’s notice.
If you are a registered patient you can complain about your own care. You are unable to complain about someone else’s treatment without their written authority. We are able to provide you with a separate complaints form to register your complaint and this includes a third-party authority form to enable a complaint to be made by someone else. Please ask at reception for this. You can provide this in your own format if you wish.
Please leave feedback online or send your written complaint to:
- Practice Management, Grosvenor House Surgery, 147 Broadway, London, W13 9BE
Complaining on Behalf of Someone Else
We keep to the strict rules of medical and personal confidentiality. If you wish to make a complaint but are not the patient involved, we will require the written consent of the patient to confirm that they are unhappy with their treatment and that we can deal with someone else about it. Please ask at reception for the complaints form which includes a statement of authority that the patient can sign. Where the patient is incapable of providing consent due to illness or accident it may still be possible to deal with the complaint. Please provide the precise details of the circumstances which prevent this in your covering letter. Please note that we are unable to discuss any issue relating to someone else without their express permission, which must be in writing, unless the above circumstances apply.
All complaints must be treated in the strictest confidence.
Where the investigation of the complaint requires consideration of the patient’s medical records, the Practice Manager must inform the patient or person acting on his or her behalf if the investigation will involve disclosure of information contained in those records to a person other than the practice or an employee of the practice.
The practice must keep a record of all complaints and copies of all correspondence relating to complaints but such records must be kept separate from patients’ medical records.
The practice has an annual review of complaints received within the year and the learning issues or changes to procedures which have arisen are documented.
Freedom of Information
The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:
- Have a publication scheme in place
- Allow public access to information held by public authorities.
The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.
Public authorities include government departments, local authorities, the NHS, state schools and police forces.
The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.
The Surgery publication scheme
A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:
- who we are and what we do
- what we spend and how we spend it
- what our priorities are and how we are doing it
- how we make decisions
- our policies and procedures
- lists and registers
- the services we offer
You can request our publication scheme leaflet at the surgery.
Who can request information?
Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use.
How should requests be made?
- be made in writing (this can be electronically e.g. email/fax)
- state the name of the applicant and an address for correspondence
- describe the information requested.
What cannot be requested?
Personal data about staff and patients covered under Data Protection Act.
For more information see these websites:
All GP Practices are required to declare mean earnings (i.e. average pay) for GPs working to deliver NHS services to patients at each practice.
The average pay for GPs working in the practice of Grosvenor House Surgery in the last financial year was £59,033 before tax and National Insurance.
This is for 2 full time GPs, 1 part time GP and 2 locum GPs who worked in the practice for more than six months.
GP2GP – The Electronic Transfer of Patient Records
By the end of March 2015 your GP practice will able to send computer held patient records electronically to a patient’s new surgery so they arrive much quicker than the paper notes, helping the doctors and nurses know the best way to treat you. This is called the GP2GP electronic transfer of patient records. The paper notes will continue to be sent via an NHS delivery service.
With GP2GP, your medical record is available to your new doctor within a few minutes of registration, enabling much safer care.
For more information about GP2GP visit the HSCIC website.
How we use your information
- We collect and hold data about you for the purpose of providing safe and effective healthcare
- Your information may be shared with our partner organisations to audit services and help provide you with better care
- Information sharing is subject to strict agreements on how it is used
- We will only share your information outside of our partner organisations with your consent*
- If you are happy with how we use your information you do not need to do anything
- If you do not want your information to be used for any purpose beyond providing your care please let us know so we can code your record appropriately
- You can object to sharing information with other health care providers but if this limits your treatment options we will tell you
- Our guiding principle is that we are holding your information in the strictest confidence
- For more information about who are our partner organisations and how your data is used please see the privacy notice on our website or ask at reception
*Unless the health & safety of others is at risk, the law requires it or it is required to carry out a statutory function
Infection Control Statement
We aim to keep our surgery clean and tidy and offer a safe environment to our patients and staff. We are proud of our modern, purpose built Practice and endeavour to keep it clean and well maintained at all times.
If you have any concerns about cleanliness or infection control, please report these to our Reception staff.
Our GPs and nursing staff follow our Infection Control Policy to ensure the care we deliver and the equipment we use is safe.
We take additional measures to ensure we maintain the highest standards:
- Encourage staff and patients to raise any issues or report any incidents relating to cleanliness and infection control. We can discuss these and identify improvements we can make to avoid any future problems.
- Carry out an annual infection control audit to make sure our infection control procedures are working.
- Provide annual staff updates and training on cleanliness and infection control
- Review our policies and procedures to make sure they are adequate and meet national guidance.
- Maintain the premises and equipment to a high standard within the available financial resources and ensure that all reasonable steps are taken to reduce or remove all infection risk.
- Use washable or disposable materials for items such as couch rolls, modesty curtains, floor coverings, towels etc., and ensure that these are laundered, cleaned or changed frequently to minimise risk of infection.
- Make Alcohol Hand Rub Gel available throughout the building
We have allocated a Named Accountable GP for all of our registered patients.
If you do not know who your named GP is, please ask a member of our reception team.
Unfortunately, we are unable to notify patients in writing of any change of GP due to the costs involved.
What is non-NHS work and why is there a fee?
The National Health Service provides most health care to most people free of charge, but there are exceptions: prescription charges have existed since 1951 and there are a number of other services for which fees are charged.
