Privacy Notice

 

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Purpose of this policy and privacy notice

Beaumont Elms Practice takes the privacy of all our patients very seriously; we are committed to protecting the privacy and security of your personal information. This privacy notice explains why we collect information about you, how that information may 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. We will keep your information in written form and/or in digital form.

 

Our commitment to data privacy and confidentiality 

As a healthcare provider, we collect, store, use and share personal and confidential information about our patients, including special category health data, in accordance with UK Data Protection laws and other applicable legislation.  We are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation.  

This includes:

  • General Data Protection Regulation (EU) 2016/679 (GDPR) now known as the UK GDPR
  • The Data Protection Act (DPA) 2018
  • Law Enforcement Directive (Directive (EU) 2016/680) (LED)
  • 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 laws concerning privacy, confidentiality, the processing and sharing of personal data, including:

  • Human Rights Act 1998
  • Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015
  • Common law duty of confidentiality 
  • Privacy and Electronic Communications (EC Directive) Regulations.

The practice is compliant with the national data opt-out policy.

 

Our lawful basis for processing

Data Protection Laws require us to rely on one or more lawful ground to process your personal information. We will only use your personal data when the law allows us to. Most commonly, we will process your personal information in the following circumstances:

Direct Care under UK GDPR:

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
  • Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine.
 

What information do you hold about me?

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.

 

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. It is important that we are made aware of any changes immediately in order that no information is shared in error. In addition, if you wish to change your choices about how we contact you by phone, text or email, please contact us.

 

Mobile Telephone Number

If you provide us with your mobile phone number, we may use this to send you reminders about your appointments or other health screening information. It is within our legal duty as a public authority to keep our patients updated with important information. Please let us know if you do not wish to receive reminders on your mobile. We 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.

 

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.

 

How we use your information

We use and share the information in your GP record to support a wide range of activities relating to your healthcare. Common examples include:

  • Enabling the healthcare professionals, both internally and externally who care for you to understand your health conditions, treatments and personal needs
  • Providing our surgery administration staff secure and confidential access to carry out various functions necessary for the performance of their role (for example booking appointments and updating records)
  • Referring you to other healthcare providers when you need more specialist assessments, tests or treatments
  • Sharing samples with laboratories and sharing your results with other professionals involved in your care
  • Sending your prescriptions to a pharmacy and dealing with your medication queries
  • Recording allergies and other important health information
  • Receiving reports of appointments you have attended elsewhere, e.g. at a hospital clinic or other local health service
  • Investigating and responding to any queries or complaints you have about your care
  • Texting or emailing you with information about healthcare services or treatments

We may use selected information from patient records to check that the care we provide is safe and to help us improve our services. Any information we use for this purpose is de-identified to protect your confidentiality. Some examples include:

  • Auditing the treatment we provide, to check our care is in line with the latest recommendations
  • Identifying people at risk of developing particular health conditions or who may require additional support (known as ‘case finding’)
  • Recording and reviewing any adverse events or ‘near misses’, to ensure our services are safe
  • Monitoring how long patients are waiting for our appointments
  • Supporting staff training and the development of services to meet patient need

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you 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 in this way it is necessary for them to have a legitimate basis in law. This is explained further in 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 
 

How do you keep my information safe?

Your GP record is held securely in a NHS-approved system. The information in your GP record is used by authorised health professionals and administrators providing your care.

Only authorised healthcare professionals and administrators with a legitimate reason to access your GP record may do so and they are legally required to protect your confidentiality.

Everyone working for our organisation is subject to a legal duty of confidentiality. The information you provide to us is kept in confidence will only be used for lawful purposes;

  • Our staff receive training on data protection and confidentiality 
  • Our electronic records are backed up securely in line with NHS standard procedures and information is held in secure locations and restricted to authorised personnel
  • We will only ever use or pass on information about you if we reasonably believe that the recipients have a genuine need for it
  • We check that only the minimum and necessary amount of data is shared or accessed
  • We use smartcards and passwords to protect our IT systems, to ensure that only the right people have access to your data
  • We use encrypted email and storage systems on the secure NHS network, which make it harder for someone to intercept or ‘hack’ your information
  • We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care

We only use information collected lawfully in accordance with: 

  • Data Protection Legislation
  • Human Rights Act
  • Common Law Duty of Confidentiality
  • NHS Codes of Confidentiality and Information Security
  • Health and Social Care Act 2015
  • And all other applicable UK legislation.

