Partnering Health Limited (PHL) – Information Sharing Protocol
Fair Processing Notice (Also known as Privacy Notice)
Your information; what you need to know
Partnering Health Limited wants all service users to feel confident about the security and privacy of any personal information that we may hold or process.
A core principle of the Data Protection Act 1998 and the EU General Data Protection Regulation (GDPR) is to be transparent and provide accessible information to individuals (patients, clients and other parties) about how personal data held by PHL is used and provide assurance that all data is processed fairly.
To meet this requirement PHL has a duty to produce a Fair Processing Notice.
What PHL do
PHL provides a range of primary care and outpatient based acute healthcare services to both NHS patients and patients wishing to pay for their own treatment.
The majority of patients that we offer services are accessing Out of Hours primary care services as residents of Hampshire and the Isle of Wight.
What sort of information is collected and held by PHL?
PHL will keep a record of basic details for all patients that access our services, this includes address, date of birth, NHS number and records of any treatment you have received from us.
PHL records all calls that are received or made by the Out of Hours service, and some calls received into Best Practice South and Guildhall Walk Health Centre.
Who in PHL collects data and information and has access to information?
Any member of staff who is directly involved in offering a healthcare service may collect data from patients, this includes receptionists, administration staff, nurses, doctors, urgent care practitioners and members of our Quality and Governance team who undertake audits and handle complaints.
All staff members sign a confidentiality agreement as part of their terms of employment and undertake annual information governance (data protection) training to refresh their skills and understanding.
How is information collected and stored by PHL?
PHL takes our obligation to protect the privacy and confidentiality of all our patients and customers seriously.
We collect data largely through our interactions with patients in providing primary healthcare services and this is securely recorded into one of our patient administration systems.
PHL has an IT infrastructure which meets all national and legislative guidelines to ensure that information is collected and stored securely.
Patients accessing services in Best Practice South will have a paper based clinical record and this is stored securely on site at Best Practice.
Why we will collect information about patients and customers
PHL keeps records about the health care treatment and advice we have given to all patients that access one of our services. It is important that we keep a record in order to ensure that PHL is providing the best possible care, and to share where appropriate, with other healthcare agencies in order to equip them with relevant and important information to provide ongoing care.
How will any information collected or stored be used by PHL?
PHL will only collect or store information to effectively provide and deliver healthcare services. For example, it is important that we record what advice has been given to any patient that attends the Out of Hours service for an appointment.
How and why are PHL records shared with the NHS?
The Out of Hours Services and Best Practice South will always pass on information relating to any treatment or advice received to a patient’s registered GP. This allows the registered GP to hold a full and detailed record of a patients clinical history and pathway to better inform future healthcare advice and treatment.
As well as being passed to your registered GP, your information may be used to help assess the needs of the general population and make informed decisions about the provision of future services. Information can also be used to conduct health research and development and monitor NHS performance. Where information is used for statistical purposes, stringent measures are taken to ensure individual patients cannot be identified. Where it is not sufficient to use anonymised information, personal identifiable data may be used, but only for essential NHS purposes. In these circumstances, where it is not practical to obtain your explicit consent, we are informing you through this notice, which is referred to as a Fair Processing Notice, under the Data Protection Act.
We share your information for health purposes with your GP Practice and with NHS Digital. We will also share your information with NHS Trusts for example your local Hospital, NHS 111 or Ambulance service. For patients registered at Guildhall Walk Healthcare Centre it is often necessary to share information to facilitate a referral for further specialist care. Your NHS number allows NHS Digital to link records to the clinical outcome data collected when 111 or 999 patients attend other healthcare services, for example an A&E department or GP.
The NHS Number is classified as a personal data, which means individual details could be identified, however, it is also the most secure form of identifiable data, and the only one we will use when matching the records for linking. We also share your information with our Commissioners (the professional NHS staff who oversee our NHS contracts) to plan future healthcare services. If your personal details are needed to cross-check information that is going to be used in this way, this will be done under secure conditions by organisations that are part of the NHS or linked to it. They use the same confidentiality systems as us.
We are required by law to report certain information to the appropriate local and national authorities. This is only provided after formal permission has been given by a qualified health professional. Occasions when we must pass on information include:
- where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS)
- where a formal court order has been issued
Our guiding principle is that we are holding your records in strictest confidence and only share information when we know it will be used under the same restrictions that we apply to ourselves. Information Sharing with Non-NHS Organisations Information may also be required to be shared for your benefit with other non NHS organisations from which you are also receiving care, such as social services. Where information sharing is requested by non NHS organisations, we will not disclose any health information without your explicit consent, unless there are exceptional circumstances, such as when the health or safety of others is at risk or where the law requires it. We may be asked to share basic information about you, such as your name and address which does not include sensitive information. This would normally be to assist them to carry out their statutory duties.
What is the impact of sharing information on patients and customers?
The intended impact of data sharing is to equip partner healthcare organisations with update to date information regarding a patients medical history and current care pathway to allow the right decisions to be made regarding any ongoing treatment required. Information shared with agencies such as social services is intended to enable up to date records and inform decisions around further involvement required to safeguard or protect vulnerable or at risk children and adults.
Withdrawing consent to share personal information
At any time patients and customers have the right to advise PHL that they do not wish for their information to be shared. The possible consequences will be fully explained to you and could include details in receiving care.
Information collected or stored for marketing purposes
PHL does not collect or store information for marketing purposes. However, we do operate a Facebook page for Guildhall Walk Healthcare Centre and Best Practice South to enable the services to update followers regarding service access, opening times and specialist services such as travel vaccine clinics and ole removal clinics etc. Followers of this page have chosen to opt in to access ongoing updates and we do not store their information anywhere else.
Accessing your health record
Under the Data Protection Act 1998 you have the right to request a copy of any information we hold on you (for which a reasonable fee may be charged). If you want to access your health records you should make a written request to Head of Quality and Governance, PHL, First Floor Cowplain Centre, 26 – 30 London Road, Cowplain, Waterlooville, PO8 8DL.