Sometimes the charge is because the service is not covered by the NHS, for example, providing copies of health records or producing medical reports for insurance companies, solicitors or employers.
The Government’s contract with GPs covers medical services to NHS patients but not non-NHS work. It is important to understand that many GPs are not employed by the NHS; they are self-employed and they have to cover their costs – staff, buildings, heating, lighting, etc. – in the same way as any small business.
In recent years, however, more and more organisations have been involving doctors in a whole range of non-medical work. Sometimes the only reason that GPs are asked is because they are in a position of trust in the community, or because an insurance company or employer wants to ensure that information provided to them is true and accurate.
Examples of non-NHS services for which GPs can charge their own NHS patients are:
- accident/sickness certificates for insurance purposes
- school fee and holiday insurance certificates
- reports for health clubs to certify that patients are fit to exercise
- private prescriptions for travel purposes
Examples of non-NHS services for which GPs can charge other institutions are:
- life assurance and income protection reports for insurance companies
- reports for the Department for Work and Pensions (DWP) in connection with
- disability living allowance and attendance allowance
- medical reports for local authorities in connection with adoption and fostering
- copies of records for solicitors
Do GPs have to do non-NHS work for their patients?
With certain limited exceptions, for example a GP confirming that one of their patients is not fit for jury service, GPs do not have to carry out non-NHS work on behalf of their patients. Whilst GPs will always attempt to assist their patients with the completion of forms, they are not required to do such non-NHS work.
Is it true that the BMA sets fees for non-NHS work?
The British Medical Association (BMA) suggest fees that GPs may charge their patients for non-NHS work (i.e. work not covered under their contract with the NHS) in order to help GPs set their own professional fees. However, the fees suggested by them are intended for guidance only; they are not recommendations and a doctor is not obliged to charge the rates they suggest.
Why does it sometimes take my GP a long time to complete my form?
Time spent completing forms and preparing reports takes the GP away from the medical care of his or her patients. Most GPs have a very heavy workload and paperwork takes up an increasing amount of their time. Our GPs do non-NHS work out of NHS time at evenings or weekends so that NHS patient care does not suffer.
I only need the doctor’s signature – what is the problem?
When a doctor signs a certificate or completes a report, it is a condition of remaining on the Medical Register that they only sign what they know to be true. In order to complete even the simplest of forms, therefore, the doctor might have to check the patient’s ENTIRE medical record. Carelessness or an inaccurate report can have serious consequences for the doctor with the General Medical Council (the doctors’ regulatory body) or even the Police.
If you are a new patient we may not have your medical records so the doctor must wait for these before completing the form.
What will I be charged?
It is recommended that GPs tell patients in advance if they will be charged, and what the fee will be. It is up to individual doctors to decide how much they will charge. The surgery has a list of fees based on these suggested fees which is available on request.
What can I do to help?
- Not all documents need a signature by a doctor, for example passport applications. You can ask another person in a position of trust to sign such documents free of charge. Read the information that comes with these types of forms carefully before requesting your GP to complete them.
- If you have several forms requiring completion, present them all at once and ask your GP if he or she is prepared to complete them at the same time to speed up the process.
- Do not expect your GP to process forms overnight: urgent requests may mean that a doctor has to make special arrangements to process the form quickly, and this may cost more. Usually non-NHS work will take 2 weeks.
The practice complies with the Data Protection Act. All information about patients is confidential: from the most sensitive diagnosis, to the fact of having visited the surgery or being registered at the Practice. All patients can expect that their personal information will not be disclosed without their permission except in the most exceptional of circumstances, when somebody is at grave risk of serious harm.
All members of the primary health care team (from reception to doctors) in the course of their duties will have access to your medical records. They all adhere to the highest standards of maintaining confidentiality.
As our reception area is a little public, if you wish to discuss something of a confidential nature please mention it to one of the receptionists who will make arrangements for you to have the necessary privacy.
The duty of confidentiality owed to a person under 16 is as great as the duty owed to any other person. Young people aged under 16 years can choose to see health professionals, without informing their parents or carers. If a GP considers that the young person is competent to make decisions about their health, then the GP can give advice, prescribe and treat the young person without seeking further consent.
However, in terms of good practice, health professionals will encourage young people to discuss issues with a parent or carer. As with older people, sometimes the law requires us to report information to appropriate authorities in order to protect young people or members of the public.
Your information, what you need to know
This privacy notice explains why we collect information about you, how that information may 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. These records help to provide you with the best possible healthcare and help us to protect your safety.
We collect and hold data for 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 may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form.
The records may include basic details about you, such as your name and address. They may 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 GP Practice may hold about you include the following:
- Details about you, such as your address and next of kin
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments,
- Notes and reports about your health
- Details about your treatment and care
- Results of investigations, such as laboratory tests, x-rays,
- Relevant information from other health professionals, relatives or your carers
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.
The health records we use may 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 Act 2018
- 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 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 may choose to opt-out to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website 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 which will not affect your entitlement to care, but you 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.
Child Health Information
We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS CLCH health visitors and school nurses, and with NEL Commissioning Support Unit, who provide the Child Health Information Service on behalf of NHS England.
Information may be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.
Sometimes anonymised data may be used for research purposes – but we will always ask your permission before releasing any information for this purpose which could be used to identify you.
