Privacy Policy

• Data Controller: Dr Yvonne Girgis Hanna
• Data Protection Officer: Dr Rob Howlett

Background – General Data Protection Regulations

The General Data Protection Regulation (GDPR) became law on 24th May 2016. This is a single EU-wide regulation on the protection of confidential and sensitive information. It entered into force in the UK on the 25th May 2018, repealing the Data Protection Act (1998).

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the Data Protection Act 2018 the practice responsible for your personal data.

The practice will be what’s known as the ‘Controller’ of the personal data you provide to Cambridge Private Doctors.

We collect basic personal data about you which includes name, address, email and mobile number. We will only ever ask for and store information that is relevant in order to provide safe and effective care.

We will collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief, ethnicity, and sex during the services we provide to you and/or linked to your healthcare through other health providers or third parties.

Why do we need your information?

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

Where we store your information

All your 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 outside of the UK.

No third parties have access to your personal data unless the law allows them to do so (see safeguarding below) and appropriate safeguards have been put in place. We have Data Protection policies and procedures in place to oversee the secure processing of your personal and or special category (sensitive, confidential) data.

Cambridge Private Doctors health records are predominantly electronic. Information collected via paper is kept to a minimum and scanned on the patient record with paper copies disposed of in confidential waste. We use 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 practice 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 i.e. consultants or your NHS GP.

Cambridge Private Doctors use the following I.T. systems for handling and managing your personal data:-

• Semble – clinical database for storing of medical records.
  https://www.semble.io/privacy-policy
• MyWebGP – membership encrypted communication portal. (please ask a member of our team if you require a copy of the data sharing agreement).
• Microsoft 365 – We use Microsoft 365 in our practice to securely manage emails, documents, and patient-related information in compliance with NHS and data protection standards.
  https://www.microsoft.com/en-gb/privacy/privacystatement
• Heidi – AI tool for populating clinical consultations within Semble.
  https://www.heidihealth.com/uk/legal/privacy-policy
• Docmail – posting of hardcopy documentation.
  https://www.cfh.com/legal/
• Mailchimp – patient newsletter circulation and certain integrated functions through Semble clinical system.
  https://mailchimp.com/gdpr/
• Surveymonkey – patient surveys.
  https://www.surveymonkey.com/product/features/privacy/

These systems are all compliant with GDPR regulations and are provided by ISO 27001 suppliers or meet the equivalent standard. A log of all systems is kept along with copies of their privacy and data security policies, which is reviewed on a regular basis to ensure ongoing compliance.

How do we lawfully use your data & legal requirements

Cambridge Private Doctors do not currently partake in any forms of research but the following sections of the GDPR mean that we can use medical records for research and to check the quality of care (national clinical audits)

Article 6(1)(e) – ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’.

For medical research: there are two possible Article 9 conditions.

Article 9(2)(a) – ‘the data subject has given explicit consent…’

To check the quality of care (clinical audit):

Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services…’

Risk stratification data tools – these are increasingly being used in the NHS to gather information in order to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Currently Private GP Practices do not form part of this data gathering process.

Audits – The practice regularly carries out audits to ensure safe practices are being followed. These may include things such as medication management and management of hypertension. All results are annoymised and used to assist with continuous service improvements. We may be requested to carry out audits and share the outcomes with the following organisations:-

• NHS Digital
• the Care Quality Commission.
• local health protection team or Public Health England.
• the court if ordered.

Safeguarding – Sometimes we need to share information so that other people, including healthcare staff, children or others with safeguarding needs, are protected from risk of harm. These instances are rare. We do not need your consent or agreement to share information in these circumstances, as we are required to do this in the best interest of the patient or others.

Care Quality Commission (CQC) – The CQC regulates health and social care services to ensure that safe care is provided. The law states that we must report serious events to the CQC. The CQC will undertake regular inspections and audits of clinic activity to ensure safe patient care and services which will include review of patient data and clinical audits. Reports on the findings from inspection are publicised using annonymised data and summary of findings. For more information about the CQC see: http://www.cqc.org.uk/

Public Health – The law requires us to share data for public health reasons, for example to prevent the spread of infectious diseases or other diseases which threaten the health of the population. We will report the relevant information to local health protection team or Public Health England. For more information about Public Health England and disease reporting see: https://www.gov.uk/guidance/notifiable-diseases-and-causative-organisms-how-to-report

How do we maintain the confidentiality of your records? 

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

• Data Protection Act 2018
• The General Data Protection Regulations 2016
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management
• Information: To Share or Not to Share Review

Every member of staff who works at Cambridge Private Doctors has a legal obligation to keep information about you confidential. All employees and sub-contractors engaged by our practice 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.

All employees and sub-contractors are required to undertake regular mandatory training relating to data and information security.

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 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.

Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the 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.

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 patient information is annoymised.

With your consent we would also like to use your information to inform you of other services

We would however like to use your name, contact details and email address to inform you of services that may benefit you. Specific written consent will be obtained from patients on registration with the practice.

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 as below.

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 Services
• GP’s
• Independent Contractors such as dentists, opticians, pharmacists
• Other Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• 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 specific consent for this to happen when this is required.

We 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.

Record retention period

The practice will keep general practice medical records for the lifetime of the patient and for a further period of 10 years after death, in line with guidance from the British Medical Association.

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

You have rights in relation to the personal data we hold on you. If you would like to discuss this with us you can write to the practice manager. We will seek to deal with your request in a timely manner and in accordance with the requirements of any applicable laws. Please note that we make a log of your communications with us to assist in resolving any queries.

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.

Withdrawal of consent: Where you wish to withdraw consent previously given you have a right to do so and can speak with your clinician or the practice manager in order to withdraw.

Erasing of records: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” personal data we hold on you. 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 remove your data.

Moving of data: If you wish, you have the right to transfer your data from us to another data controller.

National Data Opt-Out

Cambridge Private Doctors is a private GP practice and so data is not automatically extracted by NHS Digital. Should there be a requirement to share information with NHS Digital, patients will be asked to provide explicit consent to do so and the reasons why.

For more information about NHS Digital please visit this link https://nhs.uk/your-nhs-data-matters/.

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 practice holds about you and to have it amended should it be inaccurate. The Practice hold a separate policy on this which is available on request. To make a subject access request please write to the Practice Manager. There is no charge to have a copy of the information held about you and we are required to provide the information within 28 days of receipt of the written request. Please provide full name, address, date of birth, NHS number if known, along with what information you require. Please note we may need to contact you to verify your identification before releasing any information.