Our Policies

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 everyone and is highly regarded at the Surgery. We make every effort to recognise issues and address concerns 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

FGM

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

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 

Further Information

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

We are continually looking to turn out patients’ feedback into real improvements in the services we provide. We use it to focus on the things that matter most to our patients, carers and their families.

We would like to hear from you if you have a suggestion on how we can do things better to improve our patients’ experiences.

The best way to provide feedback and / or a complaint is via email or in writing by letter which can be posted to us or left in person with the reception team.

Emails can be sent directly to the Practice Manager on her email address: [email protected]

or

You can send an email to admin email address: [email protected]

WHAT WE WILL DO

We will acknowledge your complaint within 3 working days and aim to have fully investigated within 10 working days of the date it was received, if we expect it to take longer we will explain the reason for the delay and tell you when we expect to finish. When we look into your complaint, we will investigate the circumstances; make it possible for you to discuss the problem with those concerned; make sure you receive an apology if this is appropriate, and take steps to make sure any problem doses not arise again,.

You will receive a final letter setting out the result of any practice investigations.

IF YOU NEED HELP WITH YOUR COMPLAINT

You can seek support with VoiceAbility either on their website: www.voiceability.org, by phone at: 0300 330 5454 or by email at: [email protected].

TAKING IT FURTHER

If you remain dissatisfied with the outcome you may refer the matter to:

The Parliamentary and Health Service Ombudsman

Millbank Tower

Millbank

London

SW1P 4QP

Tel 0345 015 4033

www.ombudsman.org.uk

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.

Confidentiality

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.

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?

Requests must:

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:

Legislation GOV.UK

Information Commissioners Office

NHS England requires that the net earnings of doctors engaged in the practice is publicised, and the required disclosure is shown below:

However, it should be noted that the prescribed method for calculating earning is potentially misleading because it takes no account of how much time doctors spend working at the practice and should not be used to form judgement about GP earnings, nor to make any comparison with any other practice.

All GP practices are required to declare the mean earnings (e.g. Average pay) for GPs working to deliver NHS services to patients at each practice.

The average pay for GPs working in The Avenue Doctors Surgery in the last financial year was £76,420 before tax and national insurance. During that financial year the practice had 2 full time GPs and 1 part time GP who were working in the practice for more than six months.

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

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

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

General Data Protection Regulation

Human Rights Act

Common Law Duty of Confidentiality

NHS Codes of Confidentiality and Information Security

Health and Social Care Act 2015

And all applicable legislation

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

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for 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.

Clinical audit

Information may be used by the Clinical Commissioning Group 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.

Clinical Research

Sometimes anonymised data may be used for research purposes – but we will normally 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

Invoice validation is an important process. It involves using your NHS number to check which Clinical Commissioning Group 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

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

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

Gender

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:

https://www.england.nhs.uk/wp-content/uploads/2018/05/NHS-England-Privacy-Notice-published-13-04-2021.pdf

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.

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:

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

National Registries

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

Risk Stratification

‘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.

Safeguarding

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 Clinical Commissioning Groups 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.

Suspected Cancer

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.

COVID-19 and your information

This notice describes how we may use your information to protect you and others during the COVID19 outbreak.

The health and social care system is facing significant pressures due to the COVID-19 outbreak. Health and care information is essential to deliver care to individuals, support health and social care services, and protect public health. Information will also be vital in researching, monitoring, tracking and managing the outbreak. It has become even more important to share health and care information across relevant organisations in the current emergency.

Existing law, which allows confidential patient information to be used and shared appropriately and lawfully in a public health emergency, is being used during this outbreak. Using this law, the Secretary of State has required NHS Digital, NHS England and Improvement; Arm’s Length Bodies (such as Public Health England); local authorities; health organisations and GPs to share confidential patient information to respond to the COVID-19 outbreak. Any information used or shared during the COVID19 outbreak will be limited to the outbreak period unless there is another legal basis to use the data.

Further information is available on gov.uk, and some FAQs on this law are also available on the NHSX website. https://www.gov.uk/government/publications/coronavirus-covid-19-notification-of-data-controllers-to-share-information

https://www.nhsx.nhs.uk/information-governance/frequently-asked-questions/

During this period of emergency, opt-outs will not generally apply to the data used to support the COVID- 19 outbreak due to the public interest in sharing information. This includes National Data Optouts.

However, in relation to the Summary Care Record, existing choices will be respected. Where data is used and shared under these laws, your right to have personal data erased will also not apply. It may also take us longer to respond to Subject Access Requests, Freedom of Information requests and new opt-out requests while focusing our efforts on responding to the outbreak.

https://www.nhs.uk/your-nhs-data-matters/

To look after your health and care needs, we may share your confidential patient information, including health and care records, with clinical and non-clinical staff in other health and care providers, such as neighbouring GP practices, hospitals, and the NHS 111. We may also use the details to send public health messages to you, either by phone, text or email.

In addition, we may also share your information with Local Authorities within North West London for purposes beyond individual care relating to COVID-19.

In such circumstances where you tell us you’re experiencing COVID-19 symptoms, we may need to collect specific health data about you. Where we need to do so, we will not collect more information than we require, and we will ensure that any information collected is treated with the appropriate safeguards.

During this period of emergency, we may offer you a consultation via telephone or video conferencing. By accepting the invitation and entering the consultation, you are consenting to this. Your personal/confidential patient information will be safeguarded in the same way it would with any other consultation.

We will also be required to share personal/confidential patient information with health and care organisations and other bodies engaged in disease surveillance for the purposes of protecting public health, providing healthcare services to the public and monitoring and managing the outbreak.

Further information is available about how health and care data is being used and shared by other NHS and social care organisations in a variety of ways to support the COVID-19 response https://www.nhs.uk/your-nhs-data-matters/ . NHS England and Improvement and NHSX have developed a single, secure store to gather data from across the health and care system to inform the COVID-19 response. This includes data already collected by NHS England, NHS Improvement, Public Health England and NHS Digital. New data will include 999 call data, data about hospital occupancy and A&E capacity data, and data provided by patients themselves. All the data held in the platform is subject to strict controls that meet the requirements of data protection legislation.

HR, Staffing, Employment, Recruitment & Training

The CCG collects and stores information about staff for the purposes of HR, Employment, Recruitment and Training. Information is collected and stored about prospective, current and past employees, including self-employed and temporary staff. Data is collected for purposes including recruitment, occupational health, vetting checks, staff training and payroll.

Data Retention

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

https://www.nhsx.nhs.uk/media/documents/NHSX_Records_Management_Code_of_Practice_2020_3.pdf

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 types of organisations:

NHS Trusts

Specialist Trusts

Community Services

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

Police

Other ‘data processors’

Specific details of the organisations with whom we share your data can be seen here:

https://www.nwlondonccg.nhs.uk/your-health/your-patient-record

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.

Will my information be shared with anyone else?

We share your information with other health and social care organisations directly involved in your care. We will always have a legal agreement in place with these organisations and ensure that your information will be held securely:

NHS organisations involved in your case – we share your information with other NHS trusts, GP surgeries and other care providers involved in your

Non-NHS health and social care professionals – we share your information with local authorities and social workers concerned with your care. Our aim is to ensure that other health and social care providers have access to information that supports your

We share your information with organisations involved in planning and improving your care. We provide anonymised information or require legal justification if they request information that may identify

NHS bodies – your information may be requested by NHS bodies concerned with the planning and commissioning of healthcare services, such as clinical commissioning groups

Regulatory, audit and inspection bodies – these organisations are concerned with regulating aspects of care and deciding where improvements may be

In some situations, we use other organisations to help us process your information to help us deliver your care. We will always have a legal agreement in place with these organisations, which ensures that they can only use your information as we

We share staff information with HM Revenue and Customs, Department of Work and Pensions. Information may also be shared with occupational Health and payroll service provider.

Your rights

The data that we keep about you is your data, and we ensure that we keep it confidential and that it is used appropriately. You have the following rights when it comes to your data

 

. You have the following rights when it comes to your data: 1. You have the right to request a copy of all of the data we keep about you. Generally, we will not charge for this service;

You have the right to ask us to correct any data we have, which you believe to be inaccurate or incomplete. You can also request that we restrict all processing of your data while we consider your rectification request;

You have the right to ask that we erase any of your personal data which is no longer necessary for the purpose we originally collected it. We retain our data in line withthe Information Governance Alliance’s guidelines (https://digital.nhs.uk/data-and-information/looking-after-information/data-security-and-information-governance/codes-of-practice-for-handling-information-in-health-and-care/records-management-code-of-practice-for-health-and-social-care-2016

You may also request that we restrict the processing if we no longer require your personal data for the purpose we originally collected it for, but you do not wish it to be erased.

You can ask for your data to be erased if we requested for your consent to process your data. You can withdraw consent at any time – please contact us to do so.

If we are processing your data as part of our legitimate interests as an organisation or in order to complete a task in the public interest, you have the right to object to that processing. We will restrict all processing of this data while we look into your objection.

You may need to provide adequate information for our staff to identify you, for example, a passport or driver’s license. This is to make sure that data is not shared with the wrong person inappropriately. We will always respond to your request as soon as possible and at the latest within one month.

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

OUR PRACTICE IS COMPLIANT WITH NDO

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 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 the Practice staff. Under special circumstances, some information may be withheld.

If you wish to have a copy of the information we hold about you, please contact Reception.

Freedom of Information

Under the Freedom of Information Act 2000, you have the right to request copies of non – personal information held by the Chiswick Family Practice. To gain access to a copy of this information, you will need to make a Freedom of Information (FOI) Request to the Practice Manager.

Change of Details

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

Mobile telephone number

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

Notification

The Digital Economy 2017 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal data

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

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

Complaints

If you have concerns or are unhappy about any of our services, please contact the Practice Manager

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

The Information Commissioner,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire SK9 5AF

Phone: 0303 123 1113

Website: www.ico.orguk

Information we are required to provide to you

Data Controller contact details

Chiswick Family Practice

Data Protection Officer

contact details

Felicia Ayo-Ajala [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. Either:

Article 9(2)(a) – ‘the data subject has given explicit consent…’ Or:

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)(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 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

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…’

 

Lawful basis for processing for employment purposes

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;’

Other Lawful bases for processing Information

e.g. Personnel, Financial, Internal audits, Complaints, noncontractual invoices

Article 6(1)(a)- Consent Article 6(1)(b) – Contract Article 6(1)(c) – Legal Obligation

 

Article 6(1)(e) – Public Task Article 9(2)(a) – Explicit Consent Article 9(2)(b) – Employment, Social Security or Protection Law Article 9(2)(g) – Substantial Public Interest Article 9(2)(f) – Legal Claims

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

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 the practice website – https://www.cfpdrsbhattandszyszko.nhs.uk/practice-info/our-policies/gdpr- interim-privacy-note/

 

·        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.

Retention period

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   or speak to the practice.

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.

https://www.nhsx.nhs.uk/media/documents/NHSX_Records_Management_Code_of_Practice_2020_ 3.pdf

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programmes available to you, confidentiality, information and your right to complain if things go wrong. https://www.gov.uk/government/publications/the-nhs-constitution-for-england

NHS Digital

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

Reviews of and Changes to our Privacy Notice

We will keep our Privacy Notice under regular review. This notice was last reviewed in June 2021.

Our practice is supporting vital health and care planning and research by sharing your data with NHS Digital. For more information about this see the GP Practice Privacy Notice for General Practice Data for Planning and Research.”

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, Patient Advisors, Nurses, HCAs and 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 patient advisors who will make arrangements for you to speak in private.

Under 14s

The duty of confidentiality owed to a person under 14is as great as the duty owed to any other person. Young people aged under 14 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.

Useful Websites

Confidentiality NHS Code of Practice

Confidentiality and Mental Health

Confidentiality Guidance

Our Duties

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

Your Information

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.

Information Includes:

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:

Hospitals

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)

Objections

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:

See how NHS Digital uses your information.

Read about how NHS Digital handles your information and your choices.

Your Rights

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.

Data Security

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.

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.

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, checking and cancelling appointments, ordering repeat prescriptions and viewing a summary of your medical records on-line. We are not currently offering Full Access to your records or the Questionnaire options.

If you would like to set up an Online account you will need to complete and sign an application form and provide photo ID and proof of address. Please bring this in to reception so that an account can be activated for you. You will be prompted to change your password on your first log in.

Full details and the application forms can be found by clicking the Online tab at the top of this page.

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.

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.

FAQs

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

Introduction

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.

Indications

Bruising

Burns

Falls

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

Action Required

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

Frequency

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

Contact List

Service

Contact Number

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

Ealing CCG

3rd Floor, Perceval House

14/16 Uxbridge Road

Ealing, W5 2HL

020 8280 8080

NHS England

North West London Area Team

Patient’s Rights

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.

Patient’s Responsibilities

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.

NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. For more information see these websites:

UK – The NHS Constitution for England

NHS Choices – NHS Constitution

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.

This accessibility statement applies to 102 The Avenue Surgery. This website is run by 102 The Avenue Surgery. We want as many people as possible to be able to use this website. For example, that means you should be able to:

change colours, contrast levels and fonts

zoom in up to 300% without the text spilling off the screen

navigate most of the website using just a keyboard

navigate most of the website using speech recognition software

listen to most of the website using a screen reader (including the most recent versions of JAWS, NVDA and VoiceOver)

We’ve also made the website text as simple as possible to understand.

AbilityNet has advice on making your device easier to use if you have a disability.

We know some parts of this website are not fully accessible:

the text will not reflow in a single column when you change the size of the browser window

you cannot modify the line height or spacing of text

most older PDF documents are not fully accessible to screen reader software

live video streams do not have captions

some of our online forms are difficult to navigate using just a keyboard

you cannot skip to the main content when using a screen reader

there’s a limit to how far you can magnify the map on our ‘contact us’ page

Feedback and contact information

If you need information on this website in a different format like accessible PDF, large print, easy read, audio recording or braille:

email: [email protected]

call: 020 8997 2525

We’ll consider your request and get back to you in 7 days.

If you cannot view the map on our ‘contact us’ page, call or email us for directions.

We’re always looking to improve the accessibility of this website. If you find any problems not listed on this page or think we’re not meeting accessibility requirements, contact:

email: [email protected]

call: 020 8997 2525

Reporting accessibility problems with this website

We’re always looking to improve the accessibility of this website. If you find any problems not listed on this page or think we’re not meeting accessibility requirements, contact:

email: [email protected]

call: 020 8997 2525

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you’re not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS).

Contacting us by phone or visiting us in person

We provide a text relay service for people who are D/deaf, hearing impaired or have a speech impediment.

Our offices have audio induction loops, or if you contact us before your visit we can arrange a British Sign Language (BSL) interpreter.

Compliance

This website is partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard, due to ‘the non-compliances and exemptions’ listed below.

Non-accessible content

The content listed below is non-accessible for the following reasons:

This site may contain older PDFs and Word documents do not meet accessibility standards – for example, they may not be structured so they’re accessible to a screen reader. This does not meet WCAG 2.1 success criterion 4.1.2

Disproportionate burden

Google Maps – There’s a limit to how far you can magnify the embedded Google Map on our ‘contact us’ page. The code for this map is supplied by Google and we are unable to make amendments to it.

Preparation of this accessibility statement

This statement was prepared on 27/04/2022 and was updated on 28/04/2023.

Site compliance was checked using a combination of manual testing and third party tools, including:

WAVE Web Accessibility Evaluation Tool (https://wave.webaim.org/)

WebAIM Contrast Checker (https://webaim.org/resources/contrastchecker/)

HTML_CodeSniffer (https://squizlabs.github.io/HTML_CodeSniffer/)

Pa11y – Automated accessibility testing (https://pa11y.org/)

axe – Web Accessibility Testing (https://www.deque.com/axe/