Greater Peterborough Network Ltd fully appreciates the importance of protecting and managing your data and maintaining your privacy. To ensure that we comply with these requirements all our data management and clinical processes fully recognise the data protection law in force in the UK (e.g. the Data Protection Act 1998 and from 25th May 2018, the Data Protection Act 2018 which includes relevant Articles from the EU General Data Protection Regulation (GDPR)
Please read the following information carefully to understand how we process your personal data.
For the purpose of the Data Protection Laws, the Data Controller is Greater Peterborough Network Ltd, whose address is G.16 Office Unit, Allia Future Business Centre, Peterborough United Football Club, London Road, Peterborough, PE2 8AN
When we refer to ‘we’, ‘us’ and ‘our’, we mean Greater Peterborough Network Ltd
Use of Your Personal Information
This privacy notice explains why we collect information about you and how that information may be used.
Our health care professionals who provide you with our services maintain records about your health and any treatment or care you have received previously. These records help to provide our clients with the best possible healthcare.
Your records may exist in several formats including electronic, paper, or a mixture of both, and we deploy many working organizations and approaches to ensure that such information is maintained within a confidential and secure environment. The records which we could hold about you may include the following information: –
- Personal details relating to you, including your address and contact details, carer, legal representative, and parents’ emergency contact details
- Any contact we have had or intend to have with you such as appointments, clinic or surgery visits, home visits, etc.
- Notes and reports about your health which is deemed to be of a sensitive nature
- Details about your referral, diagnostics procedures, treatment, and care
- Results of any additional relevant investigations
- Relevant information from other health professionals, relatives, or those who care for you
To ensure you receive the highest levels of care, your records will be used to facilitate the care that we provide. Anonymized information held about could, on occasions, be used to help protect the health and wellbeing of the general public and to help us manage our contracts with commissioners. Information could also be used within our organization for the purposes of clinical audits which in turn will provide monitoring of the quality of the services we provide.
Some of this information will be used for statistical purposes and we will ensure that individuals cannot be identified. For situations where we may contribute to research projects, we will always gain your explicit consent before releasing any relevant information.
Where healthcare professionals make use of the Cambridgeshire & Peterborough Training Hub (a Sub-Organisation of Greater Peterborough Network Ltd) we may store the following information about those people:
- Name, email, practice code, profession
- Courses that they have previously attended
This data will be stored by our newsletter distributer MailChimp. As part of this, we will gather statistics regarding email openings and clicks, to help us monitor and improve the newsletter for you. MailChimp is a Privacy Shield registered organization and complies with NHS Digital requirements as a non-EU-EA registered organization.
Maintaining the Confidentiality of Your Records
We will take all possible care to protect your privacy and will only use information collected with the law including: –
- Data Protection Act 1998 and the General Data Protection Regulation 2018 from 25th May 2018
- Human Rights Act 1998
- Common-Law Duty of Confidentiality
- Health and Social Care Act 2012 (if appropriate)
- Codes of Confidentiality, Information Security, and Records Management
Our staff are all trained and briefed in data protection principles and understand they have a legal obligation to keep information about you confidential. They also understand that information about you will only be shared with other parties if there is an agreed need to do so or for a legal reason. We will only share your data without your permission if there are very exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and/or in accordance with the Caldicot Principle 7 e.g. to share or not to share. This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott Principles. Whilst the Caldicott Principles were originally developed for NHS purposes, we have adopted the underlying principles in order to align with best practices.
All personal information that we manage is stored within the UK within a secure environment and we always use suitably protected methods and systems to transfer your personal information.
Legal Basis for Processing
Our legal basis for processing your data relies on certain conditions set out by GDPR Articles 6 and 9 which will be relevant from 25th May as part of the 2018 UK Data Protection Act.
It may be possible that we will share your information with other organizations, if this is required we will apply very strong controls. The current organizations who we share data with include: –
- GP Practices – Clinical Data
It is noted that the above list is not exhaustive, and we may contract with other external organizations to undertake the process of your personal information. These 3rd party organizations will abide by our stringent contractual conditions regarding the protection of personal data.
In some cases, you will be requested to provide positive consent if we intend to share your personal details with other organizations.
Access to Personal Information and Your Rights
You have a right under the Data Protection Act 1998 and the Data Protection Act 2018 from 25th May 2018, to request access to view or to obtain a copy of what information the organization holds about you and to have it modified should it be inaccurate. The process to access your records is known as a Subject Access Request (SAR) and the way it works is outlined below: –
- Your SARs request must be made in writing to the organization’s IG Lead at the address shown above or by email to SARs@greaterpeterboroughgps.nhs.uk
- The latest regulations state that there is no charge to have a copy of your electronic or paper information unless the request is repetitive.
- The request will be reviewed and if possible completed within one calendar month (subject to our possible requests for further clarification for you)
- You will need to provide adequate proof of your identity before we will release the requested details (e.g. full name, address, date of birth, NHS number, and details of your request), you must also provide two forms of identification
In addition to the right of access, under the Data Protection Act 2018, you will also have the following rights: –
- Erasure, which is the right to request that your personal data be removed from our systems be they paper or electronic – please note that under certain circumstances we are legally obliged to maintain a copy of your data for contractual and or statutory reasons
- Restriction of processing, this is the right for you to request that we only process certain parts of your data
- Objection – you have the right to object to the way that we are processing your data
- data portability – this concerns the right to request that we provide a copy of your data in an easily transportable format.
- Automatic processing – you have the right to object to the way we automatically process data – in the case of our organization we do not, at present, carry out automatic processing of your data
- If you have provided us with your consent to process your data for the purpose of providing our services, you have the right to withdraw this at any time. In order to do this should contact us by emailing or writing to the organization.
Retention of your data
Your data will be retained for no longer than is absolutely necessary and in accordance with our Documentation Management Lifecycle Policy and the associated Schedule of Retention
Updating Personal Details
If any of your details e.g. your name, address, or other personal data have changed or are incorrect you have a responsibility to inform the professional treating you who will arrange for the necessary updates to be made. This will help us to ensure that the data we hold about you is accurate and complete.
The Data Protection Act 1998 and the Data Protection Act 2018 requires organizations that control data to register with the Information Commissioners Office (ICO) website www.ico.org.uk
The organization is registered with the ICO as a Data Controller under the Data Protection Act 1998. The registration number is ZA155956 and can be viewed online in the public register at http://www.ico.gov.uk/
Should you have any concerns about how your information is managed by the Organisation please contact us at: –
Greater Peterborough Network Ltd
G.16 Office Unit,
Allia Future Business Centre,
Peterborough United Football Club,
If you are still unhappy following a review by the Organisation you can then complain to the Information Commissioners Office (ICO) via their website www.ico.org.uk
or in writing to: –
Information Commissioner’s Office
If you are happy for your data to be extracted and used for the purposes described in this Privacy Notice, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact us.