We always maintain our duty of confidentiality to you. We will only ever use or pass on information about you if we reasonably believe that others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

 

How long do we retain your information?

Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your personal information only for as long as we believe it is necessary to fulfil the purposes for which the personal information was collected. This includes for the purpose of meeting any clinical, legal, accounting or other reporting requirements or obligations.  The periods for which your information shall be held will be in accordance with NHS Digital’s Record Management Code of Practice for Health and Social Care.

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 with our information asset registers, in line with the Records Management Code of Practice for 2021.

You may request that we delete the personal information that we hold about you. There are instances where applicable law or regulatory requirements allow or require us to refuse to delete this personal information. In the event that we cannot delete your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. 

 

Sharing required by law

Occasionally ,we are required by law to share your information with other agencies. In these circumstances we will try to inform you before we are required to disclose and we only disclose the minimum information that the law requires us to do so. These situations are uncommon, but examples might be:

  • To safeguard children or vulnerable adults who may be at risk of neglect or abuse
  • For the purposes of detecting or preventing a serious crime
  • To report notifiable infectious diseases to public health
  • To report cases of female genital mutilation or suspected radicalisation
  • If we are required to disclose the information by a court order.
  • To a regulatory body 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

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

 

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.

 

Individual rights under UK GDPR

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

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

Your right to opt out of data sharing and processing

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’.

There are two forms of opt-out available and you can change your mind about your choice at any time.

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 direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to apply a Type 1 Opt Out to your record you should make your wishes know to the Practice Manager. 

National Data Opt-Out 

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 share a patient’s confidential patient information for purposes beyond their individual care. 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. 

To find out more or to register your choice to opt out, please visit the NHS website

At these websites, 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 

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only ever be used in this way with your specific agreement. 

 

Right of Access to your Information (Subject Access Request SAR)

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 are 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, or via the practice’s system.

 

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’.

 

Data Protection 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 Information Commissioner's Office website 

We are registered under registration number Z5846727. 

Our designated Data Protection Officers are the Practice Manager, Kate King, and Seraphim Patel, GP Data Protection Officer at the Buckinghamshire, Oxfordshire & West Berkshire (BOB) Integrated Care Board (ICB).

If you have any queries or wish to make a request in relation to your information, please contact:

Data Protection Officer
Beaumont Street Surgery
19 Beaumont Street
Oxford
Oxfordshire
OX1 2NA

Contact us online

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

If a complaint should arise, and as part of the complaint process, we may need to share information related to the complaint to our indemnity insurer or legal team.

For independent advice about data protection, privacy and data-sharing issues, you can contact the Information Commissioner

 

Medical Student Placements 

Our practice is involved in the training of medical students. As part of this programme medical students will work in the practice and may be involved in your care. If staff would like a student to be present, they will always ask for your permission before the start of the consultation. The treatment or care you receive will not be affected if you refuse to have a student present during your appointment. It is usual for GPs to discuss patient case histories as part of their continuing medical education or for the purpose of training GPs and/or medical students. In these situations, the identity of the patient concerned will not be revealed.

 

Medical examiner service

Following the death of any patients we are now obliged to inform our NHS Trust, Medical Examiner Service. 

Medical examiner offices at acute trusts now provide independent scrutiny of non-coronial deaths occurring in acute hospitals.  The role of these offices is now being extended to also cover deaths occurring in the community.

Medical examiner offices are led by medical examiners, senior doctors from a range of specialties including general practice, who provide independent scrutiny of deaths not taken at the outset for coroner investigation. They put the bereaved at the centre of processes after the death of a patient, by giving families and next of kin an opportunity to ask questions and raise concerns. Medical examiners carry out a proportionate review of medical records, and liaise with doctors completing the Medical Certificate of Cause of Death (MCCD). The Practice will share any patient records with the service upon request. 

 

Storage of records

We use a locally commissioned Records Storage and Management Service, which entails the off-site storage of paper-based medical records. This service includes the secure handling, scanning, transportation, storage and retrieval of documents. Oasis Group, the supplier awarded the contract, has been vetted and complies with a range of accreditations including, but not limited to, ISO 9001 and ISO 2700. This ensures it provides an enhanced safe and secure full end-to-end document management solution that is appropriate for the storage of documents that are sensitive in nature.

 

Changes to this privacy notice

We will keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in March 2025.

Appendix A

The Practice will share patient information with these organisations where there is a legal basis to do so.

Commissioning and contractual purposes Planning Quality and Performance

Purpose

Anonymous data is used by the Integrated Care Board (ICB) for planning, performance and commissioning purposes, as directed in the practices contract, to provide services as a public authority.

Legal Basis

UK GDPR 6 1(b) Contractual obligation as set out in the Health and Social Care Act for Quality and Safety 2015 

Patients may opt out of having their personal confidential data used for planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to apply a National Data Opt Out

Processor

Berkshire, Buckinghamshire & Oxfordshire ICB (Integrated Care Board)

Summary Care Record Including additional information

Purpose

The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

Legal Basis - Direct care under UK GDPR

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ) ‘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...”

Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be completed online and returned to the practice.

Please note that by opting out of having your information shared with the Summary Care Record could result in a delay to care that may be required in an emergency.

Processor

NHS England

Research

Purpose

We may share anonymous patient information with research companies for the purpose of exploring new ways of providing healthcare and treatment for patients with certain conditions. This data will not be used for any other purpose. 

Where personal confidential data is shared your consent will be required.

Where you have opted out of having your identifiable information shared for this Planning or Research your information will not be shared.

Legal Basis

  • Articles 6(1)(a) and 9(1)(a) – explicit consent; or
  • Article 6(1)(c) (where we are legally obligated to share your personal data) for your standard personal data and Article 9(2)(j) (scientific research) for your health data.

Where identifiable data is required for research, patient consent will be needed, unless there is a legitimate reason under law to do so or there is support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales.

Sharing of aggregated non identifiable data is permitted.

Processor

NIHR Clinical Research Network and Clinical Practice Research Datalink (CPRD) MHRA

Individual Funding Requests

Purpose

We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our standard NHS contract.

The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time but this may affect the decision to provide individual funding. 

Legal Basis

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ) ‘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...”

Data processor

Berkshire, Buckinghamshire & Oxfordshire ICB (Integrated Care Board)

Safeguarding Adults

Purpose

We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of individuals.

Consent is not required to share information for this purpose.

Legal Basis – in some cases consent will be required otherwise:

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ) ‘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...”

Data Processor

Oxfordshire Safeguarding Adults Board

Safeguarding Children

Purpose

We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children.

Legal Basis

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ) ‘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...”

Consent may not be required to share this information.

Data Processor

Oxfordshire Safeguarding Children Board

Risk Stratification – Preventative Care

Purpose

‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops. 

Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information.  This can help us identify and offer you additional services to improve your health. 

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.

Type of Data

Identifiable/Pseudonymised/Anonymised/Aggregate Data

Legal Basis 

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ) ‘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...”

Processors

Berkshire, Buckinghamshire & Oxfordshire ICB (Integrated Care Board)

Public Health Screening programmes (identifiable)

  • Notifiable disease information (identifiable)
  • Smoking cessation (anonymous)
  • Sexual health (anonymous)
  • Vaccination Programmes

Purpose

Personal identifiable and anonymous data is shared.

The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service to name a few. The law allows us to share your contact information, and certain aspects of information relating to the screening with Public Health England so that you can be appropriately invited to the relevant screening programme.

More information can be found on the NHS website or by speaking to the practice.

Patients may not opt out of having their personal information shared for Public Health reasons.

Patients may opt out of being screened at the time of receiving an invitation.

Legal Basis

Sharing personal data for this purpose is governed by the COPI Reg 2.

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article 9(2)(h) ) ‘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...”

Data Processors

Thames Valley Public Health Team, NHS England SE, UK Health Security Agency (HSA) South East, Oxfordshire County Council, Public Health dept

Direct Care

  • NHS Trusts
  • Community Providers
  • Pharmacies
  • Enhanced care providers
  • Nursing Homes
  • Other Care Providers

Purpose

Personal information is shared with other secondary care trusts and providers in order to provide you with individual direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service. 

Legal Basis

The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following:

  • Article 6 1 (e) direct care and 9 2 (h) to provide health or social care.

In some cases patients may be required to consent to having their record opened by the third party provider before patients information is accessed. Where there is an overriding need to access the GP record in order to provide patients with lifesaving care, their consent will not be required.

Processors

Oxford Health NHS Foundation Trust, Oxford University Hospitals NHS Foundation Trust, Local pharmacies – you will be informed of which pharmacy you are referred to at the time of booking an appointment with them, care homes.

Care Quality Commission (CQC)

Purpose

The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.

More details on how they ensure compliance with data protection law (including UK GDPR) and their privacy statement are available on their website.

Legal Basis

  • Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) ) ‘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...”

Processors

Care Quality Commission

Population Health Management

  • BOB ICB
  • NHS England
  • The Thames Valley & Surrey (TVS) Care Records

Purpose

Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data in order to:

  • Understand the health and care needs of the care system’s population, including health inequalities
  • Provide support to where it will have the most impact
  • Identify early actions to keep people well, not only focusing on people in direct contact with services, but looking to join  up care across different partners.

This links to the Risk Stratification activity identified above.

Type of Data

Identifiable/Pseudonymised/Anonymised/Aggregate Data. 

Only organisations that provide your care will see your identifiable data.

Anonymous data is also shared with the National Association of Primary Care to support work on health inequalities. In addition to the BOB ICB, the TVS Shared Care Record is also undertaking this activity over the Thames Valley & Surrey area. To opt out of this data sharing, patients can register a “Type One Opt-Out” with the GP practice. You can find more information about how to do this on the NHS website.

Legal Basis

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; 
  • Article 9(2)(g): “processing is necessary for reasons of substantial public interest”
  • Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine 
  • Article 9(2)(i): “processing is necessary for reasons of public interest in the area of public health”

Data Processors

Optum, Cerner, Graphnet

Payments, invoice validation

Purpose

Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amounts paid per patient per quarter varies according to the age, sex and other demographic details for each patient. 

There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. 

Practices can also receive payments for certain national initiatives such as immunisation programs.

Practices may also receive incomes relating to a variety of non-patient related elements such as premises. 

Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. 

In order to make patient-based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.

Legal Basis

  • Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.”
  • And Article 9(2)(h) ) ‘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...”

Data Processors

NHS England, Public Health, Berkshire, Buckinghamshire & Oxfordshire ICB (Integrated Care Board)

Patient Record Database

Purpose

Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date.  Your record will follow you as you change surgeries throughout your life. 

Closed records will be archived by NHS England.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

EMIS, Docman and PCSE (Primary Care Support England)

Medical Reports Subject Access Requests

Purpose

Your medical record may be shared in order that:

  • Solicitors/persons acting on your behalf can conduct certain actions as instructed by you. 
  • Insurance companies seeking medical reports where you have applied for services offered by them can have a copy of your medical history for a specific purpose. 

Legal Basis

  • Article 6(1)(a) – consent for personal data; and
  • Article 9(2)(a) – explicit consent for special-category data.

Processor

IGPR, solicitors, insurance organisations

Medicines Management Team Medicines Optimisation

Purpose

Your medical record is shared with the medicines management team, pharmacists, in order that your medication can be kept up to date and any necessary changes to medication can be implemented.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

Berkshire, Buckinghamshire & Oxfordshire ICB (Integrated Care Board)

GP Federation 

Providing services such as: 

  • Urgent Care Centre 
  • College Nursing 
  • Primary Consultation & Advice Service (CAS) 
  • Community Gynaecology Service

Purpose

Your medical record will be shared with PML (Principal Medical Limited) in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics. The Federation will be acting on behalf of the GP practice.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

PML

Primary Care Network (PCN) 

Healthier Oxford Network (HON) includes services such as

  • Enhanced access
  • Social prescribing
  • Physiotherapy

Purpose

Your medical record will be shared with the Healthier Oxford Network in order that they can provide direct care services to the patient population. 

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

Beaumont Elms Practice, Summertown Health Centre, Banbury Road Medical Centre, Luther Street Medical Centre 

Oxford City Primary Care (OCPC) Ltd 

Providing services such as: 

  • Primary Care Visiting Service
  • Urgent Care Centre
  • Physiotherapy

Purpose

Your medical record will be shared with our local Oxford City Primary Care company in order that they can provide direct care services to the patient population. This could be in the form of the Urgent Care Centre or the Primary Care Visiting service. 

Access to the Primary Care record and PCN EMIS Clinical Services care record for both the GP Practice and the cross-organisational multi-disciplinary teams will ensure that healthcare professionals are able to make informed, timely decisions when planning, delivering and/or managing your care and treatment. Authorised staff involved in your care can securely view your primary care record and new information captured can be instantly shared back to your registered GP Practice. 

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

EMIS, Oxford City Primary Care (OCPC), Healthier Oxford Network PCN

Smoking Cessation

Purpose

Personal information is shared in order for the smoking cessation service to be provided.

Only those patients who wish to be party to this service will have their data shared.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

Stop for Life Oxon 

Police

Purpose

Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared, consent will not always be required. 

The Police will require the correct documentation in order to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime. Or where the information is necessary to protect a person or community.

Legal Basis

  • UK GDPR –6 1 (c) Legal Obligation. Article 6 1 (f) legitimate interest Article 9 2 (f) requests for legal reasons

Processor

Police Constabulary

Coroner

Purpose

Personal health records or information relating to a deceased patient may be shared with the coroner or medical examiner upon request.

Legal Basis

  • Article 6(1)(c) – necessary under a legal obligation to which the controller is subject”;
  • and Article 9(2)(h)– “processing is necessary for the purposes of preventive 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”

Processor

The Coroner

Medical Examiners’ Office for Oxfordshire

Purpose

Medical records associated with deceased patients are outside scope of the UK GDPR. However, next of kin details are within the scope of the UK GDPR. We will share specified deceased patient records and next of kin details with the Medical Examiners within Oxford University Hospitals NHS Foundation Trust. 

Legal Basis

  • Article 6(1)(c) – necessary under a legal obligation to which the controller is subject”;
  • and Article 9(2)(h)– “processing is necessary for the purposes of preventive 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”

Processor

Medical Examiners service, OUH NHS FT

Private Healthcare Providers

Purpose

Personal information shared with private health care providers in order to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with private providers.

Legal Basis

  • Articles 6(1)(a) and 9(2)(a) consent by the patient given under contract to the provider.

Provider

BUPA, Nuffield Health, etc, private care home

Messaging Service

Purpose

Personal identifiable information shared with the messaging service in order that messages including; appointment reminders; results; campaign messages related to specific patients health needs; and direct messages to patients, can be transferred to the patient in a safe way.

Legal Basis

  • UK GDPR Article 6 1 (b) Contract, Article 6 1 (e) Public task, Article 9 2 (h) Health data

Provider

AccuRX, NHS App, eConsult 

Electronic Messaging

Purpose

Personal identifiable information shared with the organisations in order that the patient and practice can communicate and information can be transferred to the patient in a safe way.

Legal Basis

  • UK GDPR Article 6 1 (b) Contract, Article 6 1 (e) Public task, Article 9 2 (h) Health data

Providers

NHS Mail, eConsult, Treeview designs,

Telephony

Purpose

The practice uses an internet based telephony system that records telephone calls, for their own purpose and to assist with patient consultations. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients.

Legal Basis

While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way.

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ and Article 9(2)(h) Health data as stated above

Provider

Surgery Connect – X-ON, 

Remote consultation

Including; 

  • Video Consultation
  • Clinical photography

Purpose

Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Patients may be videoed or asked to provide photographs with consent.  There are restrictions on what the practice can accept photographs of. No photographs of patients who cannot consent to the process. No pictures of children.

Processor

e-Consult, AccuRX

MDT (multi-disciplinary team) meetings

Purpose

For some long term conditions, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions. Personal data will be shared with other agencies in order that mutual care packages can be decided.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

MS Teams

General Practice Extraction Service (GPES)

  1. At risk patients data collection Version 3
  2. CVDPREVENT Audit
  3. Physical Health Checks for people with Severe Mental Illness
  4. National Obesity Audit

Purpose

GP practices are required to provide data extraction of their patients personal confidential information for various purposes to NHS England. The objective of this data collection is on an ongoing basis to identify patients registered at General Practices who fit within a certain criteria, in order to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction, by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work:  

  1. At risk patients including severely clinically vulnerable
  2. NHS England has directed NHS England to collect and analyse data in connection with Cardiovascular Disease Prevention Audit
  3. GPES Physical Health Checks for people with Severe Mental Illness (PHSMI) data collection.
  4. National Obesity Audit - NHS England Digital

Legal Basis

All GP Practices in England are legally required to share data with NHS England for this purpose under section 259(1)(a) and (5) of the Health and Social Care Act 2012 

Further detailed legal basis can be found in each link. 

Any objections to this data collection should be made directly to NHS England.

Processor

NHS England

Medication/Prescribing

Purpose

 Prescriptions containing personal identifiable and health data will be shared with organisations who provide medicines management including chemists/pharmacies, in order to provide patients with essential medication regime management, medicines and or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. 

Pharmacists may be employed to review medication, Patients may be referred to pharmacists to assist with diagnosis and care for minor treatment, patients may have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver care and medication 

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

Pharmacy of choice

Professional Training

Purpose

We are a training surgery. On occasion you may be asked if you are happy to be seen by one of our GP registrars, pharmacists or other clinical team to assist with their training as a clinical professional. 

You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE (Health Education England).

Legal Basis

  • 6 1 (a) consent, patients will be asked if they wish to take part in training sessions.
  • 9 2 (a) - explicit consent will be required when making recordings of consultations.

Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.

Processor

RCGP, HEE

Learning Disability Mortality Programme

  • LeDer

Purpose

The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with this criteria will be shared with NHS England.

Legal Basis

It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information who fit within a certain criteria. 

Processor

Berkshire, Buckinghamshire & Oxfordshire ICB (Integrated Care Board), NHS England

Shared Care Record

Purpose

In order for the practice to have access to a shared record, the Integrated Care Board has commissioned a number of systems including GP connect, which is managed by NHS Digital, which will enable patient information to be used for a number of care related services. These systems may also include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population. 

Where data is used for secondary uses no personal identifiable data will be used. 

Where personal confidential data is used for Research explicit consent will be required. 

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

NHS England 

Local shared care record;

  • Thames Valley & Surrey (TVS) Care Record
  • Health Information Exchange (HIE)

Purpose

Health and Social care services are developing shared systems to share data efficiently and quickly.  It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment.  It is also quicker for staff to access a shared record than to try to contact other staff by phone or email.

Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job.  Systems do not share all your data, just data which services have agreed is necessary to include.

For more information on the TVS Care Records and HIE, you can visit their website

If you wish to opt out from this data sharing, you will need to let the practice know so they can change your record sharing settings. Please contact the surgery and ask us to record that you have refused consent for upload to local shared electronic record. 

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processors

Graphnet, Cerner

Patient Participation Group (PPG)

Purpose

The practice has an active Patient Participation Group (PPG), which meets quarterly. Its aim is to involve patients on the development of services provided by the practice and to influence the provision of local health services. Any patient can join the PPG. To participate, you will need to complete a form which collects personal information about you. We use this information to allow the practice team to contact you.

Legal Basis

  • 6 (1) (a) Consent, patients will be asked if they wish to take part in the Patient Participation Group.

NHS South, Central and West Commissioning Support Unit – Child Health Information Services (CHIS)

Purpose

South, Central and West Child Health Information Services (SCW CHIS) is commissioned by NHS England to support the monitoring of care delivered to children. Personal data is collected from the child’s GP record to enable health screening, physical examination and vaccination services to be monitored to ensure that every child has access to all relevant health interventions.

For more information: Fair Processing Notice Child Health Information Services

Legal Basis

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’;
  • and Article 9(2)(h) ‘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...”

Processors

SCW, Apollo Medical Software Solutions, System C

Oxfordshire MIND

An Oxfordshire MIND worker is embedded in the practice supporting patient wellbeing.  Medical data will be used to provide care to people who use the service and occasionally for safeguarding processes.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processors

Oxfordshire MIND

Record storage

Off-site storage of paper-based medical records. The service includes the secure handling, storage and retrieval of medical records. 

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’
  • And Article 9(2)(h) ) ‘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...”

Processor

Oasis Group

CCTV

The surgery provides facilities to members of the public, staff and suppliers and to keep these groups safe the surgery uses CCTV to prevent and detect crime and anti-social behaviour.  The surgery does this by storing and processing photographic/ video imagery.

Legal Basis

  • Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’

Processors

Executive Alarms

Providing NHS Services

Beaumont Street Surgery
19 Beaumont Street
Oxford
Oxfordshire
OX1 2NA

Elms Road Surgery
Elms Road
Oxford
OX2 9JS

Telephone: 01865 240501