In some instances, the Confidentially Advisory Group, part of the Health Research Authority may allow for identifiable information to be shared with researchers without consent of individuals. You may however opt-out of this, details of which can be found below under the ‘National Data Opt-Out’.
Improving Diabetes Care and long-term condition management
Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led local diabetes and long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.
Individual Funding Request
An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for funding of specialised healthcare which falls outside the range of services and treatments that CCG has agreed to commission for the local population. An Individual Funding Request is taken under consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.
Invoice validation is an important process. It involves using your NHS number to check 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.
NHS England and Open Exeter
NHS England has a legal duty to keep a list of all patients registered with GP Practices in England. This list is held in the National Health Application and Infrastructure Services (NHAIS) systems. These systems also hold data about patients registered with GPs in Wales and the Isle of Man. NHS Digital, and other service agencies around the country manage these systems on behalf of NHS England.
The data are used to provide Primary Care Support Services. NHS England has a contract with Capita Business Services Ltd, operating as Primary Care Support England to provide these services which include:
- Moving paper patient records between practices and into storage when patients leave or move practices
- Storing paper records of unregistered and deceased patients
- Sending letters to patient to inform them of their NHS number when one is first allocated
- Providing the cervical cytology call and recall administrative service on behalf of Public Health England
- delivering prior notification lists of patients eligible for screening to GPs
- processing new patient registrations and de-registrations at GP practices to maintain accurate lists of numbers of patients at GP Practices–
- Making payments to NHS Ophthalmic practitioners for NHS services provided
- Making payments to GP practices based on lists of registered patients, and specific payments for childhood vaccinations and immunisations
- Writing to patients on behalf of Primary Care commissioners with regards to provision of primary care services or assignment to a GP Practice list.
- Writing to patients when they have been removed from their GP Practice list
- Conducting audits and reconciliations of GP Practice lists to ensure list sizes are accurate.
The data from the NHAIS list is used to update the Personal Demographics Service (PDS). This provides information for hospitals, Public Health England Cancer Screening Programmes, Child Health systems and other health providers making sure that they know their patients’ current GP Practice and can access other essential information such as the Summary Care Record.
NHS England Regional Local Teams (RLTs) and Clinical Commissioning Groups (CCGs) (where delegated) may also undertake necessary processing of a limited subset of these data (e.g. patient name, address, postcode and NHS number) for example when managing practice closures and list dispersals (the process used to allocate patients to neighbouring GP Practices). This processing is necessary to inform patients of their reregistration options and ‘Choice’ as required under the NHS Constitution.
Sources of the data: The data are transferred automatically from GP practice systems in to the NHAIS systems. The data is also updated by Primary Care Support England after notifications from data subjects themselves.
The categories of personal data held on the systems are:
- Name – including any previous names, unless name changes are the result of adoption, gender reassignment or witness protection schemes
- Current and historic addresses and whether the address is a registered nursing home
- Dates of Birth
- Place of Birth
- NHS number
- Cervical Screening history
- Special allocation scheme status
- Current and Previous GP practice details
- GPs Banking details
Categories of recipients: Statistical information (numbers) produced from NHAIS systems is shared with other organisations to enable them to fulfil their statutory obligations, for example the Office of National Statistics, Public Health England and local authorities for their public health purposes. Personal data may also be shared with the approval of NHS England’s Caldicott Guardian when he is assured that confidentiality is respected, for example when hospitals need to update their records for direct care purposes or to support specific research projects with ethical and or Health Research Authority approval.
Legal basis for processing: For GDPR purposes NHS England’s basis for lawful processing is Article 6(1)(e) – ‘…exercise of official authority…’. For special categories (health) data the basis is Article 9(2)(h) – ‘…health or social care…’
For more details relating to patient information available to NHSE se their privacy notice:
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 local health or care professional outside of your usual practice services, such as in an Evening and Weekend GP HUB services, 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 some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent.
Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or EMIS remote consulting system).
In all cases, your information is only accessed and used by authorised staff 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).
Enhanced Data Sharing Module for practices using TPP SystmOne
If your Practice uses the TPP SystmOne software, you can choose whether other health and care providers can access your information to help provide you with care. We have drawn up an “allowed list” of local organisations with whom we can share your data (when you register for their services and give them verbal permission to provide your care through a TPP clinical system). See the link below under Who are our partner organisations.
If your GP uses SystmOne clinical software, organisations outside of this allowed group who use the same software will require formal documented permission to see your records. Your GP system will send you an SMS or email which you can give to the organisation asking for access which will formally validate your consent.
It is possible for you to set your own specific permissions (as distinct from the allowed list we have provided). More information about this, and how to do so, can be found here. eDSM enhancements_Patient Quick Start Guide v.1.0 – Sharing Poster GP
Cloud Based Hosting for EMIS practices
From 10 June 2019 EMIS Web started migrating practice patient data storage to Amazon Web Services (AWS). The security and governance arrangements for this service have been scrutinised and a Data Protection Impact Assessment (DPIA) has been undertaken on behalf EMIS practices which can be obtained through those practices.
Grosvenor House Surgery does not use EMIS.
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 the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see:
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.
‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.
Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health.
Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the NWL Clinical Commissioning Groups. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from: https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification /
If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.
To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.
Summary Care Record (SCR)
The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.
Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.
Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, fax or phone. If you wish to opt- out of having an SCR please return a completed opt-out form to the practice.
Supporting Medicines Management
NWL CCGs use pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the CCG medicines management team may provide relating to obtaining medications on behalf of your GP Practice to support your care.
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 may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital NHS Foundation Trust, London North West Healthcare NHS Trust and University College London Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual patients.
We manage patient records in line with the records-management-cop-hsc-2016 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
- Independent Contractors such as dentists, opticians, pharmacists
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services
- Local Authorities
- Education Services
- Fire and Rescue Services
- Other ‘data processors’
Specific details of the organisations with which we share your data can be seen here.
We will not share your full information outside of health partner organisations without your 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. No information will ever be shared where we do not have a lawful basis to do so.
Within the health partner organisations providing your care (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – your information will 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. 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 notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence.
Primary Care Network
We are a member of South Central Ealing Primary Care Network (PCN). This means we will be working closely with a number of other Practices and health and care organisations to provide healthcare services to you.
During the course of our work we may share your information with these Practices and health care organisations/professionals. We will only share this information where it relates to your direct healthcare needs.
When we do this, we will always ensure that appropriate agreements are in place to protect your information and keep it safe and secure. This is also what the Law requires us to do.
If you would like to see the information the PCN holds about you please contact the – NWL DPO SERVICE [email protected]
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. No information will ever be shared where we do not have a lawful basis to do so.
Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to 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. 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 notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence.
Right to withdraw consent to share 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.
There are two main types of opt-out.
Type 1 Opt-Out
If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. Please talk to a member of staff at your Practice to initiate the type 1 opt-out.
National Data Opt-Out
NHS Digital have created a new opt-out system named the National Data Opt-Out which allows individuals to opt-out of their information being used for planning and research purposes. From 25 May 2018, NHS Digital has had to apply this opt-out for all their data flows, and from 2020 all health and care organisations will have to ensure the opt-out is respected. Individuals who previously opted out with a ‘Type 2’ objection will not have to do anything as you will be automatically be opted out.
If you wish to apply the National Opt-Out, please go to NHS Digitals website here https://www.nhs.uk/your-nhs-data-matters/
Access to your information
Under the Data Protection Act 2018 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 or speak to a member of staff at the practice. Under special circumstances, some information may be withheld.
If you wish to have a copy of the information we hold about you, please contact:
Dr Ramulu Dasoju [email protected]
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.
The Data Protection Act 2018 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.
If you have concerns or are unhappy about any of our services, please contact the Practice Manager Ms. K Psilllakis [email protected]
For independent advice about data protection, privacy and data-sharing issues, you can contact:
The Information Commissioner,
Wilmslow, Cheshire SK9 5AF
Phone: 0303 123 1113
Information we are required to provide you
|Data Controller contact
|Grosvenor House Surgery, 147 Broadway, London W13 9BE
|Data Protection Officer contact details
|NWL DPO SERVICE <[email protected]>|
|Purpose of the processing for the provision of your healthcare
|· To give direct health or social care to individual patients.
· For example, when a patient agrees to a referral for direct care, such as to a hospital, relevant information about the patient will be shared with the other healthcare staff to enable them to give appropriate advice, investigations, treatments and/or care.
· To check and review the quality of care. (This is called audit and clinical governance).
|Lawful basis for processing
for the provision of your healthcare
|These purposes are supported under the following sections 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…’; and
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…”
Healthcare staff will also respect and comply with their obligations under the common law duty of confidence.
|Purpose of the processing for medical research and to measure quality of care||Medical research and to check the quality of care which is given to patients (this is called national clinical audit).|
|Lawful basis for processing for medical research and to measure the quality of care
|The following sections of the GDPR mean that we can use medical records for research and to check the quality of care (national clinical audits)
Article 6(1)(e) – ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’.For medical research: there are two possible conditions.
Article 9(2)(a) – ‘the data subject has given explicit consent…’
Article 9(2)(j) – ‘processing is necessary for… scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member States law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject’.To check the quality of care (clinical audit):
Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’
|Purpose of the processing to meet legal requirements||Compliance with legal obligations or court order.|
|Lawful basis for processing to meet legal requirements||These purposes are supported under the following sections of the GDPR:
Article 6(1)(c) – ‘processing is necessary for compliance with a legal obligation to which the controller is subject…’
Article 9(2)(g) – ‘processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject;
Schedule 1 part 2 of the Data Protection Act 2018 lists the substantial public interest conditions, of which paragraph 2 states data can be processed when the purpose is for the exercise of function conferred on a person by enactment or rule of law.
|Purpose of the processing for National screening programmes
|· The NHS provides several national health screening programmes to detect diseases or conditions early such as cervical and breast cancer, aortic aneurysm and diabetes.
· The information is shared so that the correct people are invited for screening. This means those who are most at risk can be offered treatment.
|Lawful basis for processing for National screening programmes
Lawful basis for processing for employment purposes
|The following sections of the GDPR allow us to contact patients for screening.
Article 6(1)(e) – ‘processing is necessary…in the exercise of official authority vested in the controller…’’
Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’The following sections of GDPR allow us to process staff data in an employment capacity
Article 6(1)(b) – ‘processing is necessary for compliance with a legal obligation’
Article 9(2)(b) – ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment … law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;’
|Rights to object
|· You have the right to object to information being shared between those who are providing you with direct care.
