Practice Policies & Patient Information

Our doctors, nurses and staff take pride in offering the highest standard of patient-centred healthcare.

We run many clinics for chronic disease care and offer a wide variety of other medical services such as antenatal and postnatal care, Warfarin monitoring, childhood vaccinations, sexual health, contraception including coils and implants and cryotherapy.

Stone Cross prescription email address: esxccg.prescriptionstx@nhs.net
Stone Cross Email general enquiries address: stone.cross@nhs.net (Please note this email is NOT to be used for any medical issues).

Disabled Access
There is a ramp into the Pevensey Bay Medical Surgery and consulting rooms are available on the ground floor level. Westham Surgery is entirely on ground level with good disabled access. At Stone Cross Surgery, consultation rooms are located on both the ground and first floors; however, a lift is available for easy access

There is designated parking for disabled patients in our car park at Stone Cross and Westham Surgery.

Important information regarding images sent by email
please note that any digital image submitted as part of an online consultation/prior to a consultation will be stored within your clinical notes

Chaperone Policy

Confidentiality

You can be assured that anything you discuss with any member of the surgery staff, whether doctor, nurse or receptionist, will remain confidential. Even if you are under 16, nothing will be said to anyone, including parents, other family members, care workers or teachers, without your permission. The only reason why we might want to consider passing on confidential information without your permission would be to protect either you or someone else from serious harm. In this situation, we would always try to discuss this with you first.

If you have any worries or queries about confidentiality, please ask a member of staff.

If you would like to discuss matters of a confidential nature, either with our receptionists or a member of the dispensary team, we have a side room available in reception for this purpose.

Data Protection

In order to provide the right level of care, we are required to hold personal information about you on our computer systems and in paper records to help us to look after your health needs, and your doctor is responsible for their accuracy and safe-keeping. Please help to keep your record up to date by informing us of any changes to your circumstances.

Confidentiality and Personal Information

Doctors and staff in the practice have access to your medical records to enable them to do their jobs. From time to time information may be shared with others involved in your care if it is necessary. Anyone with access to your record is properly trained in confidentiality issues and is governed by both legal and contractual duty to keep your details private.

All information about you is held securely and appropriate safeguards are in place to prevent accidental loss.

In some circumstances we may be required by law to release your details to statutory or other official bodies, for example if a court order is presented, or in the case of public health issues. In other circumstance you may be required to give written consent before information is released – such as for medical reports for insurance, solicitors etc.

To ensure your privacy, we will not disclose information over the telephone or fax unless we are sure that we are talking to you. Information will not be disclosed to family, friends or spouses unless we have prior written consent, and we do not, leave messages with others.

You have a right to see your records if you wish. Please ask at reception if you would like further details about our patient information leaflet. An appointment may be required. In some circumstances a fee may be payable.

Disabled Access

GDPR

This practice keeps data on you relating to who you are, where you live, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care.

When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS England, a national organisation which has legal responsibilities to collect NHS data.

GPs have always delegated tasks and responsibilities to others that work with them in their surgeries, on average an NHS GP has between 1,500 to 2,500 patients for whom he or she is accountable. It is not possible for the GP to provide hands on personal care for each and every one of those patients in those circumstances, for this reason GPs share your care with others, predominantly within the surgery but occasionally with outside organisations.

If your health needs require care from others elsewhere outside this practice we will exchange with them whatever information about you that is necessary for them to provide that care. When you make contact with healthcare providers outside the practice but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all of those reports. Normally we will receive equivalent reports of contacts you have with non NHS services but this is not always the case.

Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law.

People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments, the practice nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst the GP you see or speak to will normally have access to everything in your record.

You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests. Please see below.

We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.

1) Data Controller contact details	Stone Cross Surgery, Mimram Road, Stone Cross, Pevensey, East Sussex, BN24 5DZ
2) Data Protection Officer contact details	Name: Dr Tim Tran and Charlotte Backler, Contact Details: 01323 761461
3) Purpose of the processing	Direct Care is care delivered to the individual alone, most of which is provided in the surgery. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.
4) Lawful basis for processing	The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the GDPR: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’. Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…” We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”*
5) Recipient or categories of recipients of the processed data	The data will be shared with Health and care professionals and support staff in this surgery and at hospitals, diagnostic and treatment centres who contribute to your personal care, Eastbourne District General Hospital, Conquest Hospital for example
6) Rights to object	You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance
7) Right to access and correct	You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.
8) Retention period	The data will be retained in line with the law and national guidance. https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016 or speak to the practice.
9) Right to Complain.	You have the right to complain to the Information Commissioner’s Office, you can use this link https://ico.org.uk/global/contact-us/ or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website)

* “Common Law Duty of Confidentiality”, common law is not written out in one document like an Act of Parliament. It is a form of law based on previous court cases decided by judges; hence, it is also referred to as ‘judge-made’ or case law. The law is applied by reference to those previous cases, so common law is also said to be based on precedent.

The general position is that if information is given in circumstances where it is expected that a duty of confidence applies, that information cannot normally be disclosed without the information provider’s consent.

In practice, this means that all patient information, whether held on paper, computer, visually or audio recorded, or held in the memory of the professional, must not normally be disclosed without the consent of the patient. It is irrelevant how old the patient is or what the state of their mental health is; the duty still applies.

Three circumstances making disclosure of confidential information lawful are:

where the individual to whom the information relates has consented;
where disclosure is in the public interest; and
where there is a legal duty to do so, for example a court order.

GP Earnings

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.

The average pay for GPs working in Dr Tasharrofi & Partners in the 2023-2024 financial year was £103479 before tax and national insurance.

This is for 0 full time, 7 part time and 2 locum GPs who worked in the practice for more than 6 months.

IT Policy

This practice is committed to preserving, as far as is practical, the security of data used by our information systems. This means that we will take all reasonable actions to;

Maintain the Confidentiality of all data within the practice by:

Ensuring that only authorised persons can gain access to our systems
Not disclosing information to anyone who has no right to see it

Maintain the integrity of all data within the practice by:

Taking care over input
Ensuring that all changes are reported and monitored
Checking that the correct record is on the screen before updating
Reporting all apparent errors and ensuring that they are resolved

Maintain the availability of all data by:

Ensuring that all equipment is protected from intruders
Ensuring that backups are taken at regular, predetermined intervals
Ensuring that contingency is provided for possible failure or equipment theft and that any such contingency plans are tested and kept up to date

Additionally we will take all reasonable measures to comply with our legal responsibilities under:

Patient Record

View your medical record

Sharing Your Medical Record

Increasingly, patient medical data is shared e.g. between GP surgeries and District Nursing, in order to give clinicians access to the most up to date information when attending patients.

The systems we operate require that any sharing of medical information is consented to by patients beforehand. Patients must consent to sharing of the data held by a health provider out to other health providers and must also consent to which of the other providers can access their data.

e.g. it may be necessary to share data held in GP practices with district nurses but the local podiatry department would not need to see it to undertake their work. In this case, patients would allow the surgery to share their data, they would allow the district nurses to access it but they would not allow access by the podiatry department. In this way access to patient data is under patients’ control and can be shared on a ‘need to know’ basis.

Update Your Details

There is a new Central NHS Computer System called the Summary Care Record (SCR). The Summary Care Record is meant to help emergency doctors and nurses help you when you contact them when the surgery is closed. Initially, it will contain just your medications and allergies.

Later on as the central NHS computer system develops, (known as the ‘Summary Care Record’ – SCR), other staff who work in the NHS will be able to access it along with information from hospitals, out of hours services, and specialists letters that may be added as well.

Your information will be extracted from practices such as ours and held on central NHS databases.

As with all new systems there are pros and cons to think about. When you speak to an emergency doctor you might overlook something that is important and if they have access to your medical record it might avoid mistakes or problems, although even then, you should be asked to give your consent each time a member of NHS Staff wishes to access your record, unless you are medically unable to do so.

On the other hand, you may have strong views about sharing your personal information and wish to keep your information at the level of this practice. Connecting for Health (CfH), the government agency responsible for the Summary Care Record have agreed with doctors’ leaders that new patients registering with this practice should be able to decide whether or not their information is uploaded to the Central NHS Computer System.

For existing patients it is different in that it is assumed that you want your record uploaded to the Central NHS Computer System unless you actively opt out.

Personal Data

The following IT systems are in use at the practice:

Referral Management (using NHS numbers in referrals)
Electronic Appointment Booking (the facility to book routine appointments online and, similarly, to cancel appointments
Online booking of repeat prescriptions
Summary Care Record (uploading details of your current medication and allergies to the national “spine” so that these are available for doctors involved in your care elsewhere)
GP to GP transfers (the electronic transfer of records from practice to practice when you re-register
Patient Access to records (the facility to view your medical records online).

If you are not already registered for online access and would like to be please complete our online form.

If you would like access to your medical records enabled or would like to opt out of the local or national summary care record, please contact reception.

Fair Processing Notice (Privacy Notice)

Your Personal Information – what you need to know

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form

Our Commitment to Data Privacy and Confidentiality Issues

As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation. This includes the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.

Data we collect about you

Records which this GP Practice will hold or share about you will include the following:

Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances

where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.

Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place
Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care. For example it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing at Appendix A.

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

improving the quality and standards of care provided
research into the development of new treatments
preventing illness and diseases
monitoring safety
planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

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

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for Health and Social Care 2016.

Individuals Rights under GDPR

Under GDPR 2016 the Law provides the following rights for individuals. The NHS uphold these rights in a number of ways.

The right to be informed
The right of access
The right to rectification
The right to erasure (not an absolute right) only applies in certain circumstances
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and

Your right to opt out of data sharing and processing

The NHS Constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’. For further information please visit: The NHS Constitution

Type 1 Opt Out

This is an objection that prevents an individual’s personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to apply a Type 1 Opt Out to their record they should make their wishes know to the practice manager.

National data opt-out

The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.

By 2020 all health and care organisations are required to apply national data opt-outs where confidential patient information is used for research and planning purposes. NHS Digital has been applying national data opt-outs since 25 May 2018. Public Health England has been applying national data opt-outs since September 2018.

The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to National data opt out programme

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

On this web page you will:

See what is meant by confidential patient information
Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
Find out more about the benefits of sharing data
Understand more about who uses the data
Find out how your data is protected
Be able to access the system to view, set or change your opt-out setting
Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
See the situations where the opt-out will not apply

Right of Access to your information (Subject Access Request)

Under Data Protection Legislation everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access and you may find information has been redacted or removed for the following reasons;

Does not cause harm to the patient
That legal confidentiality obligations for the non-disclosure of third-party information are adhered to

You do not need to give a reason to see your data. And requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require.

Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the extra copies.

You will need to provide proof of identity to receive this information.

If you would like to access your GP record online click here https://www.patientaccess.com

Change of Detail

It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.

Mobile telephone number

If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile.

Email address

Where you have provided us with your email address, with your consent we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email please let us know.

Notification

Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a Data Controller and our registration can be viewed online in the public register at: http://ico.org.uk/what_we_cover/register_of_data_controllers

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Data Protection Officer

Should you have any data protection questions or concerns, please contact our Data Protection Officer via the surgery at: stone.cross@nhs.net

What is the right to know?

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However you can request this under a right of access request – see section above ‘Access to your information’.

Right to Complain

If you have concerns or are unhappy about any of our services, please contact the Charlotte Backler, Practice Manager.

For independent advice about data protection, privacy and data-sharing issues, you can contact:

The Information Commissioner Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

Phone: 0303 123 1113 Website: https://ico.org.uk/global/contact-us

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under Data Protection Legislation.

http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong. https://www.gov.uk/government/publications/the-nhs-constitution-for-england

Appendix A – The Practice will share your information with these organisations where there is a legal basis to do so.

Activity

Rationale

CCG

Purpose – Anonymous data is used by the CCG for planning and

performance as directed in the practices contract.

	Legal Basis – Contractual Processor – Eastbourne, Hailsham and Seaford CCG
Summary Care Record	Purpose – The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable. Legal Basis – Direct Care Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, phone. If you wish to opt- out of having an SCR please return a completed opt-out form to the practice. Processor – NHS England and NHS Digital
Research	Purpose – We many share personal confidential or anonymous information with research companies. Where you have opted out of having your identifiable information shared for this purpose your information will be removed. Legal Basis – consent is required to share confidential patient information for research, unless there is have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales Processor – Clinical Research Network Kent, Surrey and Sussex
Individual Funding Requests	Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our contracts. Legal Basis – The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time
Safeguarding Adults	Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns. Legal Basis – Because of public Interest issues, e.g. to protect the safety

and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.

Data Processor – SAB

Safeguarding Children

Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns.

Legal Basis – Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.

Data Processor – ESSCP

Risk Stratification

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

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

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

Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data

Legal Basis

GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2020 NHS England Risk Stratification which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.

Processors – Stone Cross Surgery

Public Health

Screening programmes

Purpose – Personal identifiable and anonymous data is shared.

The NHS provides national screening programmes so that certain

(identifiable)

Notifiable disease information (identifiable) Smoking cessation (anonymous)

Sexual health (anonymous)

diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.

More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes [Or insert relevant link] or speak to the practice

Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below

Data Processors – Public Health Lewes

NHS Trusts

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

Legal Basis – The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions as stated below:

Processors – ESHT

Care Quality Commission

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

More detail on how they ensure compliance with data protection law (including GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy- statement

Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below

Processors – Care Quality Commission

Payments, Invoice validation

Purpose – Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QUOF), for instance the proportion

of diabetic patients who have had an annual review. Practices can also

	receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws. Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below Data Processors – NHS England, CCG, Public Health
Patient Record data base	Purpose – Your medical record will be shared, in order that a data base can be maintained and managed in a secure way Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below Processor – EMIS
IGPR	Purpose – Your medical record will be shared in order that a report can be provided to agencies such as insurance companies or solicitors Legal Basis – Your consent will be required to share your record for this purpose Processor – iGPR
OptimiseRX AnalyseRX	Purpose – Your anonymous information will be shared in order to optimise your medication within your record. This will enable your GP to provide a more efficient medication regime. Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below Processor – FDB
Medicines Management Team	Purpose – your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes can be implemented. Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below Processor – Eastboume. Hailsham and Seaford CCG
GP Federation	Purpose – Your medical record will be shared with the SDHC Federation in order that they can provide direct care services to the patient population. This could be in the form of video consultations,

	Minor injuries clinics, GP extended access clinics Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below Processor – SDHC federation, LIVI, Engage Consult
PCN	Purpose – Your medical record will be shared with the Eastbourne East Pevensey and Polgate PCN in order that they can provide direct care services to the patient population. Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below Processor – Sovereign Practice, Harbour Practice, Manor Park, Downlands and Stone Cross Surgery
Smoking cessation	Purpose – personal information is shared in order for the smoking cessation service to be provided. Legal Basis – consented Processor – One You
Social Prescribers	Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their social care needs. Legal Basis – Consented
Subject Access Requests	Purpose – Personal information will be shared with the person or their representative at their request Legal Basis – Contractual agreement with the patient – and consented Processor – Patients and or their representatives – e.g. family members, solicitors, insurance companies
Medical Reports	Purpose – Personal information will be shared with Insurance companies, or potential or active employers at the patients request Legal Basis – Consented Processor – Patients and or their representatives – e.g. Insurance companies, RAF, Navy
Police	Purpose – Medical reports may be requested by the police for criminals Legal Basis – Consented or Section 29 Processor – Police Constabulary
Coroners	Purpose – Personal information may be shared with the coroner Legal Basis – Legal Obligation

	Processor – The Coroner
Private healthcare providers	Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patients request Legal Basis – Consented and under contract between the patient and the provider
Texting Service	Purpose – Personal identifiable information shared with the texting service in order that text messages including appointment reminders, campaign messages related to specific patients health needs and direct messages to patients Legal Basis – Consent from patients and direct care Provider – AccuRX and Mjog
Technical solutions for analytics

Reviews of and Changes to our Privacy Notice

We will keep our Privacy Notice under regular review. This notice was last reviewed in November 2019.

Lawful basis for processing:

The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the GDPR:

Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”

Summary Care Record

Your patient record is held securely and confidentially on the electronic system at your GP practice. If you require treatment in another NHS healthcare setting such as an Emergency Department or Minor Injury Unit, those treating you would be better able to give you appropriate care if some of the information from the GP practice were available to them.

This information can now be shared electronically via: The Summary Care Record, used nationally across England

The information will be used only by authorised health care professionals directly involved in your care. Your permission will be asked before the information is accessed, unless the clinician is unable to ask you and there is a clinical reason for access.

If you would like to opt out, please ask reception for our opt out form.

A parent or guardian can request to opt out children under 16 but ultimately it is the GP’s decision whether to create the records or not, because of their duty of care to the child. If you are the parent or guardian of a child under 16 and feel that they are able to understand, then you should make this information available to them.

Who Has Access?

Across all health care settings, including urgent care, community care and outpatient departments in England.

Information Source

GP record

Content

Your current medications
Any allergies you have
Any bad reactions you have had to medicines
Additional information (upon request to your GP)

For more information visit:

www.digital.nhs.uk

Training

GPs in Training

Our practice is approved to train fully qualified doctors who wish to specialise in general practice. Our GP registrar will have had 2-4 years of experience as a qualified hospital doctor working in various specialities. They consult patients on their own, under the mentorship of our trainer, Dr xxxxx. Occasionally we ask permission to video a consultation. You will always be asked in advance and are given the option not to take part, and this will not affect your care in any way. No recording will be taken without your consent and the camera will be switched off on request. These videos are used only for educational purposes with the doctor doing the consultation and are destroyed after use.

Dr xxxxx is currently the GP registrar at the practice.

Medical Students

Medical students are sometimes attached to the practice for 2 – 3 weeks as part of their training. If you do not wish a student to be present during your consultation, please inform the receptionist.

Violence Policy

The Practice staff shall always show due respect and courtesy when dealing with patients and their representatives. We respectfully request that patients and their representatives do the same when dealing with members of the practice team.

The NHS operate a zero tolerance policy with regard to violence and abuse and the practice has the right to remove violent patients from the list with immediate effect in order to safeguard practice staff, patients and other persons.

No form of aggression (whether verbal or physical in nature) will be tolerated – any instances of such behaviour on the practice premises may result in the perpetrator being reported to the Police and removed from the practice’s List of Registered Patients.

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.

About Our Surgery