You are entitled to have a chaperone present for any consultation, examination or procedure and this would be a specially trained member of staff. If you would like the practice to provide a chaperone, please try to request this in advance so that arrangements can be made and avoid the need for the appointment to be rescheduled. Your healthcare professional may also require a chaperone to be present for certain consultations. 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. You are free to decline any examination or chose an alternative examiner or chaperone.

Clinical governance describes the structures, processes and culture needed to ensure that healthcare organisations – and all individuals within them – can assure the quality of the care they provide and are continuously seeking to improve it. The main components of clinical governance include: risk management, clinical audit, education training and CPD, evidence-based care, patient and carer involvement and staffing and management. If you would like further details on our clinical governance policy, please contact the practice manager.

All information from every contact you have with the practice is covered under the Data Protection Act 1998 and includes both electronic and paper records and face to face and telephone conversations. All staff within the practice will have access to your records to do their job and all are bound by the same rules of confidentiality. Anyone with access to your record is properly trained in confidentiality issues and is governed by both a legal and contractual duty to keep your details private.

Under 16

The duty of confidentiality owed to a person under 16 is as great as the duty owed to any other person. Young people aged under 16 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.

Useful Websites

• Confidentiality NHS Code of Practice
• Confidentiality and Mental Health
• Confidentiality Guidance

The purpose of this protocol is to set out the practice’s approach to consent and the way in which the principles of consent will be put into practice. Where possible, a clinician must be satisfied that a patient understands and consents to a proposed treatment, immunisations or investigation.

Implied Consent

Implied consent will be assumed for many routine physical contacts with patients. Where implied consent is to be assumed by the clinician, in all cases, the following will apply: an explanation will be given to the patient about what he/she is about to do and why. In all cases where the patient is under 18 years of age, a verbal confirmation of consent will be obtained and briefly entered into the medical record. Where there is a significant risk to the patient an ‘Expressed Consent’ will be obtained in all cases (see below).

Expressed Consent

Expressed consent (written or verbal) will be obtained for any procedure that carries a risk that the patient is likely to consider a substantial risk. A note will be made in the medical record detailing the discussion about the consent and the risks. A consent form may be used for the patient to express consent (see below).

Obtaining Consent

Consent (implied or expressed) will be obtained prior to the procedure. The clinician will ensure that the patient is competent to provide a consent (16 years or over) or has ‘Gillick Competence’ if under 16 years (has ‘sufficient understanding and maturity to enable them to understand fully what is proposed’). For children under 16 years, someone with parental responsibility should give consent on the child’s behalf by signing accordingly on the consent form.

NHS England aims to link information from all the different places where you receive care, such as hospital, community service and us your GP Surgery. This will allow them to compare the care you received in one area against the care you received in another.

Information will be held in a secure environment called the Health and Social Care Information Centre (HSCIC). The role of the HSCIC is to ensure that high quality data is used appropriately to improve patient care. The HSCIC has legal powers to collect and analyse data from all providers of NHS care. They are committed, and legally bound, to the very highest standards of privacy and confidentiality to ensure that your confidential information is protected at all times.

This data can also be used, with permission, for research purposes. If you do not wish to share data for research, you can opt out by contacting the practice.

• You can object to information containing data that identifies you from leaving the Practice. This will prevent identifiable information held in your record from being sent to the HSCIC secure environment. It will also prevent those who have gained special legal approval from using your health information forresearch.
• You can also object to any information containing data that identifies you from leaving the HSCIC secure environment. This includes information from all places you receive NHS care, such as hospitals. If you object, confidential information will not leave the HSCIC and will not be used, except in very rare circumstances for example in the event of a public health emergency.

For more information visit: www.england.nhs.uk/caredata

The law requires Doctors to provide some very limited information about certain things. The law says, for example, that Doctors must provide information to local authorities about some infectious diseases, e.g. if you had food poisoning. Very rarely, Doctors may be required to disclose information in order to detect a serious crime. Likewise, a court order can require Doctors to disclose certain information during a court case.