·This will not affect your entitlement to care, but this may affect the care you receive – please speak to the practice.
. Any objection will be reviewed by the Practice and a decision taken on whether to uphold the request. The right to object is not an absolute right.
. In appropriate circumstances it is a legal and professional requirement to share information for safeguarding reasons. This is to protect people from harm.
. The information will be shared with the local safeguarding service Ealing Borough Social Services – Children/Adults 0208 825 8000
|Right to access and correct||· You have the right to access your medical record and have any errors or mistakes corrected. Please speak to a member of staff or look at our ‘subject access request’ policy on this practice website
. You have the right to request rectification of your record if you believe information contained within it is wrong. Information will only be deleted in very exceptional circumstances. In most instances the original information will be retained on the record noting the rectified information.
|GP medical records will be kept in line with the law and national guidance. Information on how long records are kept can be found at: https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016|
|Right to complain
|You have the right to complain to the Information Commissioner’s Office. You may follow this link https://ico.org.uk/global/contact-us/ or call the helpline 0303 123 1113|
|Data we get from other organisations||We receive information about your health from other organisations who are involved in providing you with health and social care. For example, if you go to hospital for treatment or an operation the hospital will send us a letter to let us know what happens. This means your GP medical record is kept up-to date when you receive care from other parts of the health service.|
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 the Data Protection Act 2018.
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 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.
Reviews of and Changes to our Privacy Notice
We will keep our Privacy Notice under regular review. This notice was last reviewed in 1st June, 2021.
Privacy Notice – Transparency Statement
“How the NHS and care services use your information”
Grosvenor House Surgery is one of many organisations working in the health and care system to improve care for patients and the public.
Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment.
The information collected about you when you use these 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 where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
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 www.nhs.uk/your-nhs-data-matters.
On this web page you will:
- See what is meant by confidential patient information
- Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
- Find out more about the benefits of sharing data
- Understand more about who uses the data
- Find out how your data is protected
- Be able to access the system to view, set or change your opt-out setting
- Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
- See the situations where the opt-out will not apply
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and
https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care. Our organisation is currently’ compliant with the national data opt-out policy.
Privacy Statement Policy
As part of our legal duties, this practice is required to;
- Maintain full and accurate records of the care and services we provide you
- Keep records about you confidential and secure
The practice aims to provide you with safe, high quality care that is based on accurate, up to date information.
This information allows us to work others involved in your care and this may involve sharing information with other health and social care organisations.
- Basic details such as address, date of birth and next of kin
- Contact we have had with you
- Notes and reports about your health
- Details and records about your treatment and care
Others may also need to use records about you to:
- Check the quality of care you are receiving
- Protect the health of the general public
- Keep track of NHS spending
- Help investigate any concerns or complaints you ask us to
- Teach students or staff
- Support health and social care research
Sometimes we share your information with third parties to support your care such as:
- Social care
- Community Health
- Clinical Commissioning Groups
- Mental Health Providers
- NHS Digital
When we are sharing information to support third parties in providing your care, we will work hard to ensure it is the minimum necessary and that it is done so securely and lawfully. We aim to ensure that we only use your personal information in a way that you would reasonably expect.
When we share information that is used for healthcare management or planning, this does not allow for you to be identified.
Sometimes we will be required to share information for other reasons;
- When required to by law
- We have special permission for health or research purposes (e.g. if you have agreed to take part in a research trial)
- There is a strong public interest (e.g. there is a risk of serious harm or crime)
You can choose not to have information that could identify you shared beyond your GP practice. You can also choose to prevent information that does not identify you from being shared for planning and research.
Simply contact your GP either to register an opt-out or end an opt-out you have already registered and they will update your medical record. Your GP practice will also be able to confirm whether or not you have registered an opt-out in the past.
If you have previously told your GP practice that you don’t want NHS Digital to share your personal confidential information for purposes other than your own care and treatment, your opt-out will have been implemented by NHS Digital from 29th April 2016 as instructed in a direction from the Secretary of State. It will remain in place unless you change it.
As the Secretary of State’s direction; this included the policy on how to apply opt-outs was not available before April 2016 it was not possible for NHS Digital to honour opt-outs made before this date. This means that information may have been shared without respecting these opt-outs between January 2014 and April 2016.
You can find more information on NHS Digital’s website:
Under Data Protection law, you have a right to;
- object to certain uses of your data
- to be provided with a copy information held about you
- that your information will not be used for direct marketing purposes
- have any incorrect information amended or erased
Please contact your surgery for any requests made in connection with these rights.
For a copy of your information;
- Your request must be made in writing to your surgery
- The surgery is required to respond to your request in writing within 40 days (a month from May 2018)
- You will need to give the surgery your full name, address, date of birth and NHS number
- You will be required to provide personal identification such as a driving licence or passport
Use of the Website
Generally, our website will not require you to enter personal information. When it does, for example; online appointment booking, we will apply the same confidentiality principles as those described above.
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should be aware that we do not have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites.
We intend to protect the confidentiality, quality and integrity of your personal information and we have implemented appropriate technical and organisational measures to do so. These include staff training, up to date policies and procedures and working to align with national cyber security guidelines.
