Privacy Notice - Care Navigator Service

Privacy Notice - Care Navigator Service

Fair Processing Notice

 

We at Eastleigh Southern Parishes Network (ESP Network) Limited understand how important it is to keep your personal information safe and secure and we take this very seriously. We have taken steps to make sure your personal information is looked after in the best possible way and we review this regularly.

 

Please read this Fair Processing Notice (otherwise known as a ‘Privacy Notice’) carefully, as it contains important information about how we use the personal and healthcare information we collect on your behalf.

 

WHO WE ARE

Eastleigh Southern Parishes Network (ESP Network) Ltd. is responsible for providing Extended Access Primary care services for the local population of West Hampshire Clinical Commissioning Group (CCG) via ESP Hub, Hedge End Medical Centre, 24-28 Lower Northam Road, Hedge End, Southampton, Hampshire, SO30 4FQ.

We also deliver a phlebotomy service for our partner GP practices. In addition, we also provide a non-clinical Care Navigation Service to the local populations of Eastleigh Southern Parishes and the New Forest which aims to support patients and carers to “navigate” their way around health, social care and community and voluntary services, thereby ensuring people receive the right services in the right place tailored to individual need.

 

This Fair Processing Notice relates to ESP Care Navigation service.

 

You may find a copy of this Fair Processing Notice:

on our website, or

a copy may be provided on request.

 

 

We regularly review and update our Fair Processing Notice. This Fair Processing Notice was last updated on:  Monday 23rd July 2018.

 

 

WHY WE ARE PROVIDING THIS PRIVACY NOTICE

We are required to provide you with this Privacy Notice by Law. It explains how we use the personal and healthcare information we collect, store and hold about you. If you are unclear about how we process or use your personal and healthcare information, or you have any questions about this Fair Processing Notice or any other issue regarding your personal and healthcare information, then please do contact our Data Protection Officer (details below).

The Law says:

We must let you know why we collect personal and healthcare information about you;
 

We must let you know how we use any personal and/or healthcare information we hold on you;
 

We need to inform you in respect of what we do with it;
 

We need to tell you about who we share it with or pass it on to and why; and
 

We need to let you know how long we can keep it for.

 

 

THE DATA PROTECTION OFFICER

As a public authority, we have to appoint a Data Protection officer (DPO). The organisation has an arrangement with Hedge End Medical Centre to be an independent advisor on Information Governance. This arrangement allows the DPOs to assist us in monitoring internal compliance, provides advice regarding Data Protection impact Assessments (DPIAs) ad helps us demonstrate compliance with an enhanced focus on accountability.

Our DPO for Eastleigh Southern Parishes Network Ltd is Jennie Dock (Practice Manager at Hedge End Medical Centre) who can assist with the following:

If you wish to make a complaint about anything to do with the personal and healthcare information we hold about you;
 

Or any other query relating to this Policy and your rights as a patient.

 

If you have any enquiries about any of the bullet points below, please address this query to the DPO team at Eastleigh Southern Parishes Network Ltd.

You have any questions about how your information is being held;
 

If you require access to your information or if you wish to make a change to your information;

 

You can inform us of your enquiry via emailing admin.espn@nhs.net (marked for the attention of the Data Protection Officer) or in writing to Data Protection Officer, ESP Network Ltd, Blackthorn Health Centre, Satchell Lane, Southampton, SO31 4NQ.

 

 

ABOUT US

We, Eastleigh Southern Parishes Network (ESP Network) Ltd. (whose registered address is c/o Blackthorn Medical Centre at Satchell Lane, Hamble-le-Rice, Southampton, SO31 4NQ), are a Data Controller of your information. This means we are responsible for collecting, storing and handling your personal and healthcare information when you attend as a patient.

There may be times where we also process your information. That means we use it for a particular purpose and, therefore, on those occasions we may also be Data Processors. The purposes for which we use your information are set out in this Fair Processing Notice.