Summary Care Record (SCR)

If you decide to have a SCR, it will contain important information about any medicines you are taking, allergies you suffer from and any bad reactions to medicines that you have had. This does not include diagnosis or procedures.

Giving healthcare staff access to this information can prevent mistakes being made when caring for you in an emergency or when your GP practice is closed. Your Summary Care Record will also include your name, address, date of birth and your unique NHS Number to help identify you correctly. If you and your GP decide to include more information it can be added, but only with your express permission.

For more information:

• Phone 0300 123 3020
• or visit: digital.nhs.uk

Patient Access Data Sharing

The practice uses a clinical computer system called Patient Access to store your medical information. The system is also used by other GP practices, Child Health Services, Community Services, Hospitals, Out of Hours, Palliative Care services and many more. This means your information can be shared with other clinicians so that everyone caring for you is fully informed about your medical history including medication and allergies. You can control how your medical information is shared with other organisations that use this system.

1. Sharing Out – This controls whether your information stored in the practice can be shared with other NHS services (i.e. made shareable)
2. Sharing In – This controls whether information made shareable at other NHS care services can be viewed by us, your GP practice, or not. (i.e. shared in)

Benefits of sharing information

Sharing information can help improve understanding, responses to different treatments and potential solutions. Information will also help to:

• Provide better information to out of hours and emergency services
• Prevent Prescribing of medication to which you may already have an allergy
• Make more informed prescribing decisions about drugs and dosages Avoid unnecessary duplication in prescribing
• Increase clinician confidence when providing care
• Results of investigations, such as X-rays and laboratory tests
• Reduce referrals, ambulance journey admissions, tests, time wastage and visits to healthcare premises
• Find out basic details about you, such as address and next of kin.

Do I have a choice?

Yes. You have the right to prevent confidential information about you from being shared or used for any purpose other than providing your care, except in special circumstances. If you do not want information that identifies you to be shared outside this Practice, complete the sheet enclosed in this leaflet. This will prevent your confidential information being used other than where necessary by law.

Objecting on behalf of others

If you are a carer and have a Lasting Power of Attorney for health and welfare then you can object on behalf of the patient who lacks capacity. If you do not hold a Lasting Power of Attorney then you can raise your specific concerns with the patient’s GP.

If you have parental responsibility and your child is not able to make an informed decision for themselves, then you can make a decision about information sharing on behalf of your child. If your child is competent then this must be their decision.

If you have any special needs please let our staff know so that we can help and ensure you get the same support in the future. The surgery is all on ground level with disabled facilities.

Wheelchair access

The surgery is all on ground level (bungalow) and has direct flat access from the car park. The front door is automatic and there are parking spaces directly outside the front door.

Disabled Parking – Blue Badge Scheme

The Blue Badge scheme is for people with severe mobility problems. It allows Blue Badge
holders to park close to where they need to go.

Loop System

At the surgery we have a loop induction system at the reception desk to assist the hearing impaired. For more information on the loop hearing system visit Hearing Link website.

• British Deaf Association
• The Deaf Health Charity – SignHealth
• Action Hearing Loss
• Royal Association for Deaf People
• National Deaf Children’s Society

Blind/Partially Sighted

If you or family members are blind or partially sighted we can give you a CD or large print of our practice leaflet upon request. Please ask reception for further information.

For more advice and support for blind people please see the following websites:

• Royal National Institute of Blind People (RIND)
• Action for Blind People
• Blind.org.uk
• British Blind Sport

Guide Dogs

Guide dogs are welcome at the surgery but we ask that you be aware of other patients and staff who may have an allergy or fear of dogs.

Further Information:

• Guide Dogs

Other Disability Websites

• BID Services
• Disability Go
• Disabled People, your Rights, Benefits, Carers and the Equality Act
• Disability Rights UK
• Living with a Disability NHS Choices
• Disability Action
• Mencap

Our practice is committed to providing equality of opportunity and anti-oppressive practice. The organisation will not tolerate any kind of discrimination, harassment or oppressive practices and is committed to stopping it.

