Accessible Information Standard
The standard aims to make sure our patients, or their carers, with a disability, sensory loss or impairment are provided with information they can easily read or understand with support, for example large print, so they can communicate effectively with health and social care services
If you have any information or communication support needs relating to a disability, impairment or sensory loss please let us know.
We are a baby-friendly Practice. You are welcome to breastfeed your baby; please ask a Receptionist if you would like to sit somewhere private.
NHS England is currently involved in developing a modern information system, to help improve health services.
To discover how information about you helps us to provide better care you can visit the NHS England website or download the leaflets shown below.
Health and Social Care Act 2012
Collection of your personal data under the Health and Social Care Act 2012.
Care Quality Commission (CQC)
The Practice is registered with CQC. The aim of CQC is to ensure that patients can expect all health and adult social care services to meet essential standards of quality. As part of this the CQC will occasionally undertake inspections at the Practice. As part of inspection, the CQC Representative will talk to patients as well as the Practice Team to gather information. To support this they may also access documents and records, including patient information.
NHS England and the Care Quality Commission commit to a common purpose to improve outcomes for patients
NHS England and the Care Quality Commission (CQC) are committed to working together to deliver the statutory duty set out in the Health and Social Care Act 2012 to co-operate and to deliver their common purpose, which is to improve outcomes for patients.
The Partnership Agreement aims to foster a culture in which there is support, challenge, engagement, openness and co-ordination at all levels.
The agreement formalises existing close working between the CQC and NHS England, embedding a shared commitment to work together to achieve three priorities that will facilitate improved outcomes for patients.
NHS England and CQC will:
- Agree an information exchange protocol to share information and intelligence about the quality of care to spot potential problems early and manage risk
- Implement the mechanisms proposed by the National Quality Board (NQB) in their document ‘Quality in the new Health System: Maintaining and Improving Quality from April 2013 (January 2013)’, on how the healthcare system should prevent, identify and respond to serious failures in quality.
- Set the tone for ways of working nationally, locally and in the wider landscape of our organisations and strategic partners in healthcare.
- The agreement between NHS England and CQC cements joint working at national level and sets out the values and behaviours we want to demonstrate through effective joint working.
Our Practice is committed to providing a safe, comfortable environment where patients and staff can be confident that best practice is being followed at all times; the safety of everyone is of paramount importance.
All medical consultations, examinations and investigations are potentially distressing. Patients can find examinations, investigations or photography involving the breasts, genitalia or rectum particularly intrusive (these examinations are collectively referred to as ‘intimate examinations’). Consultations involving dimmed lights, the need for patients to undress or intensive periods of being touched may also make a patient feel vulnerable.
Chaperoning is the process of having a third person present during such consultations to provide support, both emotional and sometimes physical, to the patient, to provide practical support to the Doctor as required, and also to protect the Doctor against allegations of improper behaviour during such consultations.
Please refer to our Chaperone Policy shown below for further information:
This Policy is designed to protect both patients and staff from abuse or allegations of abuse, and to assist patients in making an informed choice about their examinations and consultations.
Clinicians (male and female) will consider whether an intimate or personal examination of the patient (either male or female) is justified, or whether the nature of the consultation poses a risk of misunderstanding.
- The Clinician will give the patient a clear explanation of what the examination will involve
- They will always adopt a professional and considerate manner and be careful with humour as a way of relaxing a nervous situation, as it can easily be misinterpreted
- The patient will always be provided with adequate privacy to undress and dress
- A suitable sign will be clearly on display in each Consulting or Treatment Room offering the Chaperone Service.
The above guidelines are to remove the potential for misunderstanding. However, there will still be times when either the Clinician, or the patient, feels uncomfortable, and it would then be appropriate to consider using a Chaperone.
Patients who request a Chaperone will never be examined without a Chaperone being present. If necessary, where a Chaperone is not available, the consultation/examination will be rearranged for a mutually convenient time when a Chaperone can be present.
Complaints and claims have not been limited to Doctors treating/examining patients of the opposite gender – there are many examples of alleged assault by female and male doctors on people of the same gender.
Consideration will always be given by staff to the possibility of a malicious accusation by a patient, and a Chaperone organised if there is any potential for this.
There may be occasions when a Chaperone is needed for a home visit in which case the following procedure will be followed.
Who can act as a Chaperone?
A variety of people can act as a Chaperone in the practice, but staff undertaking a formal Chaperone role will have been trained in the competencies required. Where possible, Chaperones will be clinical staff familiar with procedural aspects of personal examination.
Where the Practice determines that non-clinical staff will act in this capacity, the patient will be asked to agree to the presence of a non-Clinician in the examination, and for confirmation that they are at ease with this. The staff member will be trained in the procedural aspects of personal examinations, be comfortable acting in the role of Chaperone, and be confident in the scope and extent of their role. They will also have received instruction on where to sit/stand and what to watch and listen for. A Chaperone will document in the patient notes that they were present, and detail any issues arising.
- The Chaperone will only be present for the examination itself, with most of the discussion with the patient taking place while the Chaperone is not present.
- Patients are reassured that all Practice staff understand their responsibility not to divulge confidential information.
- The Clinician will contact reception to request a Chaperone
- Where no Chaperone is available, a Clinician may offer to delay the examination to a date when one will be available, as long as the delay would not have an adverse effect on the patient’s health
- If a Clinician wishes to conduct an examination with a Chaperone present but the patient does not agree to this, the Clinician will explain clearly why they want a Chaperone to be present. The Clinician may choose to consider referring the patient to a colleague who would be willing to examine them without a Chaperone, as long as the delay would not have an adverse effect on the patient’s health
- The Clinician will record in the notes that the Chaperone is present, and identify the Chaperone
- The Chaperone will enter the room discreetly and remain in the room until the Clinician has finished the examination
- A Chaperone will attend inside the curtain/screened-off area at the head of the examination couch and observe the procedure
- To prevent embarrassment, the Chaperone will not enter into conversation with the patient or GP unless requested to do so, or make any mention of the consultation afterwards
- The Chaperone will make a record in the patient’s notes after examination. The record will either state that there were no problems, or give details of any concerns or incidents that occurred. The Chaperone must be aware of the procedure to follow if any concerns require to be raised
- The patient can refuse a Chaperone, and if so this must be recorded in the patient’s medical record.
Clinical Commissioning Group
Clinical Commissioning Groups (CCGs) commission most of the Hospital and community NHS services in the local areas for which they are responsible.
Commissioning involves deciding what services are needed for diverse local populations, and ensuring that they are provided.
CCGs are assured by NHS England, which retains responsibility for commissioning primary care services such as GP and Dental services, as well as some specialised Hospital services. Many GP services are now co-commissioned with CCGs.
All GP practices now belong to a CCG, but CCGs also include other Health Professionals, such as nurses.
Services CCGs commission include:
- most planned Hospital care
- rehabilitative care
- urgent and emergency care (including out-of-hours)
- most community health services
- mental health and learning disability services
Clinical governance is the system through which NHS organisations are accountable for continuously improving the quality of their services and safeguarding high standards of care, by creating an environment in which clinical excellence will flourish.
Clinical governance encompasses quality assurance, quality improvement and risk & incident management.
Clinical Trials help Doctors understand how to treat a particular disease or condition. It may benefit you, or others like you, in the future.
If you take part in a Clinical Trial, you may be one of the first people to benefit from a new treatment.
However, if you do take part you should also be aware that there is a chance that the new treatment turns out to be no better, or worse, than the existing standard treatment.
How to make a compliment or complaint
Whether you are happy or unhappy with the care and treatment that you have received, please get in touch and let us know your views.
Receiving compliments and complaints is important to ensuring good quality local healthcare in our Practice – helping us to find out more about what we’re getting right and what we can improve.
We hope this will help you to make your feelings and experiences known to the appropriate people. Should you have a complaint we hope this page will give you more information about what to do, who to contact and what happens next.
How do I raise a concern / informal complaint?
You can speak to any member of staff initially with your complaint. This gives you the opportunity to resolve any concern you may have without it going through a formal process.
Most complaints are best resolved within the practice and these should be made via the Practice Operations Managers. We ask all patients to send their complaint in writing either:
Via Post addressed to The Practice Operations Managers, Clarendon Surgery, Pendleton Gateway, 1 The Broadwalk, Salford, M6 5FX
Or Via Email to firstname.lastname@example.org
If you would prefer to make a complaint verbally, our Care Navigators will take as much detail as possible and send a message to the Practice Operations Managers who will be in touch via telephone.
What we will do
We will contact you about your complaint within three working days and offer to discuss with you the best way to investigate it, including the time scales for a reply. We will aim to offer you an explanation within that time frame 0r a meeting with the people involved.