 

 

INFORMATION WE MAY COLLECT FROM YOU

The information we may collect from you will include:

Your contact details (such as your name and email address, including place of work and work contact details if appropriate);
 

Details and contact numbers of your next of kin;
 

Your age range;
 

Details in relation to your medical history (but limited to information that will enable the care navigator to ensure you receive the right services in the right place tailored to your individual need);
 

Your expectations of the Service;
 

Any contact the Service has with other health professionals and agencies involved in your direct healthcare, for example Community Nurses, Community Mental Health practitioners, the GPs and nurses at your registered practice and voluntary services;
 

Any contact the Service has had with you, such as home visits, telephone calls, etc.;
 

Other relevant information, for example if you live alone, have access or communication issues, or if there are other hazards to be considered;
 

Information from other health professionals, relatives or those who care for you (limited to information that is necessary for our care navigators to ensure you receive the right services in the right place tailored to your individual need);

 

 

INFORMATION ABOUT YOU FROM OTHERS

We also collect personal information about you when it is sent to us from the following:

A hospital, a consultant or any other medical or healthcare professional, or any other person involved with your general healthcare
 

NHS Trusts / Foundation Trusts
 

GP’s
 

NHS Commissioning Support Units
 

Independent Contractors such as dentists, opticians, pharmacists
 

Private Sector Providers
 

Voluntary Sector Providers
 

Ambulance Trusts
 

Clinical Commissioning Groups
 

Social Care Services
 

Health and Social Care Information Centre (HSCIC)
 

Local Authorities
 

Education Services
 

Fire and Rescue Services
 

Police & Judicial Services
 

Voluntary Sector Providers
 

Private Sector Providers
 

Other ‘data processors’ which you will be informed of

 

 

YOUR SUMMARY CARE RECORD

Your summary care record is an electronic record of your healthcare history (and other relevant personal information) held on a national healthcare records database provided and facilitated by NHS England.

Eastleigh Southern Parishes Network (ESP Network) Ltd does not currently share information with the Summary Care Record but may do so in the future. However, if you wish to find out more about the wider use of confidential personal information and to register your choice to opt-out if you do not want your data to be used in this way, please visit www.nhs.uk/my-data-choice.

Note if you do choose to opt-out, you can still consent to your data being used for specific purposes. However, if you are happy with this use of information you do not need to do anything. You may however change your choice at any time.

In addition, as your record is managed by your practice and not ESP Network, if you wish to opt-out of any of the above (as well as any other / future schemes), this will need to be initiated through your practice.

PLEASE NOTE: One of the initiatives you can opt-out of will result in your medical record not being shared with ESP Network. As a result of this we may not be able to provide a fully comprehensive care navigation service.

 

 

WHO WE MAY PROVIDE YOUR PERSONAL INFORMATION TO, AND WHY

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care Services, important information about you is collected to help ensure you get the best possible care and treatment. This information may be passed to other approved organisations where there is a legal basis, to help with planning services, improving care, research into developing new treatments and preventing illness. All of this helps in proving better care to you and your family and future generations. However, as explained in this Fair Processing Notice, confidential information about your health and care is only used in this way where allowed by law and would never be used for any other purpose without your clear and explicit consent.

We may pass your personal information on to the following people or organisations, because these organisations may require your information to assist them in the provision of your direct healthcare needs. It, therefore, may be important for them to be able to access your information in order to ensure they may properly deliver their services to you:

Hospital professionals (such as doctors, consultants, nurses, etc);
 

Other GPs/Doctors;
 

Pharmacists;
 

Nurses and other healthcare professionals;
 

Independent Contractors such as dentists, opticians, pharmacists
 

Any other person that is involved in providing services related to your general healthcare, including mental health professionals.
 

A hospital, a consultant or any other medical or healthcare professional, or any other person involved with your general healthcare.
 

Private Sector Providers
 

Voluntary Sector Providers
 

Ambulance Trusts
 

Social Care Services
 

Health and Social Care Information Centre (HSCIC)
 

Local Authorities
 

Education Services
 

Fire and Rescue Services
 

Police & Judicial Services
 

Voluntary Sector Providers
 

Private Sector Providers
 

Phlebotomy Service Providers
 

Other ‘data processors’ which you will be informed of
 

 

OTHER PEOPLE WHO MAY WE PROVIDE YOUR INFORMATION TO
 

Commissioners;
 

Clinical Commissioning Groups;
 

Local authorities;
 

Community health services;
 

For the purposes of complying with the law e.g. Police, Solicitors, Insurance Companies;
 

Anyone you have given your consent to, to view or receive your record, or part of your record. Please note, if you give another person or organisation consent to access your record we will need to contact you to verify your consent before we release that record. It is important that you are clear and understand how much and what aspects of, your record you give consent to be disclosed.   
 