The organisation wishes to secure genuine equality of opportunity whether required by legislation or not, in all aspects of its activities.

It applies to the provision of services, all aspects of employment from recruitment, selection and training of staff and volunteers, to conditions of service and reasons of termination of employment.

The individual responsibility of everyone connected to and acting on behalf of the organisation.

We aim to ensure that:

• No person is treated less favourably than another on grounds of:
  • age
  • gender
  • marital status
  • physical or mental disability
  • race
  • responsibility for dependants
  • sexual orientation
  • caring responsibilities
  • political affiliation
  • religious belief
  • offending background
  • or any other improper ground
• All employees and job applications are treated fairly and consistently and are not subject
  to unjustifiable requirements or conditions.
• Services provided to the public do not disadvantage patients on any of the grounds
  detailed above.

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

All GP practices are required to declare the mean net earnings (e.g. Average pay) for GPs working to deliver NHS services to patients at each practice. This is in the interests of the greater public accountability recognising GP pay is ultimately funded from tax paid by the public.

The average pay for GPs working in St Mary’s Surgery in the last financial year was £58,290 before tax and national insurance (This is for 0 full-time GPs, 5 part-time GPs, and 1 Locum GP who worked in the practice for more than 6 months).

We aim to keep our surgery clean and tidy and offer a safe environment to our patients and staff 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

The impact of patients failing to attend appointment can be significant and may result in you not being able to see a particular GP on the day that you wish to.

In an attempt to try and resolve this, the practice has developed the following policy:

• If you fail to attend two consecutive appointments without informing us, we will write to you asking whether there are specific problems preventing you from letting us know.
• If you fail to attend a further appointment, you may be removed from the practice list and have to find an alternative.

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 British Medical Association (BMA) sets fees for non-NHS work?

The 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 suffer.

I only need the doctor’s signature – what is the problem?

When a GP 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 GP 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.

• Fees for non-NHS services

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.

Patients Privacy Notice

St Mary’s Surgery is a well-established GP Practice. Our General Practitioners and allied healthcare professionals provide primary medical care services to our practice population and are supported by our administrative and managerial team in providing care for patients.

This privacy notice explains how we as a data controller use any personal information, we collect about you as a patient of health care services provided by St Mary’s Surgery

Why do we collect your personal information?

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 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. The records will include both personal and special categories of data about your health and wellbeing.

What types of personal information do we collect about you?

We may collect the following types of personal information:

• Your name, address, email address, telephone number and other contact information
• Gender, NHS Number and date of birth and sexual orientation
• Details of family members and next of kin details
• Health (Medical) information, including information relating to your sex life
• Details of any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments and telephone calls.
• Results of investigations such as laboratory tests or x-rays
• Biometric data
• Genetic information

How will we use the personal information we collect about you?

We may use your personal information in the following ways:

• To help us assess your needs and identify and provide you with the health and social care that you require
• To determine the best location to provide the care you require
• To comply with our legal and regulatory obligations
• To help us monitor and manage our services
• To support medical research

Text (SMS) messages

If you have provided your mobile telephone number, we may use this to send automatic appointment reminders, requests to complete surveys or to make you aware of services provided by the surgery that we feel will be to your benefit.

If you do not wish to receive these text messages, please let the reception team know.

Call recording

Recordings of calls made and received by St Mary’s Surgery may be used to support the learning and development of our staff and to improve the service we provide to our patients.

They may also be used when reviewing incidents, compliments or complaints.

Call recordings will be managed in the same way as all other personal information processed by us and in line with current data protection legislation.

Data processors

We may use the services of a data processor to assist us with some of our data processing, but this is done under a contract with direct instruction from us that controls how they will handle patient information and ensures they treat any information in line with the General Data Protection Regulation, confidentiality, privacy law, and any other laws that apply.

How will we share your personal information?

We may share your personal information with other health and social care professionals and members of their care teams to support your ongoing health and or social care and achieve the best possible outcome for you. This may include:

Primary Care Network

St Mary’s Surgery is a member of the 3 Valleys Health Primary Care Network (PCN) so you may be contacted by or treated by one of the other practices within the PCN. In order to support and provide healthcare services to you, they will require access to your patient record.

