Privacy Notice - Extended Access Service

Update - Prescribing

Purpose : Prescriptions containing personal identifiable and health data will be shared with chemists/pharmacies, in order to provide patients with essential medication or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Where patients have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be  ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver medication

Legal Basis : Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

Patients will be required to nominate a preferred pharmacy.

Processor – Pharmacy of choice

 

COVID-19 Update

Following the latest Notice issued by the Department of Health & Social Care, under Regulation 3(4) of The Health Service (Control of Patient Information) Regulations 2002, we have revised the information that we originally provided in respect of Practice Privacy Notices and the Covid-19 pandemic as follows:

1. COVID-19 Pandemic wording for practice privacy notices as at 25th March 2020:

Coronavirus (COVID-19) pandemic and your information

The ICO recognises the unprecedented challenges the NHS and other health professionals are facing during the Coronavirus (COVID-19) pandemic.

The ICO also recognise that 'Public bodies may require additional collection and sharing of personal data to protect against serious threats to public health.'

The Government have also taken action in respect of this and on 20th March 2020 the Secretary of State for Health and Social Care issued a Notice under Regulation 3(4) of The Health Service (Control of Patient Information) Regulations 2002 requiring organisations such as GP Practices to use your information to help GP Practices and other healthcare organisations to respond to and deal with the COVID-19 pandemic.

In order to look after your healthcare needs during this difficult time, we may urgently need to share your personal information, including medical records, with clinical and non-clinical staff who belong to organisations that are permitted to use your information and need to use it to help deal with the Covid-19 pandemic. This could (amongst other measures) consist of either treating you or a member of your family and enable us and other healthcare organisations to monitor the disease, assess risk and manage the spread of the disease.

Please be assured that we will only share information and health data that is necessary to meet yours and public healthcare needs.

The Secretary of State for Health and Social Care has also stated that these measures are temporary and will expire on 30th September 2020 unless a further extension is required. Any further extension will be will be provided in writing and we will communicate the same to you.
Please also note that the data protection and electronic communication laws do not stop us from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.

It may also be necessary, where the latest technology allows us to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.

If you are concerned about how your information is being used, please contact our DPO using the contact details provided in this Privacy Notice.

 

 

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.

The practice can override dissent from sending SMS messages, to inform patients of emergency issues if there is a legitimate public interest.  Of course, you should not include confidential data in your message.the practice can override dissent from sending SMS messages, to inform patients of emergency issues if there is a legitimate public interest.  Of course, you should not include confidential data in your message.

 

WHO WE ARE

Eastleigh Southern Parishes Network (ESP Network) Ltd. is responsible for providing Extended Urgent Primary care services for the local population of West Hampshire Clinical Commissioning Group (CCG) via ESP Hub, Botley Surgery, Mortimer Road, Botley, Hampshire, SO32 2UG.
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 Hub Extended Urgent Primary Care Services.
You may find a copy of this Fair Processing Notice:

 

  • in the reception of Botley Surgery,
  • 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 15th July 2019.

 

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 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);
  • Details and contact numbers of your next of kin;
  • Your age range, gender, ethnicity;
  • Details in relation to your medical history;
  • The reason for your visit to the Extended Urgent Primary Care Service;
  • Medical notes and details of diagnosis and consultations with our GPs and other health professionals within the Service involved in your direct healthcare;
  • Any contact the Service has had with you, such as appointments, telephone calls, etc.;
  • Details about treatment and care;
  • Results of investigations such as laboratory tests, x-rays, etc.;
  • Relevant information from other health professionals, relatives or those who care for you.

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. A full list of this can be found at Appendix 1.

 

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

 

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
  • Care Navigator Providers
  • Phlebotomy Service Providers
  • Other ‘data processors’ which you will be informed of
  • In addition to the above, through pharmacists and Technicians employed by West Hampshire Clinical Commissioning Group, ESP Hub may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.

The Medicines Management team are bound by the same confidentiality rules as our staff members are.

 

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.
  • This record may be shared with other healthcare professionals and additions to this record may also be made by relevant healthcare professionals and organisations involved in your direct healthcare.
  • You may have the right to demand that this record is not shared with anyone who is not involved in the provision of your direct healthcare. If you wish to enquire further as to your rights in respect of not sharing information on this record then please contact our Data Protection Officer.
  • 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 NHS 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 Hub, 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 Hub. As a result of this we may not be able to conduct a consultation with you as it is a requirement for the service that the clinician you see has access to your medical record. Your practice can advise you further of this.