 

 

ANONYMISED INFORMATION

Sometimes we may provide information about you, for example to the West Hants Clinical Commissioning Group (WHCCG) in an anonymised form. If we do so, then none of the information we provide to any other party will identify you as an individual and cannot be traced back to you.

There is a very good reason for providing anonymised data to the CCG. It enables them to provide a robust evaluation of the Care Navigation service. We will use secure NHS mail accounts to transfer this information to NHS Digital through its Data Services for Commissioners Regional Office (DSCRO) who are permitted to collect, hold and process Personal Confidential data. For more details of the DSCRO service, please visit https://digital.nhs.uk/services/data-services-for-commissioners-dsfc     

 

 

YOUR RIGHTS AS A PATIENT

The Law gives you certain rights to your personal and healthcare information that we hold, as set out below:

Access and Subject Access Requests

You have the right to see what information we hold about you and to request a copy of this information.

If you would like a copy of the information we hold about you please email our Data Protection Officer. We will provide this information free of charge however, we may in some limited and exceptional circumstances have to make an administrative charge for any extra copies if the information requested is excessive, complex or repetitive.

We have one month to reply to you and give you the information that you require. We would ask, therefore, that any requests you make are in writing and it is made clear to us what and how much information you require. 

 

 

Online Access

Eastleigh Southern Parishes Network (ESP Network) Ltd does not currently have the facility to enable you to have online access to your care record.

 

Correction

We want to make sure that your personal information is accurate and up to date. You may ask us to correct any information you think is inaccurate. It is very important that you make sure you tell us (as well as your practice) if your contact details including your mobile phone number has changed.

 

Removal

You have the right to ask for your information to be removed however this may affect our organisation’s ability to provide a fully comprehensive care navigation service.

 

 

Objection

We cannot share your information with anyone else for a purpose that is not directly related to your health, e.g. medical research, educational purposes, etc. We would ask you for your consent in order to do this, however you have the right to request that your personal and healthcare information is not shared by Eastleigh Southern Parish Network (ESP Network) Ltd. in this way. Please note the Anonymised Information section in this Fair Processing Notice.

 

Transfer

You have the right to request that your personal and/or healthcare information is transferred, in an electronic form (or other form), to another organisation, but we will require your clear consent to be able to do this.

 

 

THIRD PARTIES MENTIONED ON YOUR CARE RECORD

Sometimes we record information about third parties mentioned by you to us during any consultation. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them which may breach their rights to confidentiality, are removed before we send any information to any other party including yourself. Third parties can include: spouses, partners, and other family members. 

 

 

HOW WE USE THE INFORMATION ABOUT YOU

We use your personal and healthcare information in the following ways:

when we need to speak to, or contact other doctors, consultants, nurses or any other medical/healthcare professional or organisation during the course of your ongoing health and social care needs;
 

when we are required by Law to hand over your information to any other organisation, such as the police, by court order, solicitors, or immigration enforcement.

We will never pass on your personal information to anyone else who does not need it, or has no right to it, unless you give us clear consent to do so.

 

 

LEGAL JUSTIFICATION FOR COLLECTING AND USING YOUR INFORMATION

The Law says we need a legal basis to handle your personal and healthcare information.

CONTRACT: We have a contract with NHS England to deliver healthcare services to you. This contract provides that we are under a legal obligation to ensure that we deliver medical and healthcare services to the public.

CONSENT: Sometimes we also rely on the fact that you give us consent to use your personal and healthcare information so that we can take care of your healthcare needs.

Please note that you have the right to withdraw consent at any time if you no longer wish to receive services from us.

NECESSARY CARE: Providing you with the appropriate healthcare, where necessary. The Law refers to this as ‘protecting your vital interests’ where you may be in a position not to be able to consent. 

LAW: Sometimes the Law obliges us to provide your information to an organisation (see above).

