PRIVATE PRACTICE PRIVACY NOTICE FOR PATIENTS

What is a Privacy Notice?

A Privacy Notice (or ‘Fair Processing Notice’) is an explanation of what information the Private practice collects on patients, and how it is used. Being transparent and providing clear information to patients about how a private practice uses their personal data is an essential requirement of the GDPR & Data Protection Act 2018.

Under the DPA, the first principle is to process personal data in a fair and lawful manner, and applies to everything that is done with patient’s personal information. In private practice, this means that the Private practice must;

  • have legitimate reasons for the use or collection of personal data
  • not use the data in a way that may cause adverse effects on the individuals (e.g. improper sharing of their information with 3rd parties)
  • be transparent about how you the data will be used, and give appropriate privacy notices when collecting their personal data
  • handle personal data only as reasonably expected to do so
  • make no unlawful use of the collected data

Fair Processing

Personal data must be processed in a fair manner – the DPA says that information should be treated as being obtained fairly if it is provided by a person who is legally authorised or required to provide it. Fair Processing means that the Private practice has to be clear and open with people about how their information is used.

Providing a ‘Privacy Notice’ is a way of stating the Private practice’s commitment to being transparent and is a part of fair processing, however you also need to consider the effects of processing on the individuals and patients concerned;

  • What information are we collecting?
  • Who collects the data?
  • How is it collected?
  • Why do we collect it?
  • How will we use the data?
  • Who will we share it with?
  • What is the effect on the individuals?
  • If we use it as intended, will it cause individuals to object or complain?

Conducting a Privacy Impact Assessment is an effective way of assessing whether you can safely collect or use patient data according to the DPA and Information Governance requirements. The Information Commissioners’ Office has published guidance on carrying out a PIA and can be found here;

https://ico.org.uk/media/for-private practices/documents/1595/pia-code-of-private practice.pdf

Data Controllers

Under the Data Protection Act 2018, the data controller is the person or private practice that will decide the purpose and the manner in which any personal data will be processed – they have overall control of the data they collect, and decide how and why it will be processed.

A clinical private practice is a data controller for the patient information it collects, and should already have data processing arrangements with third parties (e.g. IT systems providers) to ensure they do not use or access data unlawfully; the data controllers will have ultimate responsibility for the Private practices’ compliance with the DPA.

Risk Stratification

This is an acceptable way of assessing patients’ needs and prevent ill health, however it is also regarded as a disclosure of personal information, and patients have the option to opt out of any data collection at the Private practice, and needs to be made clear to them.

Access to Personal Information

The DPA gives patients the right to view any information held about them – the ‘Right of Subject Access’. Explain the process and who to contact. You can find your private practice registration number by entering your Private practice name in the ‘Name’ box here; https://ico.org.uk/ESDWebPages/Search

PRIVATE PRACTICE PRIVACY NOTICE

How we use your information

This privacy notice explains why we as a private practice collect information about our patients and how we use that information.

KONCEPT MEDICAL CLINIC manages patient information in accordance with existing laws and with guidance from private practices that govern the provision of healthcare in England such as the Department of Health and the General Medical Council.

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

  • GDPR
  • Data Protection Act 2018
  • Human Rights Act 1998
  • Common Law Duty of Confidentiality
  • Health and Social Care Act 2012

As data controllers, clinicians have fair processing responsibilities under the GDPR & Data Protection Act 2018. In private practice, this means ensuring that your personal confidential data (PCD) is handled clearly and transparently, and in a reasonably expected way.

The Health and Social Care Act 2012 changed the way that personal confidential data is processed, therefore it is important that our patients are aware of and understand these changes, and that you have an opportunity to object and know how to do so.

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare.

Health records may be processed electronically, on paper or a mixture of both; a combination of working private practices and technology are used to ensure that your information is kept confidential and secure. Records held by this private practice may include the following information:

  • Details about you, such as address and next of kin
  • Any contact the private practice has had with you
  • Notes and reports about your health
  • Details about treatment and care received
  • Results of investigations, such as laboratory tests, x-rays,
  • Relevant information from other health professionals, relatives or those who care for you

The private practice collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that the information is kept confidential. However, we can disclose personal information if:

  1. It is required by law
  2. You provide consent – either implicitly or for the sake of their own care, or explicitly for other purposes
  3. It is justified to be in the public interest

Some of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict and secure measures to ensure that individual patients cannot be identified.

Information may be used for clinical audit purposes to monitor the quality of service provided, and may be held centrally and used for statistical purposes. Where we do this we ensure that patient records cannot be identified.

Sometimes your information may be requested to be used for clinical research purposes – the private practice will always endeavour to gain your consent before releasing the information.

Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.

Patients can choose to withdraw their consent to their data being used in this way. When the private practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the private practice and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-out’ of each new scheme.

A patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

KONCEPT MEDICAL CLINIC

Our website does/does not use cookies to optimise your experience. The ‘Remember my details’ feature on our online prescription form uses first party cookies on your computer to store your information. This information is only used to remember your details and is never passed to any third party (cookies must be enabled for this to work).

Using this feature means that you agree to the use of cookies as required by the EU Data Protection Directive 95/46/EC. You have the option to decline the use of cookies on your first visit to the website.

Risk Stratification

Risk stratification is a process for identifying and managing patients who are at high risk of requiring emergency or urgent care. Typically this is because patients have a long term condition such as COPD, cancer or other medical condition at risk of sudden worsening.

Information about you is collected from a number of sources including NHS Trusts and from this private practice. A risk score is then arrived at through an analysis of your de-identified information using the software as the data processor and is provided back in an identifiable form to your doctor or member of your care team as data controller.

Risk stratification enables your doctor to focus on preventing ill health and not just the treatment of sickness. If necessary, your doctor may be able to offer you additional services.

Please note that you have the right to opt out of Risk Stratification.

Should you have any concerns about how your information is managed, or wish to opt out of any data collection at the private practice, please contact the private practice, or your healthcare professional to discuss how the disclosure of your personal information can be limited.

Patients have the right to change their minds and reverse a previous decision. Please contact the private practice, if you change your mind regarding any previous choice.