Norfolk Primary Care and Your Information

This notice is summarised in video form below if you prefer.

Norfolk Primary Care – ICO Registered
An overview of Norfolk Primary Care’s commitment to data protection as an ICO-registered organisation, ensuring compliance with UK GDPR standards.

Norfolk Primary Care – Patient Rights
A guide to understanding your rights as a patient at Norfolk Primary Care, including how your personal data is managed and protected.

Norfolk Primary Care – Securing Your Data
Learn about the measures Norfolk Primary Care takes to ensure the security and confidentiality of your personal health data.

Norfolk Primary Care – Your Information
An explanation of how Norfolk Primary Care collects, uses, and safeguards your personal information in compliance with data protection regulations.

We take your privacy very seriously. We are registered with the Information Commissioner’s Office as a Data Controller and our registration number can be found if you search the ICO online register.

We aim to provide you with the highest quality health care.

To do this we must keep records about you, your health and the care we have provided or plan to provide to you.

Your doctor and other health professionals caring for you, such as nurses or physiotherapists, keep records about your health and treatment so that they are able to provide you with the best possible care.

Please be aware that both clinical and administrative staff will access your personal data, this allows us to manage high volumes of communication and activity.

Administrative staff are bound by confidentiality in the same way as the clinician is and will keep your information private.

These records are called your ‘health care record’ and may be stored in paper form or on computer and electronic systems and may include Personal Data;

• basic details about you, such as address, date of birth, NHS number, and next of kin as well as Sensitive Personal Data;
• contact we have had with you, such as clinical visits
• notes and reports about your health
• details and records about your treatment and care
• results of x-rays, laboratory tests etc

Healthcare providers are permitted to collect, store, use and share this information under Data Protection Legislation which has a specific section related to healthcare information.

If you have any questions or wish to make a request in relation to your information, please contact us using the details on our main page or contact our Data Protection Officer at [email protected]

Our Data Protection Officer service is provided by Kafico Ltd. When we ask for their support, we will aim to remove any reference to individual patients. Where this is not possible, we will use the minimum necessary to allow us to obtain advice and support.

You can find out more about Kafico Ltd, including their privacy policy at https://www.kafico.co.uk/privacy-policy

What We Do With Your Information

Below is a description of the routine uses of your information;

• Refer you to other healthcare providers when you need other service or tests
• Discuss or share information about your health or care with other health or social care providers
• Share samples with laboratories for testing (like blood samples)
• Share test results with hospitals or community services (like blood test results)
• Allow out of hours or extended hours GPs to look at your health record when you are going to an appointment
• Send prescriptions to a pharmacy
• Text patients in relation to healthcare services. See Information Technology for more information.
• Samples are provided to the courier for delivery to pathology
• Share reports with the coroner
• Receive reports of appointments you have attended elsewhere such as with the community nurse or if you have had a stay in hospital
• Produce medical reports on request from third parties such as the DVLA or your employer
• Movement of Patient records to Primary Care Support England

Along with activities related directly to your care, we also use information in ways which allow us to check that care is safe and provide data for the improvement and planning of services.

• Quality / payment / performance reports are provided to service commissioners
• As part of clinical research – information that identifies you will be removed, unless you have consented to being identified
• Undertaking clinical audits locally to ensure safety and efficiency
• Supporting staff training
• Incident and complaint management
• Sending Norfolk Primary Care information to other NHS bodies for national audits or research that are required by law (e.g. NHS Digital Audit Data Collection) or the Learning Disabilities Census
• Local evaluations and planning activities

Sharing When Required by Law

Sometimes we will be required by law to share your information and will not always be able to discuss this with you directly. Examples might be for the purposes of detection or prevention of crime, where it is in the wider public interest, to safeguard children or vulnerable adults, reporting infectious diseases or where required by court order.

Care Quality Commission Access to Health Records

CQC has powers under the Health and Social Care Act 2008 to access and use your health information where it is necessary to carry out their functions as a regulator.

