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Privacy Notice

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will 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. These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of 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 will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form. Our telephone system can also record all conversations.

Our Commitment to Data Privacy and Confidentiality Issues

As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation. This includes the General Data Protection Regulation (EU) 2016/679 (GDPR) now known as the UK GDPR, the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.

Data we collect about you

Records which this GP Practice will hold or share about you will include the following:

Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.

Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.

Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place

Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of 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 or without your permission when the practice is closed. Where your record is accessed without your permission it is necessary for them to have a legitimate basis in law. This is explained further in the Local Information Sharing at Appendix A.

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment.

The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

improving the quality and standards of care provided by the service
research into the development of new treatments and care pathways
preventing illness and diseases
monitoring safety
planning services
risk stratification
Population Health Management

Safeguarding of children or vulnerable adults

If we have significant concerns or hear about an individual child or vulnerable adult being at risk of harm, we may share relevant information with other organisations, such as local authorities and the Police, involved in ensuring their safety.

Statutory disclosures

Sometimes we are duty bound by laws to disclose information to organisations such as the Care Quality Commission, the Driver and Vehicle Licencing Agency, the General Medical Council, Her Majesty’s Revenue and Customs and Counter Fraud services. In these circumstances we will always try to inform you before we are required to disclose and we only disclose the minimum information that the law requires us to do.

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law or with consent.

Pseudonymised or anonymised data is generally used for research and planning so that you cannot be identified.

A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from Records Management Code of Practice - NHSX(opens in a new tab). Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for 2021.

Under UK GDPR 2016 the Law provides the following rights for individuals. The NHS upholds these rights in a number of ways:

The right to be informed
The right of access
The right to rectification
The right to erasure (not an absolute right) only applies in certain circumstances
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling.

The NHS Constitution states, ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’.

Type 1 Opt Out

This is an objection that prevents an individual's personal confidential information from being shared outside of their general practice except when it is being used for the purposes of their individual direct care, or in particular circumstances required by law, such as a public health screening, or an emergency like an outbreak of a pandemic disease. If patients wish to apply a Type 1 Opt Out to their record, they should make their wishes known to the Practice Manager.

National data opt-out (NDOO)

The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.

The national data opt-out replaces the previous ‘Type 2’ opt-out, which required NHS Digital not to use a patient’s confidential patient information for purposes beyond their individual care, for Planning or Research. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to National data opt out programme (opens in a new tab)

To find out more or to register your choice to opt out, please visit Your NHS Data Matters(opens in a new tab).

On this web page you will:

See what is meant by confidential patient information
Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
Find out more about the benefits of sharing data
Understand more about who uses the data
Find out how your data is protected
Be able to access the system to view, set or change your opt-out setting
Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
See the situations where the opt-out will not apply

Right of access to your information (Subject Access Request)

Under Data Protection Legislation everybody has the right of access to, or request a copy of, information we hold that can identify them, this includes medical records. There are some safeguards regarding what patients will have access to and they may find information has been redacted or removed for the following reasons;

It may be deemed to risk causing harm to the patient or others
The information within the record may relate to third parties who are entitled to their confidentiality, or who have not given their permission for the information to be shared.

Patients do not need to give a reason to see their data. And requests can be made verbally or in writing. Although we may ask them to complete a form in order that we can ensure that they have the correct information required.

Where multiple copies of the same information is requested, the surgery may charge a reasonable fee for the additional copies.

Patients will need to provide proof of identity to receive this information. We will not share information relating to you with other individuals without your explicit instruction or without sight of a legal document.

Patients may also request to have online access to their data, they may do this via the NHS APP(opens in a new tab), or via the practice’s system. If you would like to access your GP record, contact the surgery in person or contact us online using our form

Further information about the service can be found at the privacy notices for the NHS App (opens in a new tab) managed by NHS England.

Change of details

It is important that you tell the surgery if any of your contact details such as your name or address have changed, or if any of your other contacts details are incorrect including third party emergency contact details. Please always highlight if there are other registered patients who also need updated details. It is important that we are made aware of any changes immediately in order that no information is shared in error.

Mobile telephone number

If you provide us with your mobile phone number, we will use this to send you text reminders about your appointments or other health related information. It is within our legal duty as a public authority to keep our patients updated with important information. Text reminders maybe sent through Accurx or Abtrace. These are approved software programs used to support patient appointments and information.

We may also use the NHS Account Messaging Service provided by NHS England to send you messages relating to your health and care. You need to be an NHS App user to receive these messages.

Further information about the service can be found at the privacy notice for the NHS App managed by NHS England.(opens in a new tab).

Email address

Where you have provided us with your email address, we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email, please let us know.

Contact preferences

If you need information sent to you in a specific format e.g. large font, please contact the Surgery.

Research

This organisation shares information from medical records to support medical research, when the law allows us to do so. For example, to find out if different or new treatments work better or changing medication maybe more effective for particular groups of patients. All research projects are subject to external monitoring and ethical scrutiny. The practice follows strict rules about referring patients to research studies and making data available for research purposes. If you want to completely opt out of all research activity please contact the practice to opt-out.

Notification

Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a Data Controller and our registration can be viewed online in the public register on the ICO website.(opens in a new tab)

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

Data Protection Officer

Should you have any data protection questions or concerns, please contact our Data Protection Officer via the surgery

What is the right to know?