Statement of Intent
New contractual requirements came into force from 1 April 2014 requiring that GP Practices should make available a statement of intent in relation to the following IT developments:
- Summary Care Record (SCR)
- GP to GP Record Transfers
- Patient Online Access to Their GP Record
- Data for commissioning and other secondary care purposes
The same contractual obligations require that we have a statement of intent regarding these developments in place and publicised by 30 September 2014.
Please find below details of the practices stance with regards to these points.
Summary Care Record (SCR)
NHS England require practices to enable successful automated uploads of any changes to patient’s summary information, at least on a daily basis, to the summary care record (SCR) or have published plans in place to achieve this by 31st of March 2015.
Having your Summary Care Record (SCR) available will help anyone treating you without your full medical record. They will have access to information about any medication you may be taking and any drugs that you have a recorded allergy or sensitivity to.
Of course, if you do not want your medical records to be available in this way then you will need to let us know so that we can update your record. You can do this via the opt out form.
The practice confirms that your SCR is automatically updated on at least a daily basis to ensure that your information is as up to date as it can possibly be.
GP to GP Record Transfers
NHS England require practices to utilise the GP2GP facility for the transfer of patient records between practices, when a patient registers or de-registers (not for temporary registration).
It is very important that you are registered with a doctor at all times. If you leave your GP and register with a new GP, your medical records will be removed from your previous doctor and forwarded on to your new GP via NHS England. It can take your paper records up to two weeks to reach your new surgery.
With GP to GP record transfers your electronic record is transferred to your new practice much sooner.
The practice confirms that GP to GP transfers are already active and we send and receive patient records via this system.
Patient Online Access to Their GP Record
NHS England require practices to promote and offer the facility to enable patients online access to appointments, prescriptions, allergies and adverse reactions or have published plans in place to achieve this by 31st of March 2015.
We currently offer the facility for booking and cancelling appointments and also for ordering your repeat prescriptions and viewing a summary of your medical records on-line. If you do not already have a user name and password for this system – please register your interest with our reception staff.
Data for commissioning and other secondary care purposes
It is already a requirement of the Health and Social Care Act that practices must meet the reasonable data requirements of commissioners and other health and social care organisations through appropriate and safe data sharing for secondary uses, as specified in the technical specification for care data.
At our practice we have specific arrangements in place to allow patients to “opt out” of care.data which allows for the removal of data from the practice. Please see the page about care data on our website
The Practice confirm these arrangements are in place and that we undertake annual training and audits to ensure that all our data is handled correctly and safely via the Information Governance Toolkit.
Summary Care Records
About your Summary Care Record
Your Summary Care Record contains important information about any medicines you are taking, any allergies you suffer from and any bad reactions to medicines that you have previously experienced.
Allowing authorised healthcare staff to have access to this information will improve decision making by doctors and other healthcare professionals and has prevented mistakes being made when patients are being cared for in an emergency or when their GP practice is closed.
Your Summary Care Record also includes your name, address, date of birth and your unique NHS Number to help identify you correctly.
You may want to add other details about your care to your Summary Care Record. This will only happen if both you and your GP agree to do this. You should discuss your wishes with your GP practice.
Healthcare staff will have access to this information, so that they can provide safer care, whenever or wherever you need it, anywhere in England.
Who can see my Summary Care Record?
Healthcare staff who have access to your Summary Care Record:
- need to be directly involved in caring for you
- need to have an NHS Smartcard with a chip and passcode
- will only see the information they need to do their job and
- will have their details recorded every time they look at your record
Healthcare staff will ask for your permission every time they need to look at your Summary Care Record. If they cannot ask you (for example if you are unconscious or otherwise unable to communicate), healthcare staff may look at your record without asking you, because they consider that this is in your best interest.
If they have to do this, this decision will be recorded and checked to ensure that the access was appropriate.
What are my choices?
You can choose to have a Summary Care Record or you can choose to opt out.
If you choose to have a Summary Care Record and are registered with a GP practice, you do not need to do anything as a Summary Care Record is created for you.
If you choose to opt out of having a Summary Care Record and do not want a SCR, you need to let your GP practice know by filling in and returning an opt-out form (PDF, 245.9kB). Opt-out forms can be downloaded from the website or from your GP practice.
If you are unsure if you have already opted out, you should talk to the staff at your GP practice. You can change your mind at any time by simply informing your GP practice and either filling in an opt-out form (PDF, 245.9kB) or asking your GP practice to create a Summary Care Record for you.
Children and the Summary Care Record
If you are the parent or guardian of a child under 16, you should make this information available to them and support the child to come to a decision as to whether to have a Summary Care Record or not.
If you believe that your child should opt-out of having a Summary Care Record, we strongly recommend that you discuss this with your child’s GP. This will allow your child’s GP to highlight the consequences of opting-out, prior to you finalising your decision.
Where can I get more information?
For more information about Summary Care Records you can
- talk to the staff at your GP practice
- phone the Health and Social Care Information Centre on 0300 303 5678
- Read the Summary Care Record patient information
The Prevent Strategy
CONTEST, the Government’s national counter terrorism strategy, aims to reduce the risk to the United Kingdom and its interests overseas from international terrorism, so that people can go about their lives freely and with confidence.
The strategy has four main work streams:
- Pursue: to stop terrorist attacks
- Protect: to strengthen our protection against terrorist attack
- Prepare: where an attack cannot be stopped, to mitigate its impact
- Prevent: to stop people becoming terrorists or supporting terrorism
Prevent aims to stop people from becoming terrorists or supporting terrorism.