Patient Referrals

With your agreement, we may refer you to other services and healthcare providers for services not provided by St Marys Surgery

Other Providers of Healthcare

We will share your information with other providers of healthcare services to enable them to support us in providing you with direct healthcare. This may include NHS organisations or private companies providing healthcare services for the NHS.

Care Homes or Social Care Services

Sometimes the clinicians caring for you may need to share some of your information with others who are also supporting you outside of the practice.

Local Authority

The local authority (council) provides health or social care services or assists us in providing direct healthcare services to you. We will share your personal information with them to enable this to take place.

Safeguarding

We will share your personal information with the safeguarding teams of other health and social care providers where there is a need to assess and evaluate any safeguarding concerns. Your personal information will only be shared for this reason when it is required for the safety of the individuals concerned.

Summary Care Record (SCR)

Your Summary Care Record is an electronic record of important patient information created from the GP medical records. It contains information about medications, allergies and any bad reactions to medications in the past. It can be seen by staff in other areas of the health and care system involved in your direct care.

During the height of the pandemic changes were made to the Summary Care Record (SCR) to make additional patient information available to all appropriate clinicians when and where they needed it, to support direct patients care, leading to improvements in both care and outcomes.

These changes to the SCR will remain in place unless you decide otherwise.

Regardless of your past decisions about your Summary Care Record preferences, you will still have the same options that you currently have in place to opt out of having a Summary Care Record, including the opportunity to opt-back in to having a Summary Care Record or opt back in to allow sharing of Additional Information. Further details about the SCR and your choices can be found here:

Summary Care Record supplementary transparency notice – NHS Digital

Integrated Care Records (ICR)

Bath and North East Somerset, Swindon and Wiltshire Integrated Care Record (BSW ICR) is a digital care record system for sharing information in Bath and North East Somerset, Swindon and Wiltshire.  It allows instant, secure access to your health and social care records for the professionals involved in your care.

Relevant information from your digital records is shared with people who look after you.  This gives them up-to-date information making your care safer and more efficient.

St Marys Surgery uses the system in the following way :

• We can access your data stored within the system
• We can access your data stored within the system and provide relevant information about you and your health

Further details about the BSW ICR and how your information can be found here:

Your care record – Bath and North East Somerset, Swindon and Wiltshire ICB

GP Connect

We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.

GP Connect is not used for any purpose other than direct care.

Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS Digital service called GP connect.

The NHS 111 service (and other services) will be able to book appointments for patients at GP practices and other local services. Further details about GP Connect are available here:

GP Connect privacy notice – NHS Digital

NHS Digital

In order to comply with its 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.

This practice contributes to national clinical audits and will send the data, which are 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. For example, the clinical code for diabetes or high blood pressure.

National Services

There are some national services like the national Cancer Screening Programme that collect and keep information from across the NHS. This is how the NHS knows when to contact you about services like cancer screening.

Risk Stratification

Risk Stratification, also known as ‘Health Risk Screening’, is a process that helps your GP determine whether you are at risk of any unplanned admission or sudden deterioration in health. By using information such as age, gender, diagnosis, and consideration of existing long-term conditions, medication history, patterns of attendance at hospital, admissions and periods of access to community care, your GP supported by the local Clinical Commissioning Group will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.

As part of the automated Risk Stratification process your pseudonymised personal data (anything that can identify an individual is replaced with code) will be shared with the Bath, Northeast Somerset, Swindon and Wiltshire Clinical Commissioning Group.

