In accordance with the General Data Protection Regulations 2016 and the Data Protection Act 2018 and Access to Health Records Act, patients may request to see their medical records. Such requests should be made through the practice manager and may be subject to an administration charge if they are excessive or duplicated. No information will be released without the patient consent unless we are legally obliged to do so. If you wish to add any information to your medical record, please write to the practice.

We welcome compliments, suggestions or concerns about the services you have received from the doctors or any staff working in this practice.

We operate a practice complaints procedure as part of an NHS system.

As a patient of the NHS, you have a right to:

• Have your complaint dealt with efficiently
• Have your complaint properly investigated
• Be informed of the outcome of your complaint
• Take your complaint to the Health Ombudsman if you are not satisfied with the outcome

Our aim is to give you the highest possible standard of service, and we try to deal quickly with any problems that may occur.

If you would like to discuss a complaint or the complaints procedure please contact Tina Coulson, our Practice Manager, on 01293 540 620. You can also write us a letter or email us at sxicb-wsx.pound_hill.reception@nhs.net.

If you would like advocacy support when making a complaint, you can contact Healthwatch West Sussex.

If you are not happy with our response, you can ask the Health Service Ombudsman for an independent review.

If you have a complaint about a service from another NHS organisation, NHS Sussex has a list of where you can complain.

Practice Compliments

We are continuously overwhelmed by the number of compliments that we receive at the practice and we really appreciate the time and effort our patients take to do this. It is a great morale booster to those individuals who are on the receiving end as well as the whole team here so please keep them coming!

You can send a compliment by letter or email us at sxicb-wsx.pound_hill.reception@nhs.net. You can also leave a review on our NHS profile. We read all of these and pass them to the staff involved. Thank you so much to everyone who takes the time to send in their thoughts.

The practice complies with data protection and access to medical records legislation. Identifiable information about you will be shared with others in the following circumstances:

• To provide further medical treatment for you e.g. from district nurses and hospital services.
• To help you get other services e.g. from the social work department. This requires your consent.
• When we have a duty to others e.g. in child protection cases anonymised patient information will also be used at local and national level to help the Health Board and Government plan services e.g. for diabetic care.

If you do not wish anonymous information about you to be used in such a way, please let us know.

Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.

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 always being 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 us and other organisations for research and planning such as 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. 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 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 www.nhs.uk/your-nhs-data-matters

Download a copy of the patient leaflet

The core commitment of Pound Hill Medical Group is to provide fair, accessible primary care services for its registered population. The Surgery is committed to actively recognising and promoting equality and diversity within our community and believes that people who use our services, their carers and our staff should be treated with respect and dignity.

The Surgery is committed to challenging discrimination in all its forms and ensuring that equality lies at the heart of everything we do. It is our aim to be a fair and equitable organisation, one where everyone accepts differences between individuals and values the benefits that diversity brings. Ending discrimination is not simply about making our practice accessible, but about systematically identifying barriers and thus reducing inequalities.

What is Equality & Diversity all about?

Whether we are members of staff, patients, carers, service users, we all want to live in communities where we can all participate fully and equally. When we need to see a doctor we want this service to be delivered in ways which help inclusion.

Equality to us is about creating a fairer society where everyone can participate and has the opportunity to fulfil their potential. It is not about treating people the same, but recognising that everyone has different needs, which need to be met in different ways.

Diversity to us is the many distinct characteristics that staff, patients, service users, and carers bring to our practice. Our Surgery recognises and values the difference within our communities and the workplace. We can learn from the differences of others and become more understanding.

As a GP practice, we have a legal requirement to promote equality and set out how we plan to meet the ‘general and specific duties’ specified in the Public Sector Equality Duty of the Equality Act 2010.

Background

The Equality Act became law in October 2010 and was subject to Amendment in 2012. It replaced all previous legislation (such as the Race Relations Act 1976 and the Disability Discrimination Act 1995). The Act is there to strengthen protection, advance equality and simplify the law. The Act has a Public Sector Equality Duty which specific duties came into force on 10th September 2011. The Act now gives protection to groups of people who experience discrimination and have protection from this legislation. These are known as protected characteristics. It is unlawful to discriminate on the grounds of:

• age
• disability
• gender reassignment
• marriage and civil partnership
• pregnancy and maternity
• race
• religion or belief
• sex
• sexual orientation

Information about the General Practitioners and the practice required for disclosure under this act can be made available to the public. All requests for such information should be made to the practice manager.

March 2024

NHS England require that the net earnings of doctors engaged in the practice is publicised, and the required disclosure is shown below. 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.

All GP Practices are required to declare mean earnings (i.e. average pay) for GPs working to deliver NHS services to patients at each practice. The average pay for GPs working at The Pound Hill Medical Group in the last financial year was £77,224 before Tax and National Insurance. This is for 3 full time GPs, 6 part time GPs and 2 locum GP who worked in the practice for more than six months.

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 that 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) now known as the UK 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. Where your record is accessed without your permission it is necessary for them to have a legitimate basis in law. This is explained further in the Local Information Sharing in Appendix – List of Processors.

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 by the service
• research into the development of new treatments and care pathways
• preventing illness and diseases
• monitoring safety
• planning services
• risk stratification
• Population Health Management

Safeguarding of children or vulnerable adults

If we have significant concerns or hear about an individual child or vulnerable adult being at risk of harm, we may share relevant information with other organisations, such as local authorities and the Police, involved in ensuring their safety.

Statutory disclosures

Sometimes we are duty bound by laws to disclose information to organisations such as the Care Quality Commission, the Driver and Vehicle Licencing Agency, the General Medical Council, Her Majesty’s Revenue and Customs and Counter Fraud services.  In these circumstances, we will always try to inform you before we are required to disclose and we only disclose the minimum information that the law requires of us.

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 or with consent.

Pseudonymised or anonymised data is generally used for research and planning so that you cannot be identified.

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

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from the Records Management Code of Practice – NHSX.  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 2020.

Individuals Rights under GDPR

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

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure (not an absolute right) only applies in certain circumstances
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

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’.

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 their individual direct care, or in particular circumstances required by law, such as a public health screening, or an emergency like an outbreak of a pandemic disease. If you wish to apply a Type 1 Opt Out to their record, you should make your 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.

The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to use a patient’s confidential patient information for purposes beyond their individual care, for planning or research. 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 to 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 to and you may find information has been redacted or removed for the following reasons:

• It may be deemed to risk causing harm to you or to others
• The information within the record may relate to third parties who are entitled to their confidentiality, or who have not given their permission for the information to be shared.

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

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

You will need to provide proof of identity to receive this information. We will not share information relating to you with other individuals without your explicit instruction or without sight of a legal document.

Patients may also request to have online access to their data. You can do this via the NHS App, or via the practice’s system Patient Access.

Change of Details

It is important that you tell the surgery if any of your contact details such as your name or address have changed, or if any of your other contact details are incorrect including third party emergency contact details.  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 will use this to send you text reminders about your appointments or other health related information.  It is within our legal duty as a public authority to keep our patients updated with important information.

We also use the NHS Account Messaging Service provided by NHS England to send you messages relating to your health and care. You need to be an NHS App user to receive these messages. Further information about the service can be found at the privacy notice for the NHS App managed by NHS England.

Email address

Where you have provided us with your email address, 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 sxicb-wsx.pound_hill.reception@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 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 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