SSP Health
Privacy Notice

Medicines Management

SSP Health GP Practices may conduct Medicines Management reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.

How do we maintain the confidentiality of your records?

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

• Data Protection Act 2018 (UK GDPR 2021)

• The General Data Protection Regulations 2016

• Human Rights Act 1998

• Freedom of Information

• Common Law Duty of Confidentiality

• Health and Social Care Act 2022

• NHS Codes of Confidentiality, Information Security Governance and Records Management

• Information to share or not to share – Caldicott review

Every member of staff who works for SSP health, as an organisation has a legal obligation to keep information about you confidential.

We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission, and consent, unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles.

SSP Health’s policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the UK General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.

All SSP employees and sub-contractors engaged by our practices are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a sub-contractor acts as a data processor for the practice an appropriate contract (art 24-28) will be established for the processing of your information.

In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent. If some circumstances, we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.

Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose in an identifiable format. In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes.

With your consent we would also like to use your information, including research projects

We would however like to use your name, contact details and email address to inform you of services that may benefit you, with your consent only. There may be occasions were authorised research facilities would like you to take part on innovations, research, improving services or identifying trends.

At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place. This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO (please speak to your Practice Manager for information).

Where do we store your information electronically?

All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.

No 3rd parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place. We have a Data Protection programme in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;

• NHS Trusts / Foundation Trusts

• GP’s

• Independent Contractors such as dentists, opticians, pharmacists

• Private Sector Providers

• Voluntary Sector Providers

• Ambulance Trusts

• Clinical Commissioning Groups

• Primary Care Networks

• Social Care Services

• NHS England (NHSE) and NHS Digital (NHSD)

• Local Authorities

• Education Services

• Fire and Rescue Services

• Police & Judicial Services

• Voluntary Sector Providers

• Private Sector Providers

• Other ‘data processors’ which you will be informed of.

You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.

SSP Health may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure. All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for the practice an appropriate contract (art 24-28) will be established for the processing of your information.

How long will we store your information?

SSP Health are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records Management Code of Practice 2021, for health and social care and national archives requirements. More information on records retention can be found online at: Records Management Code of Practice 2021 - NHS Transformation Directorate (england.nhs.uk)

How can you access, amend move the personal data that you have given to us?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.

Access to your personal information

Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:

• Your request should be made to the Practice – for information from the hospital you should write direct to them

• There is no charge to have a copy of the information held about you

• We are required to respond to you within one month

• You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.

What should you do if your personal information changes?

You should tell us so that we can update our records please contact the Practice Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.

We have agreed to share the patient data we look after in our practice with NHS Digital who will securely store, analyse, publish, and share this patient data to improve health and care services for everyone. This includes:

• informing and developing health and social care policy

• planning and commissioning health and care services

• taking steps to protect public health (including managing and monitoring the coronavirus pandemic)

• in exceptional circumstances, providing you with individual care

• enabling healthcare and scientific research

This means that we can get on with looking after our patients and NHS Digital can provide controlled access to patient data to the NHS and other organisations who need to use it to improve health and care for everyone.

Contributing to research projects will benefit us all as better and safer treatments are introduced more quickly and effectively without compromising your privacy and confidentiality.

NHS Digital has engaged with the British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure relevant safeguards are in place for patients and all SSP GP practices.

Please Contact your SSP GP Practice Manager for any queries to the above notice.