You have the right to object to your information being used in this way. However, you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Further details about Risk Stratification can be found here:

https://bswccg.nhs.uk/how-we-use-your-information

We may be required to share information with organisations in order to comply with our legal and regulatory obligations. This may include:

Care Quality Commission (CQC)

The CQC regulates health and care services to ensure that safe care is provided. The law requires that we must report certain serious events to the CQC, for example, when patient safety has been put at risk. Further information about the CQC can be found here:

http://www.cqc.org.uk/

Public Health England

The law requires us to share data for public health reasons, for example to prevent the spread of infectious diseases or other diseases which threaten the health of the population. We will report the relevant information to local health protection team or Public Health England. Further information about Public Health England can be found here:

https://www.gov.uk/guidance/notifiable-diseases-and-causative-organisms-how-to-report

Other NHS Organisations

Sometimes the practice will share information with other NHS organisations that do not directly care for you, such as the Clinical Commissioning Group. However, this information will be anonymous and does not include anything written as notes by the GP and cannot be linked to you.

We will not share your information with organisations other than health and social care providers without your consent unless the law allows or requires us to.

NHS National Data Opt-out

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 confidential patient information helps to ensure you get the best possible care and treatment.

The confidential patient information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care where allowed by law.

You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information, you do not need to do anything. If you choose to opt out your confidential patient information will still be used to support your individual care.

We do not share your confidential patient information for purposes beyond your individual care without your permission. When sharing data for planning and reporting purposes, we use anonymised data so that you cannot be identified in which case your confidential patient information isn’t required.

Information being used or shared for purposes beyond individual care does not include your confidential patient information being shared with insurance companies or used for marketing purposes and information would only be used in this way with your specific agreement.

Health and care organisations that process confidential patient information have to put systems and processes in place so they can be compliant with the national data opt-out. They must respect and apply your opt-out preference if they want to use or share your confidential patient information for purposes beyond your individual care.

St Marys Surgery are currently compliant with the national data-out policy as we do not share your confidential patient information for purposes beyond your individual care without your permission.

To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters

You can change your choice at any time.

How long do we keep your personal information?

We follow the NHS X Records Management Code of Practice 2021 which states that electronic patient records should be retained for 10 years from the date of death. At that point, all personal data we hold on you will be securely deleted.

We keep recordings of our calls for 6 years.

Legal basis

We have been commissioned by the Bath and North East Somerset, Swindon and Wiltshire Clinical Commissioning Group to provide a GP surgery service and it is necessary for the performance of this task in the public interest for us to process your personal data.

We will use your special categories of personal data, such as that relating to your race, ethnic origin, and health for the purposes of providing you with health or social care or the management of health or social care systems and services. Such processing will only be carried out by a health or social work professional or by another person who owes a duty of confidentiality under legislation or a rule of law.

In some circumstances, we may process your personal information on the basis that:

• it is necessary to protect your vital interests;
• we are required to do so in order to comply with legal obligations to which we are subject;
• we are required to do so for the establishment, exercise or defence of a legal claim;

or

• you have given us your explicit consent to do so.

Systmconnect:

We use Systmconnect provided by Systmone TPP to assist us in delivering healthcare services to our patients that choose to use Systmnconnect. You give your explicit consent (permission) for Systmone TPP to collect and use your personal information for the services offered and provided by Systmconnect.

Systmone TPP will share your personal data with us if you require advice, an appointment or remote consultation.

Full details about how Systmone TPP will process your personal information can be found on their privacy notice here:

SystmConnect Privacy Policy – TPP

Your rights

You have a right to:

• ask for a copy of the information we hold about you;
• correct inaccuracies in the information we hold about you
• withdraw any consent you have given to the use of your information;
• complain to the relevant supervisory authority in any jurisdiction about our use of your information
• in some circumstances:
  • ask us to erase information we hold about you;
  • request a copy of your personal data in an electronic format and require us to provide this information to a third party;
  • ask us to restrict the use of information we hold about you; and
  • object to the use of information we hold about you.

You can exercise these rights by contacting us as detailed below.

Data Protection Officer

Our Data Protection Officer (DPO) function is provided by the Medvivo Data Protection Officer service.

How to contact us

If you have any questions about our privacy notice, the personal information we hold about you, or our use of your personal information then please contact our Data Protection Team at:

BSWICB.Timsbury@nhs.net

 All data protection queries will be initially dealt with by the practice data protection team and escalated to the Medvivo Data Protection Officer service if required.

