Privacy

Introduction
This privacy policy is to provide information to you, our patient, on how your personal information (which includes your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties.

Why and when your consent is necessary
When you register as a patient of our practice, you provide consent for our GPs and practice staff to access and use your personal information so they can provide you with the best possible healthcare. Only staff who need to see your personal information will have access to it. If we need to use your information for anything else, we will seek additional consent from you to do this.

Why do we collect, use, hold and share your personal information?
Our practice will need to collect your personal information to provide healthcare services to you. Our main purpose for collecting, using, holding and sharing your personal information is to manage your health.

What personal information do we collect?
The information we will collect about you includes your:
names, date of birth, addresses, contact details
medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors
Images of you on our CCTV
voice recordings from telephone conversations
digital images for your clinical records
Cookies on our website

How do we collect your personal information?
Our practice may collect your personal information in several different ways.
1. When you make your first appointment our practice staff will collect your personal and demographic information via your registration.
2. During the course of providing medical services, we collect further personal information.
3. We may also collect your personal information when you visit our website, send us an email or telephone us, make an online appointment or communicate   with us using social media.
4. In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from   you directly. This may include information from:
your guardian or responsible person
other involved healthcare providers, such as specialists, allied health professionals, hospitals and community health services.
5. We collect information from cookies when you visit our website

How do we store and protect your personal information?
Your personal information may be stored at our practice in various forms.  Our practice stores all personal information securely.
Paper records
Hard copies of records are secured on site in locked cabinets.
Electronic records
Electronic records are held in cloud based password protected information systems.
Videos
Audio – visual recordings are kept on site in locked rooms.
CCTV
CCTV recordings are kept on site in a locked room.
Voice recordings from telephone conversations
These are stored in a cloud based password protected information system
The practice utilises confidentiality agreements for staff and contractors.

The Data Controller
The Practice is the Data Controller
Our contact details are
The Oakwood Surgery
Masham Road
Cantley
Doncaster
DN4 6BU

The Data Protection Officer
Caroline Million (Caroline.million@outlook.com) has been appointed as the Data Protection Officer
Their contact details are as above.

When, why and with whom do we share your personal information?
We sometimes share your personal information:
with other healthcare providers
when it is required or authorised by law
when it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain the patient’s consent
to establish, exercise or defend an equitable claim
for the purpose of confidential dispute resolution process
during the course of providing medical services

Only people who need to access your information will be able to do so. Other than in the course of providing medical services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.

Our practice will not use your personal information for marketing any of our goods or services directly to you without your express consent.

Processing of data is for direct patient care.  
Use of the data is
necessary in the exercise of official authority vested in the controller (Article 6(1)(e)); and,
necessary for compliance with a legal obligation (Article 6(1)(c)); and,
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 (Article 9(2)(h)).
necessary in order to comply with our legal obligations this practice may send data to NHS Digital when directed by the Secretary of State for Health under the Health and Social Care Act 2012;
necessary to carry out our legal duty to contribute to national clinical audits including sending data which is required by NHS Digital when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form.

Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.  

You have the right to: 

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

How can you access and correct your personal information at our practice?
You have the right to request access to, and correction of, your personal information.
Our practice acknowledges patients may request access to their medical records. We require you to put this request in writing and our practice will respond within a reasonable time.  Please write to;
Subject:  Subject Access Request
The Oakwood Surgery
Masham Road
Cantley
Doncaster
DN4 6BU
We expect to respond within 1 month of receipt of your request.

Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, we will ask you to verify that your personal information held by our practice is correct and current. You may also request that we correct or update your information, and you should make such requests in writing to
The Practice Manager
The Oakwood Surgery
Masham Road
Cantley
Doncaster
DN4 6BU
We expect to respond within 1 month of receipt of your request.

Retention periods
GP records are retained until death or until such time that a patient de-registers from the practice.  
How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice?
We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure.
The Practice Manager
The Oakwood Surgery
Masham Road
Cantley
Doncaster
DN4 6BU
We expect to respond within 1 month of receipt of your request.

You may also contact the ICO. Generally, the ICO will require you to give them time to respond before they will investigate. For further information visit https://ico.org.uk/ or call the ICO on 0303 123 1113