 

CARE AND HEALTH INFORMATION EXCHANGE (“CHIE”)

  • Care and Health Information Exchange (CHIE) formerly known as the Hampshire Health Record or HHR, is an electronic summary record for people living in Hampshire, Portsmouth and Southampton.
  • In order for different parts of the health and care system to work together to provide you with the support you need the CHIE stores summary information from these organisations in one place so that, with your consent, professionals can view it to deliver better care to you.
  • This record contains more information than the Summary Care Record, but is only available to organisations in Hampshire.
  • Records on CHIE are held with clear NHS numbers and other identifiers required to locate information to deliver to professionals in support of treatment and care. The primary purpose of the CHIE is to provide clinical and care professionals with complete, accurate and up-to-date information when caring for patients like you.
  • In addition to ensuring that people who care for you have access to the right level of summary information CHIE also analyses trends in population health through a database called Care and Health Information Analytics (CHIA). This is called ‘secondary processing’. CHIA is a physically separate database, which receives some data from CHIE but all of the data used in this way has been ‘‘pseudo-anonymised’ – this means names, initials, addresses, dates of birth and postcodes have all been removed.
  • It is not possible to identify any patient by looking at the ‘pseudo-anonymised’ data on the CHIA database. People who have access to CHIA do not have access to CHIE.

If you object to your information being processed or stored on CHIE it can retain just enough information about you to ensure that the restriction is respected in future. You can ask to restrict processing to direct care (data not transferred to CHIA) only or completely (data not visible in CHIE or CHIA).
If you wish to enquire further as to your rights in respect of not sharing information on this record then please contact our Data Protection Officer.
Further details about CHIE are available here: CHIE Review of Procedures Compliance with GDPR V5-1
 

 

OTHER PEOPLE WHO 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.   
  • Data Extraction by the Clinical Commissioning Group – the clinical commissioning group at times extracts medical information about you, but the information we pass to them via our computer systems cannot identify you to them. This information only refers to you by way of a code that only ESP Hub can identify (it is pseudo-anonymised). This therefore protects you from anyone who may have access to this information at the Clinical Commissioning Group from ever identifying you as a result of seeing the medical information and we will never give them the information that would enable them to do this.

There are good reasons why the Clinical commissioning Group may require this pseudo-anonymised information. An example of this is to establish if an area needs a particular service, such as a community podiatry service.

 

ANONYMISED INFORMATION

Sometimes we may provide information about you 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.

 

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 medical 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, if we require this information to assist us in providing you with appropriate medical services and diagnosis for your healthcare, then removal may not be possible.

  • 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 MEDICAL 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 diagnosis or treatment or on going healthcare;
  • 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.

 

UNDER 16s

There is a separate Fair Processing Notice for patients under the age of 16, a copy of which is attached below:

 

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.

 

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 Hub 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, ensure the safety of you and our staff, and to 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 demo graphic 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 Botley Surgery’s staff for problem solving.

Emis Health Website

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

 

GP TeamNet

Cloud based Intranet for ESP Network Ltd.

No.

Clarity Website

Healthcare Computing

Botley Surgery 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 Botley Surgery’s staff for problem solving.

Healthcare Computing Website

Lexacom

Cloud based Dictation software which clinical staff use to dictate letters for the secretaries to type.

Lexacom support staff are able to dial in remotely with the consent of our or Botley Surgery’s staff for problem solving.

Lexacom Website

MJog

SMS and smart messaging system between ESP Hub and patients.

Patient’s EMIS (clinical system) numbers are uploaded to MJog’s website. The website has an encrypted link to the patient database which is interrogated for the patient’s name and mobile number.

The service is hosted on a secure virtual server at Blackthorn Health Centre. This is so the management and day-to-day administration of this can be carried out at ESP Network’s offices (which are based at Blackthorn Health Centre).

MJog employees would only have access to this identifiable information when trouble shooting – they will sometimes dial in to an ESP Network’s staff member’s PC at Blackthorn Health Centre, with the consent of the member of staff, to fix a problem.

Mjog Website

PCTI Docman Connect

Provides the auditable delivery of patient Hub Discharge Summary electron ically back to the patient’s practice.

Docman support staff can remotely dial in with the consent of our staff for problem solving.

PCTI Connect Website

PCTI Docman Share

Clinical software integrated into EMIS Web Clinical Services to enable viewing patient letters and documents from the patient’s practice.

Docman support staff can remotely dial in with the consent of our staff for problem solving.

PCTI Share Website

Vodafone

ESP Hub’s mobile number is provided through Vodafone’s network.

No.

Vodafone Website

Axis Fire & Security Services Ltd

CCTV camera

No

Axis Security ltd. Website

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