This means that inspectors may ask to look at certain records to decide whether we are providing safe, good quality care.

More information about the CQC can be obtained on their website https://www.cqc.org.uk/about-us/our-policies/privacy-statement

Children and Young People

Young people from aged 13 (and sometimes younger) are allowed to make decisions about how their health information is shared.

A parent or guardian may apply for access to young person’s information.

If a young person does not consent – we may not provide access to the adult.

If the young person does not have the capacity to understand, we may provide access to the adult because it is in the young person’s best interest to do so.

Young people can ask us to keep certain parts of their information confidential.

If the young person is making decisions about their information that puts them at risk – we may notify adults with parental rights.

Information Technology

Norfolk Primary Care will use third parties to provide services that involve your information such as;

• Removal and destruction of confidential waste
• Provision of clinical systems
• Provision of connectivity and servers
• Digital dictation services
• Data analytics or warehousing (these allow us to make decisions about care or see how effectively Norfolk Primary Care is run – personal data will never be sold or made available to organisations not related to your care delivery)

We have contracts in place with these third parties that prevent them from using it in any other way than instructed. These contracts also require them to maintain good standards of security to ensure your confidentiality.

Text Messaging

Norfolk Primary Care may wish to use text messaging to communicate with you about our activities or your own healthcare. 

We may text you;

• To send survey/questionnaires which save directly into your record 
• With a link so you can send photos to the clinician of your rash or lump for example
• Ask you to update clinicians on your treatment or wellbeing
• Invite you to health screenings or vaccinations
• send referrals letters or summaries
• Contact you if you miss an appointment e.g. at outpatients 
• Contact you if you are not able to answer a phone call
• Send you test results or ask you to call to discuss your results
• Send you general public health messages about COVID 19, flu clinics, mental health or wellbeing services
• In relation to research projects, unless you have objected

You can object at any time by getting in touch with us.

If you share a mobile phone with someone, please be mindful that they may see information about your health.

For information about the providers, we use for our SMS, please see our list of providers on the main privacy policy page.

Information Rights

Data protection law provides you with a number of rights that Norfolk Primary Care is committed to supporting you with;

Right to Access

You have the right to obtain:

• Confirmation that your information is being used, stored or shared by Norfolk Primary Care
• A copy of information held about you
• We will respond to your request within one month of receipt or will tell you when it might take longer.
• We are required to validate your identity including the identity of someone making a request on your behalf

Right to Object or Withdrawn Consent

We mainly use, store and share your information because we are permitted in order to deliver your healthcare, but you do have a right to object to us doing this.

Where we are using, storing and sharing your information based on explicit consent you have provided, you have a right to withdraw that consent at any time.

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.

Visit nhs.uk/your-nhs-data-matters to opt out

Our Data Protection Officer will be happy to speak with you about any concerns you have.

Right to Correction

If information about you is incorrect, you are entitled to request that we correct it

There may be occasions, where we are required by law to maintain the original information – our Data Protection Officer will talk to you about this and you may request that the information is not used during this time.

We will respond to your request within one month of receipt or will tell you when it might take longer.

Right to Complain

You also have the right to make complaints and request investigations into the way your information is used. Please contact our Data Protection Officer or visit the link below for more information.

For more detailed information on your rights visit https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Keeping Your Information Safe

We are committed to ensuring the security and confidentiality of your information.

There are a number of ways we do this;

• Staff receive annual training about protecting and using personal data
• Policies are in place for staff to follow and are regularly reviewed
• We check that only the minimum amount of data is shared or accessed
• We use ‘smartcards’ to access systems, this helps to ensure that the right people are accessing data – people with a ‘need to know’
• We use encrypted emails and storage which would make it difficult for someone to ‘intercept’ your information
• We report and manage incidents to make sure we learn from them and improve
• We put in place contracts that require providers and suppliers to protect your data as well
• We do not send your data outside of the UK without appropriate, lawful safeguards.
• We submit a Data Security and Protection Toolkit on an annual basis which demonstrates our commitment and compliance with national data standards.