How to make a complaint

You also have the right to raise any concerns about how your personal data is being processed by us with the Information Commissioners Office (ICO):

https://ico.org.uk/concerns

0303 123 1113

Changes to our privacy notice

We keep our privacy notice under regular review and we will place any updates on this webpage. This privacy notice was last updated on 7^th October 2022

COVID-19 Privacy Notice Appendix

This appendix has been added to include any additional data processing completed by us during the Coronavirus (COIVD-19) outbreak.

Summary Care Record with Additional Information

In light of the current emergency, the Department of Health and Social Care has removed the requirement for your explicit consent prior to sharing additional information as part of the summary care record.

You can read more about the changes to your Summary Care Record here:

Supplementary Privacy Notice for Summary Care Records

GP Connect in support of the National COVID-19 Response

To help the NHS during the COVID-19 outbreak, NHS Digital are improving the access that doctors, nurses and healthcare professionals have to medical records and information, so that they can more safely treat and advise patients who are not in their usual GP practice, who call 111 or are seen in hospitals and other healthcare settings.

You can read more about GP Connect here:

GP Connect information for patients

GPES Data for Pandemic Planning and Research (COVID-19)

This practice is supporting vital coronavirus (COVID-19) planning and research by sharing your data with NHS Digital.

The health and social care system is facing significant pressures due to the coronavirus (COVID-19) outbreak. Health and care information is essential to deliver care to individuals, to support health, social care and other public services and to protect public health. Information will also be vital in researching, monitoring, tracking and managing the coronavirus outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations. This practice is supporting vital coronavirus planning and research by sharing your data with NHS Digital, the national safe haven for health and social care data in England.

Our legal basis for sharing data with NHS Digital

NHS Digital has been legally directed to collect and analyse patient data from all GP practices in England to support the coronavirus response for the duration of the outbreak. NHS Digital will become the controller under the General Data Protection Regulation 2016 (GDPR) of the personal data collected and analysed jointly with the Secretary of State for Health and Social Care, who has directed NHS Digital to collect and analyse this data under the COVID-19 Public Health Directions 2020 (COVID-19 Direction).

All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the data provision notice issued by NHS Digital to GP practices.

Under GDPR our legal basis for sharing this personal data with NHS Digital is Article 6(1)(c) – legal obligation. Our legal basis for sharing personal data relating to health, is Article 9(2)(g) – substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the COVID-19 Direction.

The type of personal data we are sharing with NHS Digital

The data being shared with NHS Digital will include information about patients who are currently registered with a GP practice or who have a date of death on or after 1 November 2019 whose record contains coded information relevant to coronavirus planning and research. The data contains NHS Number, postcode, address, surname, forename, sex, ethnicity, date of birth and date of death for those patients. It will also include coded health data which is held in your GP record such as details of:

• diagnoses and findings
• medications and other prescribed items
• investigations, tests and results
• treatments and outcomes
• vaccinations and immunisations

How NHS Digital will use and share your data

NHS Digital will analyse the data they collect and securely and lawfully share data with other appropriate organisations, including health and care organisations, bodies engaged in disease surveillance and research organisations for coronavirus response purposes only. These purposes include protecting public health, planning and providing health, social care and public services, identifying coronavirus trends and risks to public health, monitoring and managing the outbreak and carrying out of vital coronavirus research and clinical trials. The British Medical Association, the Royal College of General Practitioners and the National Data Guardian are all supportive of this initiative.

NHS Digital has various legal powers to share data for purposes relating to the coronavirus response. It is also required to share data in certain circumstances set out in the COVID-19 Direction and to share confidential patient information to support the response under a legal notice issued to it by the Secretary of State under the Health Service (Control of Patient Information) Regulations 2002 (COPI Regulations).

Legal notices under the COPI Regulations have also been issued to other health and social care organisations requiring those organisations to process and share confidential patient information to respond to the coronavirus outbreak. Any information used or shared during the outbreak under these legal notices or the COPI Regulations will be limited to the period of the outbreak unless there is another legal basis for organisations to continue to use the information.

Data which is shared by NHS Digital will be subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the coronavirus purpose will be shared. Organisations using your data will also need to have a clear legal basis to do so and will enter into a data sharing agreement with NHS Digital. Information about the data that NHS Digital shares, including who with and for what purpose will be published in the NHS Digital data release register.

For more information about how NHS Digital will use your data please see the NHS Digital Transparency Notice for GP Data for Pandemic Planning and Research (COVID-19).

National Data Opt-Out

The application of the National Data Opt-Out to information shared by NHS Digital will be considered on a case by case basis and may or may not apply depending on the specific purposes for which the data is to be used. This is because during this period of emergency, the National Data Opt-Out will not generally apply where data is used to support the coronavirus outbreak, due to the public interest and legal requirements to share information.

Your rights over your personal data

To read more about the health and care information NHS Digital collects, its legal basis for collecting this information and what choices and rights you have in relation to the processing by NHS Digital of your personal data, see:

• the NHS Digital GPES Data for Pandemic Planning and Research (COVID-19) Transparency Notice
• the NHS Digital Coronavirus (COVID-19) Response Transparency Notice
• the NHS Digital General Transparency Notice
• how NHS Digital looks after your health and care information

The NHS Constitution states that research is a core function of the NHS. Clinical research is a major driver of innovation and central to NHS practice for maintaining and developing high standards of patient care.

Ultimately, clinical research means patients get access to new treatments, interventions and medicines. Investment in research means better, more cost-effective care for patients.

How can I get involved?

There are different ways that patients can become involved in studies our practice is
participating in.

• A GP or nurse may talk to you about the study and ask whether you would consider
  taking part,
• You may be sent information through the post if we feel that you might be a suitable
  participant, or
• You may read information on the website about a current study you wish to take part in.

For further information, please contact reception. The notice board in the main waiting room also holds information on some of these studies.

Everyone has the human right to live a life that is free from abuse and neglect. Safeguarding means protecting vulnerable adults and children who are at risk and need support, and is fundamental to ensuring high-quality health and social care. If you are concerned that someone is at risk of abuse, don’t hesitate to report your concern with the Virgin Care ASIST team on 01225 396000. You can find more support and advice about services in B&NES, including how to report concerns, here.

People who may be particularly vulnerable to abuse include:

• disabled people who have physical or sensory impairments
• people who have learning difficulties
• people who experience mental ill health
• older people
• children
• people who live in care homes
• people with acquired brain damage
• People who misuse substances.

Identifiable information about you may be shared with others with your prior written consent. This includes friends and family, other healthcare providers and social services if you require any further treatment or services. This is also true if we are asked to provide information about you, for example, a medical report for insurance or mortgage purposes. In all circumstances we will only share appropriate and necessary information.

Sometimes the law requires us to pass on information e.g. to notify a birth or when we encounter infectious diseases that may endanger the safety of others. Anonymised patient information will also be used at local and national level to help the Health Board and Government plan services e.g. for diabetic care. If you do not wish anonymous information about you to be used in such a way, please let us know.

NHS Data Opt Out

The NHS wants to make sure you and your family have the best care now and in the future. Your health and adult social care information supports your individual care. It also helps us to research, plan and improve health and care services in England.

There are very strict rules on how this data can and cannot be used, and you have clear data rights. We are committed to keeping patient information safe and will always be clear on how it is used.

You can choose whether or not your confidential patient information is used for research and planning.

Your confidential patient information

Confidential patient information identifies you and says something about your health, care or treatment. You would expect this information to be kept private. Information that only identifies you like your name and address is not confidential patient information and may still be used.  For example, to contact you if your GP practice is merging with another.

Using your confidential patient information

Your confidential patient information is used in two different ways:

Your individual care

Health and care professionals may use your confidential patient information to help with your treatment and care.  For example, when you visit your GP, they may access your records for important information about your health.

Research and planning

Confidential patient information is also used to:

• plan and improve health and care services
• research and develop cures for serious illnesses

Most of the time, anonymised data is used for research and planning.  So your confidential patient information isn’t always needed.

Where you have a choice

If you don’t want your confidential patient information to be used for research and planning, you can opt out of this. If you do opt out, there are some specific situations where your data may still be used.  Data that does not identify you may still also be used.  Your confidential patient information will still be used to support your individual care. Any preference you set using this service will not change this.  If you opt out, your decision will only apply within the health and care system in England. Your opt-out will not apply to your health data where you have accessed health or care services outside of England, such as in Scotland and Wales.

Manage your choice

You may use our online service, or request a print-and-post form, to make or change your choice at any time. You can also request assistance or make your choice using our telephone service. If you do not wish to opt out, you don’t have to do anything at all.

You can also manage a choice on behalf of another individual by proxy. For example, if you are a parent or guardian of a child under the age of 13.

Please click on the following link if you wish to Manage your choice

More information can also be viewed at www.nhs.uk/your-nhs-data-matters

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

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 requires 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 GP2GP 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 and cancelling appointments and also for ordering your repeat prescriptions and viewing a summary of your medical records on-line. If you do not already have a user name and password for this system – please register your interest with our reception staff.

We welcome all comments on the services provided by the Practice.

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. We’d also like to hear from you if you are pleased with the service you’ve received.

We’ll let the staff involved know and share the good practice across our teams.

You may write to us or contact us by phone or fax. Our details can be found on our Contact Us page.

If your complaint has been investigated by the practice and you are not happy with how
the practice has handled this then you may consider contacting the following advice
agencies:

NHS Bath and North East Somerset Clinical Commissioning Group Patient Advice and
Liaison Service (PALS)

PALS is impartial and will work with you to try to resolve a difficulty or problem and can act on your behalf if you wish.  We will discuss with you the best ways to resolve your concerns or problems and will agree with you what action to take for your individual circumstances, contact us on:

Freephone: 0300 013 4762
Email: BSCCG.Feedback@nhs.net
Address: PALS and Complaints Manager, NHS Bath and North East Somerset Clinical
Commissioning Group, 1 st Floor, Kempthorne House, St Martin’s Hospital, Clara Cross Lane, Bath BA2 5RP.

NHS England

By post to: NHS England
PO Box 16738
Redditch
B97 9PT
By email to: england.contactus@nhs.net

If you are making a complaint please state: ‘For the attention of the complaints team’ in the subject line.

By telephone: 0300 311 22 33

Our opening hours are: 8am to 6pm Monday to Friday, except Wednesdays when we open at the later time of 9.30am.

Health Services Ombudsmen

Telephone: 0345 015 4033
Textphone: 0300 061 4298
(open 8.30am – 5.30pm, Monday to Friday)
Email: phso.enquiries@ombudsman.org.uk
Website: www.ombudsman.org.uk

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. 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 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

The Surgery is an approved training practice for the training of General Practice Registrars
(GPRs). Being an approved training practice means that:

• patients can directly contribute to the training of future GPs
• patients who consult with the GPR will have longer consultations
• it keeps all doctors and nurses in touch with new medical developments and skills
• it improves all doctors and nurse’s consultation and training skills
• it ensures that clinical standards and standards of medical record keeping are maintained
• it helps with recruitment of high quality doctors to the practice for job vacancies

GPRs are qualified doctors in training who have already worked in hospitals as junior doctors for at least 3 years and have now decided that they would like to specialise in General Practice.

In order to qualify as a GP all doctors have to complete Postgraduate Specialist Training which includes at least 18 months training in General Practice.

Very occasionally, as part of an essential component of training in all medical practice, your consultation may be filmed and reviewed later by the trainer and GPR. We hope that all our patients will be willing to take part in these educational consultations to help us all in improving and maintaining our medical and consultation skills. All video recordings are strictly confidential and are used for teaching only. We will not video your consultation without your consent.

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 48 working hours.
• 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 20 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:

• GOV.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.

Removal from the Practice List

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.