Our next steps:
- Find out what happened and what went wrong
- Invite you to discuss the problem with those involved, if you would like this
- Apologise where this is appropriate
- Identify what we can do to make sure that the problem does not happen again
If you feel you do not want to contact the surgery directly, then you can contact the ICS Complaints team on. Details of how to do this can be found at the following website, under the ‘Local area feedback and complaints’ section:
You can also contact the team via:
- Post – Salford Patient Services – NHS GM, Civic Centre, Chorley Road, Swinton, M27 5AW
- Email – email@example.com
- Call: 0161 779 8800
Please note that NHS GM Integrated Care cannot deal with any complaints which are already being or have already been dealt with by the provider directly.
If you are making a complaint please state: ‘For the attention of the complaints team’ in the subject line.
If you have a complaint to make, you can either contact the Practice Manager or ask the Receptionist for a copy of our Complaints Procedure.
We will endeavour to:
- acknowledge any letter or Complaints Form within 3 working days of receiving it.
- deal with the matter as promptly as possible – within 40 days – dependent on the nature of the complaint.
- If we feel the investigation will take longer than the 40 days, we will be in touch to keep you up to date with the progress of your complaint
Who can complain
- Complainants may be current or former patients, or their nominated or elected representatives (who have been given consent to act on the patients behalf).
- Patients over the age of 16 whose mental capacity is unimpaired should normally complain themselves or authorise someone to bring a complaint on their behalf.
- Children under the age of 16 can also make their own complaint, if they’re able to do so.
If a patient lacks capacity to make decisions, their representative must be able to demonstrate sufficient interest in the patient’s welfare and be an appropriate person to act on their behalf. This could be a partner, relative or someone appointed under the Mental Capacity Act 2005 with lasting power of attorney.
In certain circumstances, we need to check that a representative is the appropriate person to make a complaint:
- For example, if the complaint involves a child, we must satisfy ourselves that there are reasonable grounds for the representative to complain, rather than the child concerned.
- If the patient is a child or a patient who lacks capacity, we must also be satisfied that the representative is acting in the patient’s best interests.
If we are not satisfied that the representative is an appropriate person we will not consider the complaint, and will give the representative the reasons for our decision in writing.
A complaint must be made within 12 months, either from the date of the incident or from when the complainant first knew about it.
The regulations state that a responsible body should only consider a complaint after this time limit if:
- the complainant has good reason for doing so, and
- it’s still possible to investigate the complaint fairly and effectively, despite the delay.
We have a two stage complaints procedure. We will always try to deal with your complaint quickly however if it is clear that the matter will need a detailed investigation, we will notify you and then keep you updated on our progress.
- Stage one – Early, local resolution
We will try to resolve your complaint within five working days if possible.
If you are dissatisfied with our response, you can ask us to escalate your complaint to Stage Two.
- Stage Two – Investigation
We will look at your complaint at this stage if you are dissatisfied with our response at Stage One.
We also escalate some complaints straight to this stage, if it is clear that they are complex or need detailed investigation.
We will acknowledge your complaint within 3 working days and we will give you our decision as soon as possible. This will be no more that 20 working days unless there is clearly a good reason for needing more time to respond.
Complain to the Ombudsman
If, after receiving our final decision, you remain dissatisfied you may take your complaint to the Ombudsman.
The Ombudsman is independent of the NHS and free to use. It can help resolve your complaint, and tell the NHS how to put things right if it has got them wrong.
The Ombudsman only has legal powers to investigate certain complaints. You must have received a final response from the Practice before the Ombudsman can look at your complaint and it will generally not look into your complaint if it happened more than 12 months ago, unless there are exceptional circumstances.
Parliamentary & Health Service Ombudsman
London SW1P 4QP
All complaints will be treated in the strictest confidence
Where the investigation of the complaint requires consideration of the patient’s medical records, we will inform the patient or person acting on his/her behalf if the investigation will involve disclosure of information contained in those records to a person other than the Practice or an employee of the Practice.
We keep a record of all complaints and copies of all correspondence relating to complaints, but such records will be kept separate from patients’ medical records.
Statistics and reporting
The Practice must submit to the local primary care organisation periodically/at agreed intervals details of the number of complaints received and actioned.
Give feedback or make a complaint
You can complain to a member of staff at the NHS service you went to, such as a GP surgery or hospital, or you can complain to the organisation in charge.
Consent to treatment is the principle that a person must give permission before they receive any type of medical treatment, test or examination and is generally requested on the basis that an explanation of the required treatment, test or procedure has been received from a Clinician.
Consent from a patient is needed regardless of the procedure, whether it’s a physical examination, organ donation or something else.
The principle of consent is an important part of medical ethics and international human rights law.
For consent to be valid, it must be voluntary and informed, and the person consenting must have the capacity to make the decision.
These terms are explained below:
- voluntary– the decision to either consent or not to consent to treatment must be made by the person themselves, and must not be influenced by pressure from medical staff, friends or family
- informed– the person must be given all of the information in terms of what the treatment involves, including the benefits and risks, whether there are reasonable alternative treatments, and what will happen if treatment doesn’t go ahead
- capacity– the person must be capable of giving consent, which means they understand the information given to them and they can use it to make an informed decision
If an adult has the capacity to make a voluntary and informed decision to consent to or refuse a particular treatment, their decision must be respected.This is still the case even if refusing treatment would result in their death, or the death of their unborn child.
If a person doesn’t have the capacity to make a decision about their treatment, the Healthcare Professionals treating them can go ahead and give treatment if they believe it’s in the person’s best interests.
Clinicians must however take reasonable steps to seek advice from the patient’s friends or relatives before making these decisions.
Read more about assessing the capacity to consent.
How consent is given
Consent can be given:
- verbally– for example, by saying you are happy to have an X-ray
- in writing– for example, by signing a Consent Form for surgery to be performed
Someone could also give non-verbal consent, as long as they understand the treatment or examination about to take place – for example, holding out an arm for a blood test.
Consent should be given to the Healthcare Professional directly responsible for the person’s current treatment, such as:
- a Nurse arranging a blood test
- a GP prescribing new medication
- a Surgeon planning an operation
If someone is going to have a major medical procedure such as an operation, their consent should ideally be secured plenty of time in advance, so that they have time to obtain information about the procedure and ask questions.
If a paitent changes their mind at any point before the procedure, they are entitled to withdraw their previous consent.
Consent from children and young people
If they’re able to, consent is usually given by patients themselves. However, someone with parental responsibility may need to give consent for a child up to the age of 16 to have treatment.
Read more about the rules of consent applying to children and young people.
When consent isn’t needed
There are a few exceptions when treatment may be able to go ahead without the person’s consent, even if they’re capable of giving their permission.
It may not be necessary to obtain consent if a person:
- requires emergency treatment to save their life, but they’re incapacitated (for example, they’re unconscious) – the reasons why treatment was necessary should be fully explained once they’ve recovered
- immediately requires an additional emergency procedure during an operation – there has to be a clear medical reason why it would be unsafe to wait to obtain consent, and it can’t be simply for convenience
- with a severe mental health condition such as schizophrenia, bipolar disorder or dementia, lacks the capacity to consent to the treatment of their mental health (under the Mental Health Act 1983) – in these cases, treatment for unrelated physical conditions still requires consent, which the patient may be able to provide, despite their mental illness
- requires Hospital treatment for a severe mental health condition, but self-harmed or attempted suicide while competent and is refusing treatment (under the Mental Health Act 1983) – the person’s nearest relative or an approved Social Worker must make an application for the person to be forcibly kept in Hospital, and two Doctors must assess the person’s condition
- is a risk to public health as a result of rabies, cholera or tuberculosis (TB)
- is severely ill and living in unhygienic conditions (under the National Assistance Act 1948) – a person who is severely ill or infirm and is living in unsanitary conditions can be taken to a place of care without their consent
Consent and life-sustaining treatments
A person may be being kept alive with supportive treatments – such as lung ventilation – without having made an advance decision based on information which outlined the care that they may have refused to receive.
In these cases, a decision about continuing or stopping treatment needs to be made based on what that person’s best interests are believed to be.
To help reach a decision, the Healthcare Professionals responsible for the person’s care should discuss the issue with the relatives and friends of the person receiving the treatment.
They should consider, among other things:
- what the person’s quality of life will be if treatment is continued
- how long the person may live if treatment is continued
- whether there’s any chance of the person recovering
Treatment can be withdrawn if there’s an agreement that continuing treatment isn’t in the person’s best interests.
The case will be referred to the Courts before further action is taken if:
- an agreement can’t be reached
- a decision has to be made on whether to withdraw treatment from someone who has been in a state of impaired consciousness for a long time (usually at least 12 months)
It’s important to note the difference between withdrawing a person’s life support and taking a deliberate action to make them die. For example, injecting a lethal drug would illegal.
If you believe you’ve received treatment you didn’t consent to, you can make an official complaint, please write to the Practice Manager, who will assist you with this process.
If you have any special needs please let our staff know so that we can help you, and also ensure you get the same support in the future.
The Practice has been specially designed to make it easier for disabled patients to visit; patients also have access to a disabled toilet.
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. For more information and an Application Form visit your local council office.
We have a loop induction system at Reception to assist the hearing impaired. For more information on the loop hearing system visit Hearing Link website.
- British Deaf Association
- British Sign Language Healthy Mind
- Action Hearing Loss
- Royal Association for Deaf People
- National Deaf Children’s Society
If you or your family members are blind or partially sighted we can give you a CD or large print of our Practice leaflet upon request. Please ask our staff for further information.
For more advice and support for blind people please visit the following websites:
- Royal National Institute of Blind People (RIND)
- Action for Blind People
- Blind in Business
- British Blind Sport
Guide dogs are welcome at the Practice but we ask that you be aware of other patients and staff who may have an allergy or fear of dogs. Please visit the guide dog website for further information.
Duty of Candour
We share a common purpose with our partners in health and social care – and that is to provide high quality care and ensure the best possible outcomes for the people who use our services. Promoting improvement is at the heart of what we do.
We endeavour to provide a first class service at all times but sometimes things go wrong and our service may fall below our expected levels.
In order to comply with Regulation 20 of the Health and Social Care Act 2008 (Regulations 2014) we pledge to:
- Have a culture of openness and honesty at all levels
- Inform patients in a timely manner when safety incidents have occurred which may affect them
- Provide a written and truthful account of the incident, explaining any investigations and enquiries made
- Provide a written apology
- Provide support if you are affected directly by an incident.
Equality and Diversity
Our Policy is designed to ensure and promote equality and inclusion, supporting the ethos and requirements of the Equality Act 2010 for all visitors to our Practice.
We are committed to:
- ensuring that all visitors are treated with dignity and respect
- promoting equality of opportunity between men and women
- not tolerating any discrimination or perceived discrimination against, or harassment of, any visitor for reason of age, sex, gender, marital status, pregnancy, race, ethnicity, disability, sexual orientation, religion or belief
- providing the same treatment and services (including the ability to register with the Practice) to any visitor irrespective of age, sex, marital status, pregnancy, race, ethnicity, disability, sexual orientation, medical condition, religion or belief
- This Policy applies to the general public, including all patients and their families, visitors and contractors
Discrimination by the Practice or Visitors / patients against you
If you feel discriminated against:
- You should bring the matter to the attention of the Practice Manager
- The Practice Manager will investigate the matter thoroughly and confidentially within 14 working days
- The Practice Manager will establish the facts and decide whether or not discrimination has taken place, and advise you of the outcome of the investigation within 14 working days
- If you are not satisfied with the outcome, you should raise a formal complaint through our Complaints Procedure
Discrimination against our Practice staff
The Practice will not tolerate any form of discrimination or harassment of our staff by any visitor. Any visitor who expresses any form of discrimination against or harassment of any member of our staff will be required to leave the Practice premises immediately. If the visitor is a patient they may also, at the discretion of the Practice Management, be removed from the Practice list if any such behaviour occurs.
Equality & Diversity Policy
Freedom of Information
nyone has a right to request information from a public authority. We have two separate duties when responding to these requests:
- to tell the applicant (you or your representative) whether we hold any information falling within the scope of their request; and
- to provide that information
We normally have 20 working days to respond to a request.
For a request to be valid under the Freedom of Information Act it must be made in writing and should be submitted to the Practice Manager and must include the name and address of the applicant, for the reply; the applicant does not need to say why they want the information. Any letter or email to a public authority asking for information is a request for recorded information under the Act.
General Practice Extraction Service (GPES)
General Practice Extraction Service (GPES) is a centrally managed, primary care, data extraction service being introduced across England, and is managed by the Health and Social Care Information Centre (HSCIC).
The purpose of GPES is to extract and compare data from across the NHS, allowing data to be turned into accurate and usable management information; this in turn leads to improvements in patient care and greater efficiency across the service as a whole. The data extracted is also used to support QOF, although GPES does not calculate or make these payments, that task is carried out by the Calculating Quality Reporting Service (CQRS).
All GP Practices are required to declare the mean earnings (e.g. average) for GPs working to deliver NHS services to patients at each Practice.
“All GP practices are required to declare the mean earnings (e.g. average pay) for GPs working to deliver NHS services to patients at each practice.
The average pay for GPs working in Clarendon Surgery in the 2021/22 financial year was £75,918 before tax and National Insurance. This is for 9 part time GPs who worked in the practice for more than 6 months.”
NHS England require that the net earnings of Doctors engaged in the Practice is publicised, and the required disclosure is shown above. However it should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time Doctors spend working in the Practice, and should not be used to form any judgement about GP earnings, nor to make any comparison with any other Practice.
Infection Control Statement
Infection Prevention and Control is the work an organisation does to identify potential risks for spread of infection between patients (and between patients and staff) and to take measures to reduce that risk. The Practice takes its responsibility to do this very seriously.
All staff take responsibility for their own role in this and all staff receive regular training in their role in Infection Prevention and Control.
Named GP Policy
As part of the NHS commitment to providing more personalised care, from June 2015 all practices are required to provide all their Patients with a named GP who will have overall responsibility for the care and support that our surgery provides.
- This will not impact your experience at the practice, the provision of appointments, your treatment, or which GP you can see
- You may wonder why your allocated GP is not necessarily the one you see most regularly. Please be assured that you can still access all of our medical team in exactly the same way as before
- Having a named GP does not guarantee you will always be seen by that GP
- Please note that the GP responsible for your care may be subject to change and reallocation in the future
You do not need to take any further action, but if you have any questions or wish to know your named GP, please speak to a member of the reception team.
What does ‘accountable’ mean?
This is largely a role of oversight, with the requirements being introduced to reassure patients that they have one GP within the practice who is responsible for ensuring that this work is carried out on their behalf.
What are the named GP’s responsibilities to 75s and over?
This is unchanged from 2014-2015; for patients aged 75 and over the named accountable GP is responsible for:
- working with relevant associated health and social care professionals to deliver a multi-disciplinary care package that meets the needs of the patient
- ensuring that these patients have access to a health check as set out in section 7.9 of the GMS Contract Regulations.
Does the requirement mean 24-hour responsibility for patients? No. The named GP will not:
- take on vicarious responsibility for the work of other doctors or health professional
- take on 24-hour responsibility for the patient, or have to change their working hours. The requirement does not imply personal availability for GPs throughout the working week
- be the only GP or clinician who will provide care to that patient
Can patients choose their own named GP
In the first instance, patients should simply be allocated a named GP. However, if a patient requests a particular GP, reasonable efforts should be made to accommodate their preference, recognising that there are occasions when the practice may not feel the patient’s preference is suitable.
Do patients have to see the named GP when they book an appointment with the practice?
No. Patients can and should feel free to choose to see any GP or nurse in the practice in line with current arrangements. However, some practices may see this change as a way to encourage and promote a greater degree of continuity of care for patients.
Smoking is not permitted either within the Practice premises or in the Practice car park.
Patient Online Services
Electronic Patient Records
IT / Electronic Patient Records
STATEMENT OF INTENT FOR Clarendon Surgery & Trinity Medical Centre
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 :
- Patient Online Access to Their GP Record
- GP to GP Record Transfers
- Summary Care Record (SCR)
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.
Patient Online Access to OWN 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 are now able to offer currently offer the full facilities for booking and cancelling appointments, ordering your repeat prescriptions on-line and access to medical records. This is done by the EMIS Online facility. If you do not already have a user name and password for this system – please ask at reception for more details.
GP to GP Record Transfers
NHS England require 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 GP to GP record transfers your electronic record is transferred to your new practice much sooner.
GP to GP transfers are already active at Clarendon Surgery & Trinity Medical Centre and we send and receive patient records via this system.
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.
The core SCR record contains medications, allergies and adverse reactions and uploaded on the basis of implied patient consent. Additional information can only be uploaded with explicit patient consent and should be information required to support patient care in an emergency or urgent situation.
The SCR should only be viewed in emergency or urgent care settings with the explicit consent of the patient unless the patient is unable to give their consent (for example a patient is unconscious).
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 on our website www.clarendonsurgery.co.uk
Clarendon Surgery & Trinity Medical Centre can confirm 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.
Practice Confidentiality Statement
- This practice recognises the right of every patient to have information about them kept secure and private.
- Any information given to any member of staff will remain confidential.
- In exceptional circumstances, permission from the patient will be sought before any information is disclosed.
- The practice has a confidentiality policy which is adhered to by every member of staff. Patients have a right to the standards of confidentiality maintained by those providing their care and these standards should be made known at their first point of contact.
Every member of staff has a confidentiality clause in their contract, which they have signed. All members of staff are responsible for ensuring that confidential information is effectively protected when stored, transmitted, received or disposed of. Patients must be informed whenever information is likely to be disclosed to others involved in their care, and that apart from exceptional circumstances, where health and safety of others would otherwise be at serious risk, they have the opportunity to withhold permission.
Release of information to others
Systems are in place to ensure that requests for reports are not processed unless and until the patient’s consent has been confirmed. Patients can indicate if they wish to see the report before it is forwarded and do have the right of access to it afterwards. The security of all information is recognised, and when information is requested from patients by administrative staff the reason for the request is explained. We can only release results and other confidential information to the patient alone and not to family or relatives unless we have the patient’s explicit consent on record or in writing.
Medical information can be divulged to parents or guardians of children under 16 years, but this must not override the young person’s right to privacy. The patient’s best interests come first.
If you need to speak to someone in private then please tell the reception staff who will arrange this for you.
You do have to say what it is about, we respect your privacy and right to confidentiality.
This is the privacy notice of Clarendon Surgery & The Angel Medical Practice. In this document, “we”, “our”, or “us” refers to Clarendon Surgery & The Angel Medical Practice, Pendleton Gateway 1 The Broadwalk Salford M6 5FX .
Telephone number: 0161 983 0190
The General Data Protection Regulation (GDPR) came in to force on May 2018.
Patient Information Leaflet
You can download or view our Patient information leaflet about GDPR (General Data Protection Regulation).
Data Impact Assesments
As part of Information Governance and GDPR we are required to publish our Data Protection Impact Assessments. Any sharing of information is risk assessed for security.
We would only share information where it benefits patient care.
See below for active DPIA’s.
This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. This privacy notice applies to personal information processed by or on behalf of the practice.
This notice explains:
- Who we are, how we use your information and information about our Data Protection Officer?
- What kinds of personal information about you do we process?
- What are the legal grounds for our processing of your personal information (including when we share it with others)?
- What should you do if your personal information changes?
- For how long your personal information is retained by us?
- What are your rights under data protection laws?
The General Data Protection Regulation (GDPR) and the Data Protection Act 2018 became law on 25th May 2018. The GDPR is a single EU-wide regulation on the protection of confidential and sensitive information, the DPA 2018 deals with elements of UK law that differ from the European Regulation. These came into force in the UK on the 25th May 2018, repealing the previous Data Protection Act (2018).
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the Data Protection Act 2018 the practice responsible for your personal data is Clarendon Surgery.
This notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
How we use your information and the law
Clarendon Surgery will be what’s known as the controller of the personal data you provide to us. We collect basic personal data about you which does include special types of information and location-based information. This does include name, address, medical conditions, contact details such as email and mobile number etc.
We will collect sensitive confidential data known as special category personal data, in the form of health information, religious belief (if required in a healthcare setting) ethnicity, and gender during the services we provide to you and or linked to your healthcare through other health providers or third parties.
Why do we need your information?
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS trust, GP surgery, walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which the Practice hold about you may include the following information;
- Details about you, such as your address, carer, legal representative, emergency contact details
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
- Notes and reports about your health
- Details about your treatment and care
- Results of investigations such as laboratory tests, x-rays etc
- Relevant information from other health professionals, relatives or those who care for you
- Contact details (including email address, mobile telephone number and home telephone number)
To ensure you receive the best possible care, your records are used to facilitate the care you receive, including contacting you. Information held about you may be used to help protect the health of the public and to help us manage the NHS and the services we provide. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.
How do we lawfully use your data?
We need to know your personal, sensitive and confidential data in order to provide you with healthcare services as a general practice, under the general data protection regulation we will be lawfully using your information in accordance with:
- Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- Article 9, (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
- This privacy notice applies to the personal data of our patients and the data you have given us about your carers/family members.
We use your personal and healthcare information in the following ways:
- When we need to speak to, or contact other doctors, consultants, nurses or any other medical/healthcare professional or organisation during the course of your diagnosis or treatment or on-going healthcare.
- When we are required by law to hand over your information to any other organisation, such as the police, by court order, solicitors, or immigration enforcement.
We will never pass on your personal information to anyone else who does not need it, or has no right to it, unless you give us consent to do so.
Legal justification for collecting and using your information
The law says we need a legal basis to handle your personal and healthcare information.
Contract: We have a contract with NHS England to deliver healthcare services to you. This contract provides that we are under a legal obligation to ensure that we deliver medical and healthcare services to the public.
Consent: Sometimes we also rely on the fact that you give us consent to use your personal and healthcare information so that we can take care of your healthcare needs. Please note that you have the right to withdraw consent at any time if you no longer wish to receive services from us.
Necessary care: Providing you with the appropriate healthcare, where necessary. The Law refers to this as ‘protecting your vital interests’ where you may be in a position not to be able to consent.
Law: Sometimes the law obliges us to provide your information to another organisation (see above).
The law states that personal information about your health falls into a special category of information because it is very sensitive. Reasons that may entitle us to use and process your information may be as follows:
Public Interest: Where we may need to handle your personal information when it is considered to be in the public interest. For example, when there is an outbreak of a specific disease and we need to contact you for treatment, or we need to pass your information to relevant organisations to ensure you receive advice and/or treatment
Consent: When you have given us consent
Vital Interest: If you are incapable of giving consent, and we have to use your information to protect your vital interests (eg if you have had an accident and you need emergency treatment)
Defending a claim: If we need your information to defend a legal claim against us by you, or by another party
Providing you with medical care: Where we need your information to provide you with medical and healthcare services.
Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from several sources including NHS Trusts and from this GP Practice. The identifying parts of your data are removed, analysis of your data is undertaken, and a risk score is then determined. This is then provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way in most circumstances, please contact the practice for further information about opt out.
Individual Risk Management at a GP practice level however is deemed to be part of your individual healthcare and is covered by our legal powers above.
Sometimes we may provide information about you in an anonymised form. Such information is used to analyse population level heath issues and helps the NHS to plan better services. If we share information for these purposes, then none of the information will identify you as an individual and cannot be traced back to you.
The practice may conduct medicines management reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.
GP connect service
The GP Connect service allows authorised clinical staff at NHS 111 to seamlessly access our practice’s clinical system and book directly on behalf of a patient. This means that should you call NHS 111 and the clinician believes you need an appointment with your GP Practice, the clinician will access available appointment slots only (through GP Connect) and book you in. This will save you time as you will not need to contact the practice direct for an appointment.
The practice will not be sharing any of your data and the practice will only allow NHS 111 to see available appointment slots. They will not even have access to your record. However, NHS 111 will share any relevant data with us, but you will be made aware of this. This will help your GP in knowing what treatment / service / help you may require.
Please note if you no longer require the appointment or need to change the date and time for any reason you will need to speak to one of our reception staff and not NHS 111.
The practice will use your name, contact details and email address to inform you of NHS services, or provide information about your health, or information to manage your healthcare or information about the management of the NHS service. There may be occasions where authorised research facilities would like you to take part in research in regard to your particular health issues, to try improve your health, your contact details may be used to invite you to receive further information about such research opportunities.
The practice is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently and conscientiously applied with the wellbeing of all, at the heart of what we do.
Our legal basis for processing for the General Data Protection Regulation (GDPR) purposes is:
- Article 6(1)(e) ‘…exercise of official authority…’.
For the processing of special categories data, the basis is: –
- Article 9(2)(b) – ‘processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law…’
Clinical Practice Research Datalink (CPRD) collects anonymised patient data from a network of GP practices across the UK. Primary care data are linked to a range of other health related data to provide a longitudinal, representative UK population health dataset. You can opt out of your information being used for research purposes at any time (see below), full details can be found on the Clinical Practice Research Datalink website.
The legal basis for processing this information
CPRD do not hold or process personal data on patients; however, NHS Digital (formally the Health and Social Care Centre) may process ‘personal data’ for us as an accredited ‘safe haven’ or ‘trusted third-party’ within the NHS when linking GP data with data from other sources. The legal bases for processing this data are:
- Medicines and medical device monitoring: Article 6(e) and Article 9(2)(i) – public interest in the area of public health
- Medical research and statistics: Article 6(e) and Article 9(2)(j) – public interest and scientific research purposes
Any data CPRD hold or pass on to bona fide researchers, except for clinical research studies, will have been anonymised in accordance with the Information Commissioner’s Office Anonymisation Code of Practice. We will hold data indefinitely for the benefit of future research, but studies will normally only hold the data we release to them for twelve months.
Categories of personal data
The data collected by practice staff in the event of a safeguarding situation will be as much personal information as is necessary or possible to obtain in order to handle the situation. In addition to some basic demographic and contact details, we will also process details of what the safeguarding concern is. This is likely to be special category information (such as health information).
Sources of the data
The practice will either receive or collect information when someone contacts the organisation with safeguarding concerns, or we believe there may be safeguarding concerns and make enquiries to relevant providers.
Recipients of personal data
- The information is used by the practice when handling a safeguarding incident or concern. We may share information accordingly to ensure duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals (i.e. their GP or mental health team).
Third party processors
In order to deliver the best possible service, the practice will share data (where required) with other NHS bodies such as other GP practices and hospitals. In addition the practice will use carefully selected third party service providers.
When we use a third-party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties includes:
- Companies that provide IT / telephone services and support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
- Delivery services (for example if we were to arrange for delivery of any medicines to you).
- Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).
- Medical report processing and/or subject access report requests (our practice outsources medical reporting work to an NHS Digital accredited company called Medi2Data, who process medical reports and SARs on behalf of the practice via a secure, encrypted portal).
Further details regarding specific third-party processors can be supplied on request to the Data Protection Officer as below.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection Act 2018
- The General Data Protection Regulations 2016
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality, Information Security and Records Management
- Information: To Share or Not to Share Review
Every member of staff who works for an NHS organisation or NHS accredited organisation has a legal obligation to keep information about you confidential.
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without adequate permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.”
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.
Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the general data protection regulations (GDPR) and all UK specific data protection requirements. Our policy is to ensure all personal data related to our patients will be protected.
All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a sub-contractor acts as a data processor for Clarendon Surgery an appropriate contract (articles 24-28) will be established for the processing of your information.
In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the data protection officer in writing if you wish to withdraw your consent. In some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.
Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified.
Sometimes your information may be requested to be used for research purposes, the surgery will always gain your consent before releasing the information for this purpose in an identifiable format. In some circumstances you can opt-out of the surgery sharing any of your information for research purposes.
With your consent, we would also like to use your information
There are times that we may want to use your information to contact you or offer you services, not directly about your healthcare, in these instances we will always gain your consent to contact you. We would however like to use your name, contact details and email address to inform you of other services that may benefit you. We will only do this with your consent. There may be occasions where authorised research facilities would like you to take part on innovations, research, improving services or identifying trends, you will be asked to opt into such programmes if you are happy to do so.
At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.
This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO as below.
National opt-out facility
You can choose whether your confidential patient information is used for research and planning.
Who can use your confidential patient information for research and planning?
It is used by the NHS, local authorities, university and hospital researchers, medical colleges and pharmaceutical companies researching new treatments.
Making your data opt-out choice
You can choose to opt out of sharing your confidential patient information for research and planning. There may still be times when your confidential patient information is used: for example, during an epidemic where there might be a risk to you or to other people’s health.
You can also still consent to take part in a specific research project.
Will choosing this opt-out affect my care and treatment?
No, your confidential patient information will still be used for your individual care. Choosing to opt out will not affect your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.
What should I do next?
You do not need to do anything if you are happy about how your confidential patient information is used.
If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service. You can change your choice at any time.
To find out more or to make your choice visit the “Your Data Matters” page on the NHS website or call 0300 303 5678.
NHS digital data collection from the practice
The NHS needs data about the patients it treats to plan and deliver its services and to ensure that care and treatment provided is safe and effective. The General Practice Data for Planning and Research data collection will help the NHS to improve health and care services for everyone by collecting patient data that can be used to do this. For example, patient data can help the NHS to:
- Monitor the long-term safety and effectiveness of care
- Plan how to deliver better health and care services
- Prevent the spread of infectious diseases
- Identify new treatments and medicines through health research
GP practices already share patient data for these purposes, but this new data collection will be more efficient and effective.
This means that GPs can get on with looking after their patients, and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it, to improve health and care for everyone.
Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality.
NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and GP practices.
NHS digital purposes for processing patient data
Patient data from GP medical records kept by GP practices in England is used every day to improve health, care and services through planning and research, helping to find better treatments and improve patient care. The NHS is introducing an improved way to share this information – called the General Practice Data for Planning and Research data collection.
NHS Digital will collect, analyse, publish and share this patient data to improve health and care services for everyone. This includes:
- Informing and developing health and social care policy
- Planning and commissioning health and care services
- Taking steps to protect public health (including managing and monitoring the coronavirus pandemic)
- In exceptional circumstances, providing you with individual care
- Enabling healthcare and scientific research
Any data that NHS Digital collects will only be used for health and care purposes. It is never shared with marketing or insurance companies.
What patient data do NHS digital collect?
This collection started from 1 July 2021. Patient data will be collected from GP medical records about:
- Any living patient registered at a GP practice in England when the collection started – this includes children and adults
- Any patient who died after the data collection started, and was previously registered at a GP practice in England when the data collection started
We will not collect your name or where you live. Any other data that could directly identify you, for example NHS number, General Practice Local Patient Number, full postcode and date of birth, is replaced with unique codes which are produced by de-identification software before the data is shared with NHS Digital.
This process is called pseudonymisation and means that no one will be able to directly identify you in the data.
NHS Digital will be able to use the same software to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason. Only NHS Digital has the ability to do this. This would mean that the data became personally identifiable data in the diagram above. An example would be where you consent to your identifiable data being shared with a research project or clinical trial in which you are participating, as they need to know the data is about you.
More information about when we may be able to re-identify the data is in the “who we share your patient data with” section below.
The data NHS digital collect
We will only collect structured and coded data from patient medical records that is needed for specific health and social care purposes explained above.
Data that directly identifies you as an individual patient, including your NHS number, General Practice Local Patient Number, full postcode, date of birth and if relevant date of death, is replaced with unique codes produced by de-identification software before it is sent to NHS Digital. This means that no one will be able to directly identify you in the data.
NHS Digital will be able to use the software to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason. This would mean that the data became personally identifiable. It will still be held securely and protected, including when it is shared by NHS Digital.
NHS digital does not collect:
- Your name and address (except for your postcode in unique coded form)
- Written notes (free text), such as the details of conversations with doctors and nurses
- Images, letters and documents
- Coded data that is not needed due to its age – for example medication, referral and appointment data that is over 10 years old
- Coded data that GPs are not permitted to share by law – for example certain codes about IVF treatment, and certain information about gender re-assignment
NHS digital does collect:
- Data on your sex, ethnicity and sexual orientation
- Clinical codes and data about diagnoses, symptoms, observations, test results, medications, allergies, immunisations, referrals and recalls, and appointments, including information about your physical, mental and sexual health
- Data about staff who have treated you
Opting out of NHS digital collecting your data
If you do not want your identifiable patient data to be shared outside of your GP practice for purposes except for your own care, you can register an opt-out with your GP practice. This is known as a Type 1 Opt-Out.
Type 1 Opt-Outs were introduced in 2013 for data sharing from GP practices, but may be discontinued in the future as a new opt-out has since been introduced to cover the broader health and care system, called the National Data Opt-Out. If this happens people who have registered a Type 1 Opt-Out will be informed. More about National Data Opt-Outs is in the section “who we share patient data with”.
NHS Digital will not collect any patient data for patients who have already registered a Type 1 Opt-Out in line with current policy. If this changes patients who have registered a Type 1 Opt-Out will be informed.
If you do not want your patient data shared with NHS Digital, you can register a Type 1 Opt-Out with your GP practice. You can register a Type 1 Opt-Out at any time. You can also change your mind at any time and withdraw a Type 1 Opt-Out.
Data sharing with NHS Digital commenced on 1 July 2021. If you have already registered a Type 1 Opt-Out with your GP practice your data will not be shared with NHS Digital.
If you register a Type 1 Opt-out after your patient data has already been shared with NHS Digital, no more of your data will be shared with NHS Digital. NHS Digital will however still hold the patient data which was shared with us before you registered the Type 1 Opt-Out.
If you do not want NHS Digital to share your identifiable patient data (personally identifiable data) with anyone else for purposes beyond your own care, then you can also register a national data opt-out. There is more about national data opt-outs and when they apply in the “national data opt-out” section below.
NHS digital legal basis for collecting, analysing and sharing patient data
When we collect, analyse, publish and share patient data, there are strict laws in place that we must follow. Under the UK General Data Protection Regulation (GDPR), this includes explaining to you what legal provisions apply under GDPR that allows us to process patient data. The GDPR protects everyone’s data.
NHS Digital has been directed by the Secretary of State for Health and Social Care under the General Practice Data for Planning and Research Directions 2021 to collect and analyse data from GP practices for health and social care purposes including policy, planning, commissioning, public health and research purposes.
NHS Digital is the controller of the patient data collected and analysed under the GDPR jointly with the Secretary of State for Health and Social Care.
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.
NHS Digital has various powers to publish anonymous statistical data and to share patient data under sections 260 and 261 of the 2012 Act. It also has powers to share data under other Acts, for example the Statistics and Registration Service Act 2007.
Regulation 3 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) also allow confidential patient information to be used and shared appropriately and lawfully in a public health emergency. The Secretary of State has issued legal notices under COPI (COPI Notices) requiring NHS Digital, NHS England and Improvement, arm’s-length bodies (such as Public Health England), local authorities, NHS trusts, clinical commissioning groups and GP practices to share confidential patient information to respond to the COVID-19 outbreak. Any information used or shared during the COVID-19 outbreak will be limited to the period of the outbreak unless there is another legal basis to use confidential patient information.
The legal basis under GDPR for General Practice Data for Planning and Research
How NHS digital use patient data
NHS Digital will analyse and link the patient data we collect with other patient data we hold to create national data sets and for data quality purposes.
NHS Digital will be able to use the de-identification software to convert the unique codes back to data that could directly identify you in certain circumstances for these purposes, where this is necessary and where there is a valid legal reason. There are strict internal approvals which need to be in place before we can do this and this will be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD).
These national data sets are analysed and used by NHS Digital to produce national statistics and management information, including public dashboards about health and social care which are published. We never publish any patient data that could identify you. All data we publish is anonymous statistical data.
We may also carry out analysis on national data sets for data quality purposes and to support the work of others for the purposes set out in our “purposes for processing patient data” section above.
Who NHS digital share patient data with
All data which is shared by NHS Digital is subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the relevant health and social care purpose will be shared.
All requests to access patient data from this collection, other than anonymous aggregate statistical data, will be assessed by NHS Digital’s Data Access Request Service, to make sure that organisations have a legal basis to use the data and that it will be used safely, securely and appropriately.
These requests for access to patient data will also be subject to independent scrutiny and oversight by the Independent Group Advising on the Release of Data (IGARD).
Organisations approved to use this data will be required to enter into a data sharing agreement with NHS Digital regulating the use of the data.
There are a number of organisations who are likely to need access to different elements of patient data from the General Practice Data for Planning and Research collection. These include but may not be limited to:
- The Department of Health and Social Care and its executive agencies, including Public Health England and other government departments
- NHS England and NHS Improvement
- Primary care networks (PCNs), clinical commissioning groups (CCGs) and integrated care organisations (ICOs)
- Local authorities
- Research organisations, including universities, charities, clinical research organisations that run clinical trials and pharmaceutical companies
If the request is approved, the data will either be made available within a secure data access environment within NHS Digital infrastructure, or where the needs of the recipient cannot be met this way, as a direct dissemination of data. We plan to reduce the amount of data being processed outside central, secure data environments and increase the data we make available to be accessed via our secure data access environment. For more information read about improved data access in improving our data processing services.
Data will always be shared in the uniquely coded form unless in the circumstances of any specific request it is necessary for it to be provided in an identifiable form (personally identifiable data in the diagram above). For example, when express patient consent has been given to a researcher to link patient data from the General Practice for Planning and Research collection to data the researcher has already obtained from the patient.
It is therefore possible for NHS Digital to convert the unique codes back to data that could directly identify you in certain circumstances, and where there is a valid legal reason which permits this without breaching the common law duty of confidentiality. This would include:
- Where the data was needed by a health professional for your own care and treatment
- Where you have expressly consented to this, for example to participate in a clinical trial
- Where there is a legal obligation, for example where the COPI Notices apply – see our “legal basis for collecting, analysing and sharing patient data” section above for more information on this
- Where approval has been provided by the Health Research Authority or the Secretary of State with support from the Confidentiality Advisory Group (CAG) under Regulation 5 of the Health Service (Control of Patient Information) Regulations 2002 (COPI) – this is sometimes known as a ‘section 251 approval’
This would mean that the data was personally identifiable. Re-identification of the data would only take place following approval of the specific request through the Data Access Request Service, and subject to independent assurance by IGARD and consultation with the Professional Advisory Group, which is made up of representatives from the BMA and the RCGP. If you have registered a National Data Opt-Out, this would be applied in accordance with the National Data Opt-Out policy before any identifiable patient data (personally identifiable data) about you was shared. More about the National Data Opt-Out is in the section below.
Where NHS digital stores patient data
NHS Digital only stores and processes patient data for this data collection within the United Kingdom (UK).
Fully anonymous data (that does not allow you to be directly or indirectly identified), for example statistical data that is published, may be stored and processed outside of the UK.
Some of our processors may process patient data outside of the UK. If they do, we will always ensure that the transfer outside of the UK complies with data protection laws.
Where we (Clarendon Surgery) store your information electronically
All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.
No third parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place (such as a data processor as above). We have a data protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.
The practice uses a clinical system provided by a data processor called EMIS. EMIS will start storing your practice’s EMIS Web data in a highly secure, third-party cloud hosted environment, namely Amazon Web Services (“AWS”).
The data will remain in the UK at all times and will be fully encrypted both in transit and at rest. In doing this, there will be no change to the control of access to your data and the hosted service provider will not have any access to the decryption keys.
AWS is one of the world’s largest cloud companies, already supporting numerous public sector clients (including the NHS), and it offers the very highest levels of security and support.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:
- NHS Trusts / Foundation Trusts
- NHS commissioning support units
- Independent contractors such as dentists, opticians, pharmacists
- Private sector providers
- Voluntary sector providers
- Ambulance trusts
- Clinical commissioning groups
- Social care services
- NHS England (NHSE) and NHS Digital (NHSD)
- Multi Agency Safeguarding Hub (MASH)
- Local authorities
- Education services
- Fire and rescue services
- Police and judicial services
- Voluntary sector providers
- Private sector providers
- Other data processors which you will be informed of
You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.
This practice operates a Clinical Computer System on which NHS staff record information securely. This information can then be shared with other clinicians so that everyone caring for you is fully informed about your medical history, including allergies and medication.
To provide around the clock safe care, unless you have asked us not to, we will make information available to trusted organisations. Wherever possible, their staff will ask your consent before your information is viewed.
We consider patient consent as being the key factor in dealing with your health information.
Shared care records
To support your care and improve the sharing of relevant information to our partner organisations when they are involved in looking after you, we will share information to other systems. The general principle is that information is passed to these systems unless you request this does not happen, but that system users should ask for your consent before viewing your record.
We may also use external companies to process personal information, such as for archiving purposes or medical report processing. These companies are bound by contractual agreements to ensure information is kept confidential and secure. All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for Clarendon Surgery, an appropriate contract (art 24-28) will be established for the processing of your information.
Sharing your information without consent
We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:
- Where there is a serious risk of harm or abuse to you or other people
- Where a serious crime, such as assault, is being investigated or where it could be prevented
- Notification of new births
- Where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS)
- Where a formal court order has been issued
- Where there is a legal requirement, for example if you had committed a Road Traffic Offence
How long will your information be stored?
We are required under UK law to keep your information and data for the full retention periods as specified by the NHS records management code of practice for health and social care and national archives requirements.
More information on records retention can be found on the NHS Digital website.
How can I access, amend or remove the personal data you have given us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws.
We may keep a record of your communications to help us resolve any issues which you raise.
Right to object
If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent
|Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.|
Right to erasure
In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to erase your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of data portability
If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.
Primary care network (PCN)
Clarendon Surgery are part of the Salford South East (formally Ordsall and Claremont) Primary Care Network (PCN).
The objective of primary care networks (PCNs) is to group practices together to create more collaborative workforces which ease the pressure of GPs, leaving them better able to focus on patient care.
Primary Care Networks form a key building block of the NHS long-term plan. Bringing general practices together to work at scale has been a policy priority for some years for a range of reasons, including improving the ability of practices to recruit and retain staff; to manage financial and estates pressures; to provide a wider range of services to patients and to more easily integrate with the wider health and care system.
This means the practice may share your information with other practices within the PCN to provide you with your care and treatment.
Access to your personal information
Subject Access Requests (SARs)
You have a right under the data protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:
- Your request should be made to the practice, for information from the hospital you should write direct to them.
- There is no charge to have a copy of the information held about you.
- We are required to respond to you within one month.
- You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.
- We outsource our medical reporting work to an NHS Digital accredited company called Medi2Data, who will process your request via a secure and encrypted portal. Clarendon Surgery and Medi2Data have an appropriate agreement in place to ensure that Medi2Data keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately.
What should I do if my personal information changes?
You should tell us so that we can update our records. This is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up to date.
You may ask us if you wish to have online access to your medical record. However, there will be certain protocols that we have to follow in order to give you online access, including written consent and production of documents that prove your identity.
Please note that when we give you online access, the responsibility is yours to make sure that you keep your information safe and secure if you do not wish any third party to gain access.
Third parties mentioned within your medical record
Sometimes we record information about third parties mentioned by you to us during any consultation or contained in letters we receive from other organisations. We are under an obligation to make sure we also protect that third party’s rights as an individual and to ensure that references to them which may breach their rights to confidentiality, are removed before we send any information to any other party including yourself.
The only website this Privacy Notice applies to is the surgery website. If you use a link to any other website from the surgery’s website then you will need to read their respective Privacy Notice. We take no responsibility (legal or otherwise) for the content of other websites.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires on our site while you complete them
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
CCTV is installed on our practice premises covering both the external area of the building and the internal area (corridors, waiting area). Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime. The images are recorded onto an integral hard drive of the equipment and are overwritten on a rolling basis. Viewing of these digital images is password protected and controlled by the Practice Manager.
Our telephone system records all telephone calls. Recordings are used periodically for the purposes of seeking clarification where there is a dispute as to what was said and for staff training.
Access to these recordings is restricted to named senior staff.
Objections or complaints
Should you have any concerns about how your information is managed at the GP, please contact the GP practice manager or the data protection officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority:
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 the practice data protection officer.
If you would like to know more about your rights in respect of the personal data we hold about you, please contact the data protection officer.
Data protection officer (DPO)
The practice data protection officer is Ruth Quinn of Salford Clinical Commissioning Group. Any queries regarding data protection issues should be addressed to Ruth at:
The Caldicott Guardian/IG Lead is responsible for;
- Ensuring implementation of the Caldicott Principles and Data Security Standards with respect to Patient Confidential Data
- Ensuring that the Practice processes satisfy the highest practical standards for handling patient information and provide advice and support to Practice staff as required
- Ensuring that patient identifiable information is shared appropriately and in a secure manner. The Caldicott Guardian will liaise where there are reported incidents of person identifiable data loss or identified threats and vulnerabilities in Practice information systems to mitigate the risk.
The aim of the Caldicott Guardian is to ensure the organisation implements the Caldicott principles and data security standards; there is no need to appoint a Caldicott Guardian, but there is a need to have an Information Governance lead (sometimes referred to as a Caldicott lead) who, if they are not a clinician, will need support from a clinically qualified individual.
It is important to point out that we may amend this privacy notice from time to time. If you are dissatisfied with any aspect of our privacy notice, please contact the data protection officer.
We may update this Privacy Notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
Our Practice aims to provide quality, consistent primary care for all patients. We strive to meet the high standards expected in any clinical setting and we expect all members of our Team to work to these standards to help us achieve our aim.
The policies, systems and processes in place in our Practice reflect our professional and legal responsibilities and follow recognised standards of good practice. We evaluate our Practice on a regular basis, through audit, peer review and patient feedback and monitor the effectiveness of our quality assurance procedures.
Quality standards and procedures
To assist our Team in providing our patients with care of a consistent quality we will:
- Provide a safe and welcoming environment
- Ensure all members of our Team are appropriately trained
- Provide patients with information about the Practice and the care available, and ensure the patient understands the terms under which care is offered
- Explain all treatment options and agree clinical decisions with the patient(s), explaining the possible risks involved with each option
- Obtain valid consent for all treatment
- Refer to Specialists for investigation or treatment as appropriate and without undue delay
- Maintain contemporaneous clinical records with an up-to-date medical history for all patients
- Provide secure storage of patients records to main confidentiality
- Explain the procedure to follow for raising a complaint about the service, identifying the Practice contact
To provide our patients with a Team that provides care of a consistent quality we will:
- Provide a safe working environment through hazard identification and risk assessment
- Provide relevant training for all new Team members
- Provide Job Descriptions and Contracts of Employment
- Agree terms for all non-employed contractors working at the Practice
- Maintain staff records, ensuring they are kept as up-to-date as possible
- Ensure staff are notified where all Practice policies and procedures are stored and accessed
Removal of Patients from our List
It is our policy not to remove patients without serious consideration. If a patient has a serious continuing medical condition, removal will be postponed until the patient’s condition stabilises.
Possible grounds for consideration of removal include:
- Physical violence to staff, Doctors or other patients
- Threat of violence to staff, Doctors or other patients
- Abusive or disruptive behaviour including when under the influence of alcohol or drugs
- Theft from the Surgery, staff, Doctors or other patients
- Criminal damage to the Surgery
- Dangerous dogs posing a real or potential hazard on home visits
- Altering documents e.g. prescriptions, insurance certificates
- Defamation of Doctors or staff
- Misuse of appointments
- Misuse of home visits
- Moving outwith the area
- Any other breakdown of the bond of trust between Doctor and patient
It should be noted that if a patient does not attend for their appointment they will not be given another one for 48 hours. In the event of a patient not attending on three occasions they will receive a letter advising them that if they miss another appointment, they will be removed from our Practice list.
In some cases we reserve the right to remove other members of the household. We will continue to be responsible for the patient’s medical care for a period of up to 8 days from the date of notification to our local health authority or until the patient registers with another Doctor, whichever is the sooner.
Our Primary Care Team is committed to safeguarding children. The safety and welfare of children who come into contact with our services either directly or indirectly is paramount, and all staff have a responsibility to ensure that Best Practice is followed, including compliance with statutory requirements.
We are committed to a Best Practice which safeguards children and young people irrespective of their background, and which recognises that a child may be abused regardless of their age, gender, religious beliefs, racial origin or ethnic identity, culture, class, disability or sexual orientation.
The Primary Care Team are committed to working within agreed policies and procedures and in partnership with other agencies, to ensure that the risks of harm to a child or young person are minimised. This work may include direct and indirect contact with children, access to patient’s details and communication via email or text message/telephone.
Our Surgery is supported by the CCG who have designated Nurses and Doctors in post who offer professional expertise and advice regarding safeguarding children.
Shared Decision Making
Making decisions about your care with your doctor or nurse (shared decision making)
When you visit your doctor’s surgery you will often find that there are decisions to be made about your health and the treatments that might be available to you. This includes when you are choosing between different types of treatment or different ways of managing any condition(s) you have. When these decisions are made it is important that you are part of that process, so that you are able to come to the best decisions based on what is important to you.
Shared Decision Making
Your doctor/nurse is an expert about health and health care. You are an expert in knowing about yourself, the impact that any conditions have on you, and what is important to you in treating your condition and in your wider life. When you and your doctor/nurse work together to share what you both know, and then use all of that information to come to a decision together, this is called ‘Shared Decision Making’.
How to get involved
In order for you to be involved in decisions about your care there are three key things you need to know;
- What are my options?
- What are the possible risks, benefits and consequences of each option?
- How can we make a decision together that is right for me?
With shared decision making your doctor/nurse is there to support you by providing good quality information, helping you understand this information, and giving you support and guidance as you think about what is most important to you. This will help you to understand what choices are available to you, the pros and cons of each option, and then use that information to come to a decision together about the best option for you.
If you would like to know more about Shared Decision Making the following video provides further information.
Where to find more information
Here are some links to information which may help you make any decisions about your healthcare
Patient Decision Aids
Patient Decision Aids (PDAs) are designed to help you decide which treatments and care options are best for you.
PDAs are useful because they allow you to pick out the things that are most important to you (your values) and make comparisons about how different treatments might affect these values. Patient decision aids have been developed for a number of common health care decisions and your doctor/nurse may use one or refer you on to one when you talk with them, or you might find it useful to look at one by yourself. If you would like to know more about patient decision aids and look at some of the patient decision aids that are publicly available, the following websites :
An international inventory of decision aids
If you are looking for information about the risk of cardio vascular disease or Type 2 diabetes and ways in which those risks can be reduced these sites contains some useful information:
Patients are reminded that if they are found posting any derogatory, defamotory, or offensive comments on social media directed to the Practice or members of staff on social networking sites, this may result in them being removed from the Practice List. We ask if you have a complaint to please contact the Practice Manager in the first instance. We would be grateful if patients could be pro-active in reporting any incidents of this nature to the Practice Manager.
Unacceptable Actions Policy
We believe that patients have a right to be heard, understood and respected. We work hard to be open and accessible to everyone. Occasionally, the behaviour or actions of individuals using our Practice makes it very difficult for us to deal with their issue or complaint. In a small number of cases the actions of individuals become unacceptable because they involve abuse of our staff or our process. When this happens we have to take action to protect our staff, and must also consider the impact of the individuals behaviour on our ability to do our work and provide a service to others. This Policy explains how we will approach these situations.
Section 1 – What actions does the Practice consider to be unacceptable?
People may act out of character in times of trouble or distress. There may have been upsetting or distressing circumstances leading up to us being made aware of an issue or complaint. We do not view behaviour as unacceptable just because a patient is forceful or determined. In fact, we accept that being persistent may sometimes be a positive advantage when pursuing an issue or complaint. However, we do consider actions that result in unreasonable demands on our Practice or unreasonable behaviour towards Practice staff to be unacceptable. It is these actions that we aim to manage under this Policy.
Section 2 – Aggressive or abusive behaviour
We understand that patients may be angry about the issues they have raised with the Practice. If that anger escalates into aggression towards Practice staff, we consider that unacceptable. Any violence or abuse towards staff will not be accepted. Violence is not restricted to acts of aggression that may result in physical harm. It also includes behaviour or language (whether verbal or written) that may cause staff to feel offended, afraid, threatened or abused. We will judge each situation individually, and appreciate individuals who come to us may be upset.
Language which is designed to insult or degrade, is derogatory, racist, sexist, transphobic, or homophobic or which makes serious allegations that individuals have committed criminal, corrupt, perverse or unprofessional conduct of any kind, without any evidence, is unacceptable.
We may decide that comments aimed not at us, but at third parties, are unacceptable because of the effect that listening or reading them may have on our staff.
Section 3 – Unreasonable demands
A demand becomes unacceptable when it starts to (or when complying with the demand would) impact substantially on the work of the Practice. Examples of actions grouped under this heading include:
- Repeatedly demanding responses within an unreasonable timescale
- Repeatedly requesting early supplies of medication
- Repeatedly requesting further supplies of stolen medication, without the required Police Incident number
- Repeatedly ordering prescriptions outwith the set timeframe
- Insisting on seeing or speaking to a particular member of staff when that is not possible
- Repeatedly changing the substance of an issue or complaint or raising unrelated concerns
- Repeatedly insisting on a course of medical treatment for which there is no clinical evidence
- Not ensuring that a review appointment is in place, prior to ongoing medication finishing
- An example of such impact would be that the demand takes up an excessive amount of staff time and in so doing disadvantages other patients
Section 4 – Unreasonable levels of contact
Sometimes the volume and duration of contact made to our Practice by an individual causes problems. This can occur over a short period, for example, a number of calls in one day or one hour. It may occur over the life-span of an issue when a patient repeatedly makes long telephone calls to us, or inundates us with letters or copies of information that have been sent already or that are irrelevant to the issue. We consider that the level of contact has become unacceptable when the amount of time spent talking to a patient on the telephone, or responding to, reviewing and filing emails or written correspondence impacts on our ability to deal with that issue, or with other Patients’ needs.
Section 5 – Unreasonable refusal to co-operate
When we are looking at an issue or complaint, we will ask the patient to work with us. This can include agreeing with us the issues or complaint we will look at; providing us with further information, evidence or comments on request; or helping us by summarising their concerns or completing a form for us.
Sometimes, a patient repeatedly refuses to cooperate and this makes it difficult for us to proceed. We will always seek to assist someone if they have a specific, genuine difficulty complying with a request. However, we consider it is unreasonable to bring an issue to us and then not respond to reasonable requests.
Section 6 – Unreasonable use of the complaints process
Individuals with complaints about the Practice have the right to pursue their concerns through a range of means. They also have the right to complain more than once about the Practice, if subsequent incidents occur. This contact becomes unreasonable when the effect of the repeated complaints is to harass, or to prevent us from pursuing a legitimate aim or implementing a legitimate decision. We consider access to a complaints system to be important and it will only be in exceptional circumstances that we would consider such repeated use is unacceptable – but we reserve the right to do so in such cases.
Section 7 – Examples of how we manage aggressive or abusive behaviour
- The threat or use of physical violence, verbal abuse or harassment towards the Practice staff is likely to result in a warning from the Senior Management Team. We may report incidents to the Police – this will always be the case if physical violence is used or threatened.
- Practice staff will end telephone calls if they consider the caller aggressive, abusive or offensive. Practice staff have the right to make this decision, to tell the caller that their behaviour is unacceptable and end the call if the behaviour persists.
- We will not respond to correspondence (in any format) that contains statements that are abusive to staff or contain allegations that lack substantive evidence. Where we can, we will return the correspondence. We will explain why and say that we consider the language used to be offensive, unnecessary and unhelpful and ask the sender to stop using such language. We will state that we will not respond to their correspondence if the action or behaviour continues and may consider issuing a warning to the Patient.
Section 8 – Examples of how we deal with other categories of unreasonable behaviour
We have to take action when unreasonable behaviour impairs the functioning of our Practice. We aim to do this in a way that allows a Patient to progress through our process. We will try to ensure that any action we take is the minimum required to solve the problem, taking into account relevant personal circumstances including the seriousness of the issue(s) or complaint and the needs of the individual.
Section 9 – Other actions we may take
Where a patient repeatedly phones, visits the Practice, raises repeated issues, or sends large numbers of documents where their relevance isn’t clear, we may decide to:
- limit contact to telephone calls from the patient at set times on set days, about the issues raised
- restrict contact to a nominated member of the Practice staff who will deal with future calls or correspondence from the patient about their issues
- see the patient by appointment only
- restrict contact from the patient to writing only regarding the issues raised
- return any documents to the patient or, in extreme cases, advise the patient that further irrelevant documents will be destroyed
- take any other action that we consider appropriate
Where we consider continued correspondence on a wide range of issues to be excessive, we may tell the patient that only a certain number of issues will be considered in a given period and ask them to limit or focus their requests accordingly. In exceptional cases, we reserve the right to refuse to consider an issue, or future issues or complaints from an individual. We will take into account the impact on the individual and also whether there would be a broader public interest in considering the issue or complaint further. We will always tell the patient what action we are taking and why.
Section 10 – The process we follow to make decisions about unreasonable behaviour
- Any member of the Practice staff who directly experiences aggressive or abusive behaviour from a Patient has the authority to deal immediately with that behaviour in a manner they consider appropriate to the situation and in line with this Policy
- With the exception of such immediate decisions taken at the time of an incident, decisions to issue a warning or remove patients from our Practice List are only taken after careful consideration of the situation by the Senior Management
- Wherever possible, we will give a patient the opportunity to change their behaviour or actions before a decision is taken
Section 11 – How we let people know we have made this decision
When a Practice employee makes an immediate decision in response to offensive, aggressive or abusive behaviour, the patient is advised at the time of the incident. When a decision has been made by Senior Management, a patient will always be given the reason in writing as to why a decision has been made to issue a warning (including the
duration and terms of the warning) or remove them from the Practice list. This ensures that the patient has a record of the decision.
Section 12 – How we record and review a decision to issue a warning
We record all incidents of unacceptable actions by patients. Where it is decided to issue a warning to a patient, an entry noting this is made in the relevant file and on appropriate computer records. Each quarter a report on all restrictions will be presented to our Senior Management Team so that they can ensure the policy is being applied appropriately. A decision to issue a warning to a patient as described above may be reconsidered either on request or on review.
Section 13 – The process for appealing a decision
It is important that a decision can be reconsidered. A patient can appeal a decision about the issuance of a warning or removal from the Practice list. If they do this, we will only consider arguments that relate to the warning or removal, and not to either the issue or complaint made to us, or to our decision to close a complaint.
An appeal could include, for example, a patient saying that: their actions were wrongly identified as unacceptable; the warning was disproportionate; or that it will adversely impact on the individual because of personal circumstances.
The Practice Manager or a GP Partner who was not involved in the original decision will consider the appeal. They have discretion to quash or vary the warning as they think best. They will make their decision based on the evidence available to them. They must advise the patient in writing that either the warning or removal still applies or a different course of action has been agreed. We may review the warning periodically or on further request after a period of time has passed. Each case is different.
This policy is subject to review
Your NHS Data Matters
Your Data Matters to the NHS
Information about your health and care helps us to improve your individual care, speed up diagnosis, plan your local services and research new treatments. The NHS is committed to keeping patient information safe, and will always be clear about how it is used.
How your data is used
Information about your individual care such as treatment and diagnoses is collected about you whenever you use health and care services. It is also used to help both the Practice and other organisations for research and planning, for example research into new treatments, deciding where to put GP clinics and planning for the number of Doctors and Nurses in your local Hospital. It is only used in this way when there is a clear legal basis to use the information to help improve health and care for you, your family and future generations.
Wherever possible we try to use data that does not identify you, but sometimes it is necessary to use your confidential patient information.
You have a choice
You do not need to do anything if you are happy about how your information is used. However, if you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely, either online or through a telephone service. You can change your mind about your choice at any time.
Will choosing this opt-out affect your care and treatment?
No, choosing to opt out will not affect how information is used to support your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.
What do you need to do?
If you are happy for your confidential patient information to be used for research and planning, you do not need to do anything.
To find out more about the benefits of data sharing, how data is protected, or to make/change your opt-out choice visit Your NHS data matters.
You can also view/download the leaflet below for your information.
The NHS operate a Zero Tolerance Policy with regard to violence and abuse and the Practice has the right to remove violent patients from their list with immediate effect, in order to safeguard practice staff, patients and other persons. Violence in this context includes actual or threatened physical violence or verbal abuse which leads to fear for a person’s safety. In this situation we will notify the patient in writing of their removal from the list and record in the patient’s medical records the fact of the removal and the circumstances leading to it.
Where patients are disruptive and display aggressive and/or intimidating behaviour and refuse to leave the premises, staff are instructed to dial 999 for Police assistance, and charges may then be brought against these individuals.