How Long We Keep Your Information

In line with the NHSX Records Management Code of Practice, we will retain / store your health record for your lifetime.

Who we Share Your Information With

You can find a list of the organisations we may share information with by clicking here.

Below, you will see a list of the suppliers that help us deliver our services.

EMIS Web                              https://www.emishealth.com/products/emis-web 

SystmOne (TPP)                    https://www.tpp-uk.com/

NWICB                                   https://www.norfolkandwaveneyccg.nhs.uk/ 

ShredIt                                   https://www.shredit.co.uk/en-gb

ISS pathology Couriers          www.issdistribution.co.uk/ 

Arden and Gem CSU             https://www.ardengemcsu.nhs.uk/

Microsoft Teams                     https://www.microsoft.com/en-gb/  

NCS Limited                           https://www.ncs-ltd.com/

WordPress                              https://wordpress.com/

Covergence                            https://www.convergence.finance/

Daisy Telecommunications    https://daisycomms.co.uk/

Xyla Health and Wellbeing      https://xylahealthandwellbeing.com

Our Services and Your Information

Norfolk Primary Care provides a number of services that involve the use of your personal data. We have explained each of these services below:

Enhanced Access Clinics

Patients accessing this service are provided with consultation, investigation and appropriate agreed treatment.  The consultation includes assessment and management with the implementation of an agreed plan, which is communicated to the service users own GP practice via a digital platform.  

Home Visiting Service – Norwich

NPC provide a Home Visiting Service for 17 GP practices based in Norwich. NPC Clinicians will visit patients requested by their registered practice . The consultation includes assessment and management with the implementation of an agreed plan, which is communicated to the service users own GP practice via the Clinical System.

GP at the Front Door (GPFD) Service

NPC have a unit at local hospitals where our doctors and nurses can see people arriving at Accident and Emergency. Patients will be sent to use and we will assess them to see if we can help them and prevent them from having to wait for hospital care. We will update our own clinical systems and let the hospital know how many people we have seen.

Rapid Diagnostic Service

The RDS is a clinical service led by a Team of GPs which co-ordinates patient care – streamlining referrals, tests, results and management plans for patients with serious nonspecific symptoms – SNSS (Serious Non Specific Symptoms), while improving the patient experience through having a dedicated accessible patient pathway navigator (PPN). They have full access to the GP records to enable the assessment, diagnosis, and discharge or onward referral for patient care.

Lower GI Support Service

The Lower GI Support Service is led by a Team of GPs, Nurses and Admin Staff  who work in collaboration with our three acute trusts locally to support waiting lists and patients care. Staff have access to the GP records to enable the assessment and treatment for patient care.

Primary Care Network (PCN) Support

The PCN Support team has access to SystemOne (clinical system) and uses its reporting functionality to provide aggregate data to commissioners for reporting purposes. Patient records may be accessed where there is a legitimate reason for doing so, in the patients best interests, or to support their direct care.

Additional Roles Reimbursement Scheme (ARRS) Staff

The Additional Roles Reimbursement Scheme (ARRS) enables NPC to employ a workforce of clinical and non-clinical staff and deploy them to general practices in Norfolk and Waveney. NPC acts as the employer to connect services and people to maximise efficiency and capacity. Operating within a GP Practice, staff will act in accordance with practice policy.  

Norwich Walk-in-Centre (WIC)

The WIC is able to treat patients with minor acute illnesses and injuries. When a patient attends at the WIC, treating clinicians and admin support staff are able to access their clinical record through SystemOne. Following consultation and treatment if necessary, notes are added (with consent to share) which forms part of the clinical record – this means that other services and clinicians are able to see information relating to that health episode. This helps to enable continuity of care and forms part of the Norfolk Shared Care Record. If the patient is registered with a GP Practice which is not on SystemOne, details will be securely shared with the persons GP.

Norwich Health Centre

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received (e.g. NHS Trust, GP Surgery, Walk-in Centre, 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 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

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided