Supplementary Privacy Notice issued in response to COVID-19
Due to the unprecedented challenges that the NHS and Woosehill Medical Centre face due to the worldwide Covid-19 pandemic, there is a greater need for public bodies to require additional collection and sharing of personal data to protect against serious threats to public health.
In order to look after your healthcare needs in the most efficient way we may therefore need to share your personal information, including medical records, with staff from other GP Practices including Practices within our Primary Care Network, as well as other health organisations (i.e. Clinical Commissioning Groups, Commissioning Support Units, Local authorities etc.) and bodies engaged in disease surveillance for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
The Secretary of State has served notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) to require organisations to process confidential patient information in the manner set out below for purposes set out in Regulation 3(1) of COPI.
The notice can be seen here
Purpose of this Notice
The purpose of this Notice is to require organisations such as ourselves to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI.
This Notice is necessary to require organisations like us to lawfully and efficiently process confidential patient information as set out in Regulation 3(2) of COPI for purposes defined in regulation 3(1), for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
Requirement to Process Confidential Patient Information
The Secretary of State has served notice to recipients under Regulation 3(4) that requires Woosehill Medical Centre to process confidential patient information, including disseminating to a person or organisation permitted to process confidential patient information under Regulation 3(3) of COPI.
Woosehill Medical Centre is only required to process such confidential patient information:
where the confidential patient information to be processed is required for a Covid-19 Purpose and will be processed solely for that Covid-19 Purpose in accordance with Regulation 7 of COPI from 20th March 2020 until 30th September 2020 (depending if renewed) for a Covid-19 Purpose.
A Covid-19 Purpose includes but is not limited to the following:
- Understanding Covid-19 risks and controlling them
- Identifying and understanding information about patients or potential patients with or at risk of Covid-19
- Monitoring and managing the response to Covid-19
- Delivering services to patients, clinicians, health services and adult social care services
- Supporting research and planning
A record will be kept by Woosehill Medical Centre of all data processed under this Notice.
Sending Public Health Messages
Data protection and electronic communication laws will not stop Woosehill Medical Centre from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.
Summary Care Records (SCR)
All patients registered with a GP have a Summary Care Record, unless they have chosen not to have one. The information held in your Summary Care Record gives registered and regulated healthcare professionals, away from your usual GP practice, access to information to provide you with safer care, reduce the risk of prescribing errors and improve your patient experience.
In light of the current emergency, the Department of Health and Social Care has removed the requirement for a patient’s prior explicit consent to share Additional Information as part of the Summary Care Record.
The notice can be seen here
It may also be necessary, where the latest technology allows us to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.
Visitors to the Practice
We have an obligation to protect our staff and employees’ health, so it is reasonable for staff at Woosehill Medical Centre to ask any visitors to our practice to tell us if they have visited a particular country, or are experiencing Covid-19 symptoms. This must only be in pre-approved circumstances and we would also ask all patients to consider government advice on the NHS 111 website and not attend the practice.
Where it is necessary for us to collect information and specific health data about visitors to our practice, we will not collect more information than we need, and we will ensure that any information collected is treated with the appropriate safeguards
Review and Expiry of this Notice
This Notice will be reviewed on or before 30 September 2020 and may be extended by The Secretary of State. If no further notice is sent to Woosehill Medical Centre by The Secretary of State this Notice will expire on 30 September 2020.
Our Data Protection Officer
The Practice has appointed Jane Jacques as its Data Protection Officer.
Please e-mail firstname.lastname@example.org, if you have any concerns about how your data is shared, or if you would like to know more about your rights in respect of the personal data we hold about you.
How to contact the appropriate authorities
If you have any concerns about your information is managed then we would encourage you to first speak to our Data Protection Officer in the first instance.
If you are still unhappy following our Data Protection Officer’s review you have the right to lodge a complaint with the Information Commissioners Office at the following address:
Tel: 01625 545745