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However, you can request this under a right of access request – see section above ‘Access to your information’.

Right to complain

If you have concerns or are unhappy about any of our services, please contact the Practice Manager. Or via the ICO details listed below.

For independent advice about data protection, privacy, and data-sharing issues, you can contact The Information Commissioners office.

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 programs available to you, confidentiality, information, and your right to complain if things go wrong.

Learn more about the NHS Constitution for England

Document control

This document was created by NHS South Central and West Commissioning Support Unit (SCW) and as such the Intellectual Property Rights of this document belong to SCW.

Privacy notice primary care template

Version: 3.7
Status: Published
Author: NHS SCW Information Governance Services
Document objectives: This document supports Practice staff in compliance with Data Protection legislation, achieving best practice in the area of Information Governance and in meeting the requirements of the Data Security and Protection Toolkit.
Target audience: All Staff
Monitoring arrangements and indicators: This document will be monitored by NHS SCW Information Governance Services to ensure any legislative changes that occur before the review date are incorporated.
Review frequency: SCW reviews customer documents in line with our planned schedule
SCW Planned Review date: May 2026
Approved and ratified by practice: Wellspring GP Surgery on 21st May 2026
Date issued by practice: 21st May 2026
Review date: 20th May 2027

Appendix A - External data controllers and processors

Abtrace

Software providing automated invitations for patients with long term conditions, or requiring routine screening and immunisation. The software reads patient record codes to create the invitation.

Read the Abtrace Privacy Policy (opens in a new tab)

AccuRx

AccuRx supports triage of patient requests and direct patient messaging via SMS and online triage. Copies of triage and text messages are downloaded to the patient record.

Read the AccuRx Privacy policy (opens in a new tab)

Avon and Wiltshire Mental Health Partnership

AWP provide community and inpatient mental health services for patients.

Read the Avon and Wiltshire Mental Health Partnership Privacy Notice

Black Pear

Black Pear software connects the GP electronic record to Community patient records.

Read the Black Pear Privacy Notice(opens in a new tab)

Brisdoc Healthcare Services CIC

Brisdoc Healthcare provide out of hours primary care services, urgent care and mental health support.

Read the Brisdoc Healthcare Services CIC Privacy Notice

Bristol City Council

Use anonymised activity data to verify practice activities for commissioned services.

Read the Bristol City Council Privacy Notice

Bristol Drugs Project

Bristol Drugs Project and ROADS work with our practice to provide shared care for patients impacted by drug and/ or alcohol use. Practice-based workers are able to enter clinic data direct onto the GP patient record.

Read the Bristol ROADS Privacy Notice - Bristol Drugs Project (opens in a new tab)

Bristol Inner City Primary Care Network

BIC PCN comprises 4 inner city GP practices. As part of contract planning and delivery we may share population level data.

Read the Bristol Inner City Primary Care Network Privacy Notice

Carers support Bristol and South Gloucestershire

Carers support provide services for carers of all ages. We may provide your contact details with your consent for a carers support assessment.

Visit Carers support Bristol and South Gloucestershire

Connecting Care

Connecting Care enables health care organisations, including hospitals, Ambulance Service and the Out of Hours service provided by Brisdoc to read healthcare records. They are not able to amend the GP medical record. You can find more information available on their website and view their Privacy Notice directly using this link: What if I don’t want my information shared? (opens in a new tab)

Dementia Wellbeing Service

The Bristol dementia wellbeing service is provided by Devon Partnership NHS Trust.

Read the Devon Partnership NHS Trust Privacy notice (opens in a new tab)

Heidi AI

The practice is taking part in a pilot to use Heidi AI to record clinical conversations. Heidi software sits separately to the clinical system and is used for note-taking purposes only. The note taking is deleted after it is copied into the note system.

Read the Heidi AI Privacy Notice(opens in a new tab)

Iron Mountain

Provides secure ISO accredited storage for physical patient records. Ironmountain has previously scanned physical record content to be added to the electronic patient record.

Read the Iron Mountain Privacy notice (opens in a new tab)

Medical Examiners Officer

The Medical Examiner service is responsible for verifying and checking the cause of death for all deceased patients in both hospital and community settings. Information is shared about the decease to enable the Medical examiner to complete necessary checks before issuing the death certificate.

Learn more about the Medical Examiners Officer(opens in a new tab)

One Care

Onecare also analyse GP activity data and population or diagnosis level data to support service improvements. You can find more information available on their website and view their Privacy Notice directly using this link:

Read the Onecare Privacy Policy (opens in a new tab)

Optum Health

Optum health-formerly known as EMIS, supplies electronic patient record system in primary care.

Find more information and view their Privacy Notice

North Bristol NHS Trust

Provides secondary and tertiary hospital and outpatient services for patients.

Read the Bristol ROADS Privacy Notice (opens in a new tab)

Sirona

Sirona Community nurses and other health care professionals can access GP information about patients who have recently been discharged from hospital, housebound, or requiring rehabilitation. This information can be read by the healthcare professional to improve the patients care, but they are not able to amend the GP medical record.

Find more information about Sirona CIC policies (opens in a new tab)

St Peter’s Hospice

Hospice staff can read the records of patients in their care for provision of services. They are not able to amend the GP medical record.

Read the St Peter’s Hospice Privacy Policy (opens in a new tab)

University Hospitals Bristol and Weston NHS Foundation Trust (UHBW)