The Department of Health (DH) has worked with the Home Office to develop guidance for healthcare organisations to implement Prevent Locally; this is called “Building Partnerships Staying Safe”. With more than 1 million consultations a day by the NHS it is an area that the DH needs to highlight to all NHS workers.
The Prevent Strategy addresses all forms of terrorism, including extreme right wing views, but continues to prioritise according to the threat posed to our national security.
The aim of Prevent is to stop people from becoming terrorists or supporting terrorism and operates in the pre-criminal space before any criminal activity has taken place. At present, the majority of effort is focused on stopping people from joining or supporting such groups as Al-Qaida and its related groups, and other extremist organisations actively recruit.
The three key objectives of the Prevent Strategy are to:
- Challenge the ideology that supports terrorism and those who promote it.
- Prevent vulnerable people from being drawn into terrorism and ensure that they are given appropriate advice and support.
- Work with sectors and institutions where there are risks of radicalisation
(Health Organisations are expected to be involved in delivering objectives 2 and 3, only).
Why must health organisations engage in the Prevent Strategy?
The Department of Health is a key strategic partner in the Prevent Strategy as Healthcare professionals may meet and treat people who are vulnerable to radicalisation. People with mental health issues or learning disability may be more easily drawn into terrorism.
People Prevent is an on-going initiative and designed to become part of the everyday safeguarding routine for NHS staff.
It does not need new structures to be created but does require that members of staff are informed and have awareness of the Prevent Agenda and how to refer concerns.
Defination of Terms
- Terrorism is defined in the Terrorism Act of 2000 (TACT 2000) as an action that endangers or causes serious violence to a person or people, causes serious damage to property or seriously interferes or disrupts an electronic system. The use of threat must be designed to influence the government or to intimidate the public and is made for the purpose of political, religious or ideological gain.
- Radicalisation in this protocol refers to the process by which people come to support terrorism and forms of extremism leading to terrorism.
- Extremism: is vocal or active opposition to fundamental values including democracy, the rule of the law, individual liberty, and mutual respect and tolerance of different beliefs and faiths.
- A Prevent Concern does not have to be proven beyond reasonable doubt; it should however be based on something that raises concern which is assessed by using exiting professional judgement of a health or social care member of staff.
- Vulnerability in the context of Prevent is a person who is susceptible to extremists’ messages and is at risk of being drawn into terrorism or supporting terrorism at a point in time. The definition of vulnerable individual from No Secrets (2000) is “who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation”.
The local CCG should have polices in place and should advise practices of their obligations, however it is up to practices to decide when an issue needs to be reported on in the same way as Safeguarding Adults, Children and even Domestic violence.
Patient confidentiality is always key and so disclosing fears and suspicions have to be taken in a responsible manner weighing up the evidence and the person of concern.
The purpose of this document is to set out the policy of the Practice in relation to the protection of vulnerable adults. Further guidance may be available on local inter-agency procedures via the Primary Care Organisation and / or Social Services.
What is a vulnerable adult?
The definition is wide, however this may be regarded as anyone over the age of 18 years who may be unable to protect themselves from abuse, harm or exploitation, which may be by reason of illness, age, mental illness, disability or other types of physical or mental impairment.
Those at risk may live alone, be dependent on others (care homes etc.), elderly, or socially isolated.
Forms of Abuse
- Neglect – ignoring mental or physical needs, care, education, or basic life necessities or rights
- Bullying – family, carers, friends
- Financial – theft or use of money or possessions
- Sexual – assault, rape, non-consensual acts (including acts where unable to give consent), touching, indecent exposure
- Physical – hitting, assault, man-handling, restraint, pain or forcing medication
- Psychological – threats, fear, being controlled, taunts, isolation
- Discrimination – abuse based on perceived differences and vulnerabilities
- Institutional abuse – in hospitals, care homes, support services or individuals within them, including inappropriate behaviours, discrimination, prejudice, and lack of essential safeguards
Abuse may be deliberate or as a result of lack of attention or thought, and may involve combinations of all or any of the above forms. It may be regular or on an occasional or single event basis, however it will result in some degree of suffering to the individual concerned. Abuse may also take place between one vulnerable adult and another, for example between residents of care homes or other institutions.
- Apparent lack of personal care
- Nervousness or withdrawn
- Avoidance of topics of discussion
- Inadequate living conditions or confinement to one room in their own home
- Inappropriate controlling by carers or family members
- Obstacles preventing personal visitors or one-to-one personal discussion
- Sudden changes in personality
- Lack of freedom to move outside the home, or to be on their own
- Refusal by carers to allow the patient into further care or to change environs
- Lack of access to own money
- Lack of mobility aids when needed
Where abuse of a vulnerable adult is suspected the welfare of the patient takes priority. In deciding whether to disclose concerns to a third party or other agency the GP will assess the risk to the patient.
- Ideally the matter should be discussed with the patient involved first, and attempt made to obtain consent to refer the matter to the appropriate agency. Where this is not possible, or in the case of emergency where serious harm is to be prevented, the patient’s doctor will balance the need to protect the patient with the duty of confidentiality before deciding whether to refer.
- The patient should usually be informed that the doctor intends to disclose information, and advice and support should be offered.