 

 

SPECIAL CATEGORIES

The Law states that personal information about your health falls into a special category of information because it is very sensitive. Reasons that may entitle us to use and process your information may be as follows:

PUBLIC INTEREST: Where we may need to handle your personal information when it is considered to be in the public interest. For example, when there is an outbreak of a specific disease and we need to contact you for treatment, or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment;

CONSENT: When you have given us consent;

VITAL INTEREST: If you are incapable of giving consent, and we have to use your information to protect your vital interests (e.g. if you have had an accident and you need emergency treatment);

DEFENDING A CLAIM: If we need your information to defend a legal claim against us by you, or by another party;

PROVIDING YOU WITH MEDICAL CARE: Where we need your information to provide you with medical and healthcare services

 

 

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We carefully consider any personal information that we store about you, and we will not keep your information for longer than is necessary for the purposes as set out in this Fair Processing Notice.

 

 

 

IF ENGLISH IS NOT YOUR FIRST LANGUAGE

If English is not your first language you can request a translation of this Fair Processing Notice. Please contact our Data Protection Officer.

 

 

COMPLAINTS

If you have a concern about the way we handle your personal data or you have a complaint about what we are doing, or how we have used or handled your personal and/or healthcare information, then please contact our Data Protection Officer.

However, you have a right to raise any concern or complaint with the UK information regulator, at the Information Commissioner’s Office: https://ico.org.uk/.

 

 

OUR WEBSITE

The only website this Fair Processing Notice applies to is ESP Network’s website (www.espnetwork.co.uk). If you use a link to any other website from ESP Network’s website then you will need to read their respective Privacy Notice. We take no responsibility (legal or otherwise) for the content of other websites.

 

 

COOKIES

ESP Network’s website uses cookies. For more information on which cookies we use and how we use them, please see our Cookies Policy.

 

 

SECURITY

We take the security of your information very seriously and we do everything we can to ensure that your information is always protected and secure. We regularly update our processes and systems and we also ensure that staff members are properly trained. We also carry out assessments and audits of the information that we hold about you and make sure that if we provide any other services, we carry out proper assessments and security reviews.

 

 

TEXT MESSAGING AND CONTACTING YOU

Because we are obliged to protect any confidential information we hold about you and we take this very seriously, it is imperative that you let us know immediately if you change any of your contact details.

We may contact you using SMS texting to your mobile phone in the event that we need to notify you about appointments and other services that we provide to you involving your direct care, therefore you must ensure that we have your up to date details. This is to ensure we are sure we are actually contacting you and not another person.

 

 

Risk Stratification

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention.

Information about you is collected from a number of sources including NHS Trusts and from ESP Network as well as your GP Practice. A risk score is then arrived at through an analysis of your anonymised information using software managed by our clinical system provider, and is only provided back to your GP as data controller in an identifiable form.

Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary your GP may be able to offer you additional services.

Please note that you have the right to opt-out of your data being used in this way.

Appendix 1: Who are our partner software suppliers / businesses?

We use a number of pieces of software and organisations outside of the NHS to facilitate your healthcare and enable our staff to contact you. These are as follows:

Name

Description

Can Employees of the Organisation Access Patient Information?

GDPR Statement

EMIS Web Clinical Services

Clinical system that holds patient demographic and medical information – remote server.

The servers and the connection to ESP Hub are encrypted, so EMIS staff are not able to access patient information in this way.

EMIS support staff are able to dial in remotely with the consent of our or Hedge End Medical Centre’s staff for problem solving.

https://supportcentre.emishealth.com/emis-group-and-the-gdpr-general-data-protection-regulation

(only accessible with a log in so PDF version attached below)

GP TeamNet

Cloud based Intranet for ESP Network Ltd.

To be confirmed

Waiting for information

Healthcare Computing

Hedge End Medical Centre primary general IT support provider.

ESP Hub has a dedicated server space so as to keep our data separate from Hedge End Medical Centre.

Healthcare Computing support staff are able to monitor the servers remotely. They are also able to remotely dial in with the consent of our or Hedge End Medical Centre’s staff for problem solving.

https://www.healthcarecomputing.co.uk/policies/gdpr-policy

Vodafone

ESP Network’s care navigator mobile numbers are provided through Vodafone’s network.

To be confirmed

https://www.vodafone.co.uk/privacy