- Where time permits, the medical defence organisation will be telephoned before any action is taken.
Due regard will be taken of the patient’s capacity to provide a valid consent.
In assessing the risk to the individual, the following factors will be considered:
- Nature of abuse, and severity
- Chance of recurrence, and when
- Vulnerability of the adult (frailty, age, physical condition etc.)
- Those involved – family, carers, strangers, visitors etc.
- Whether other third parties are also at risk (other members of the same household may being abused at the same time)
Subject to the local procedures in force, consideration will be given to;
- Report to Social Services Mental Health team
- Report to Police
- Report to PCT lead
|Police (local)||Ealing Police Station: 020 86493573
Or national police service: 999
|Community Mental Heath||Avenue House: 020 8483 1720
Out of Hour contact: 0300 1234244
|Adult Support Services/ Safeguarding Adult||020 8825 8000|
|Adult Support Services (out of hours)
Adult Protection Officer
|020 8825 5000|
|Age Concern||020 8567 8017|
|Social Services||020 8825 8000 / 020 8566 2360|
|MIND in Ealing||020 8992 0303|
|Ealing CAMHS||020 8354 8160|
|Drug Misuse||RISE: 020 8843 5900
020 8825 9888
|Medical Defence Organisation||MDU – via doctor/nurse or management membership details|
3rd Floor, Perceval House
14/16 Uxbridge Road
Ealing, W5 2HL
|020 8280 8080|
North West London Area Team
|020 7322 3700|
Your Rights and Responsibilities
We are committed to giving you the best possible service. This will be achieved by working together. Help us to help you. You have a right to, and the practice will try to ensure that:
- You will be treated with courtesy and respect
- You will be treated as a partner in the care and attention that you receive
- All aspects of your visit will be dealt with in privacy and confidence
- You will be seen by a doctor of your choice subject to availability
- In an emergency, out of normal opening hours, if you telephone the practice you will be given the number to receive assistance, which will require no more than one further call
- You can bring someone with you, however you may be asked to be seen on your own during the consultation
- Repeat prescriptions will normally be available for collection within two working days of your request
- Information about our services on offer will be made available to you by way of posters, notice boards and newsletters
- You have the right to see your medical records or have a copy subject to certain laws.
With these rights come responsibilities and for patients we would respectfully request that you:
- Treat practice staff and doctors with the same consideration and courtesy that you would like yourself. Remember that they are trying to help you
- Please ensure that you order your repeat medication in plenty of time allowing 2 working days.
- Please ensure that you have a basic first aid kit at home and initiate minor illness and self-care for you and your family.
- Please attend any specialist appointments that have been arranged for you or cancel them if your condition has resolved or you no longer wish to attend
- Please follow up any test or investigations done for you with the person who has requested the investigation
- Attend appointments on time and check in with Reception
- Patients who are more than 10 minutes late for their appointment may not be seen.
- If you are unable to make your appointment or no longer need it, please give the practice adequate notice that you wish to cancel. Appointments are heavily in demand and missed appointments waste time and delay more urgent patients receiving the treatment they need
- An appointment is for one person only. Where another family member needs to be seen or discussed, another appointment should be made
- Patients should make every effort to present at the surgery to ensure the best use of nursing and medical time. Home visits should be medically justifiable and not requested for social convenience
- Please inform us when you move home, change your name or telephone number, so that we can keep our records correct and up to date
- Read the practice leaflets and other information that we give you. They are there to help you use our services. If you do not understand their content please tell us
- Let us have your views. Your ideas and suggestions whether complimentary or critical are important in helping us to provide a first class, safe, friendly service in pleasant surroundings.
The NHS Constitution establishes the principles and values of the NHS in England. For more information see these websites:
The practice fully supports the NHS Zero Tolerance Policy. The aim of this policy is to tackle the increasing problem of violence against staff working in the NHS and ensures that doctors and their staff have a right to care for others without fear of being attacked or abused.
We understand that ill patients do not always act in a reasonable manner and will take this into consideration when trying to deal with a misunderstanding or complaint. We ask you to treat your doctors and their staff courteously and act reasonably.
All incidents will be followed up and you will be sent a formal warning after a second incident or removed from the practice list after a third incident if your behaviour has been unreasonable.
However, aggressive behaviour, be it violent or verbal abusive, will not be tolerated and may result in you being removed from the Practice list and, in extreme cases, the Police will be contacted if an incident is taking place and the patient is posing a threat to staff or other patients.
A good patient-doctor relationship, based on mutual respect and trust, is the cornerstone of good patient care. The removal of patients from our list is an exceptional and rare event and is a last resort in an impaired patient-practice relationship. When trust has irretrievably broken down, it is in the patient’s interest, just as much as that of The Surgery, that they should find a new practice. An exception to this is on immediate removal on the grounds of violence e.g. when the Police are involved.
Removing other members of the household
In rare cases, however, because of the possible need to visit patients at home it may be necessary to terminate responsibility for other members of the family or the entire household. The prospect of visiting patients where a relative who is no longer a patient of the practice by virtue of their unacceptable behaviour resides, or being regularly confronted by the removed patient, may make it too difficult for the practice to continue to look after the whole family. This is particularly likely where the patient has been removed because of violence or threatening behaviour and keeping the other family members could put doctors or their staff at risk.