PRIVACY NOTICE FOR WEBSITE USERS

Who we are

Our website address is: https://www.earcareacademy.co.uk.

 

Ear Care Academy operates https://www.earcareacademy.co.uk (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site. We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

 

Information Collection And Use

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name (“Personal Information”).

 

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze you actions on the website. We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information.

 

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

 

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

 

Changes To This Privacy Policy

This Privacy Policy is effective as of 15/1/2019 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.  We reserve the right to update or change our Privacy Policy at any time and you should check this  Privacy Policy periodically. Your continued use of the Service after we post any modifications to the  Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.  If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

 

Privacy Policy with Respect to Patients and Patient Care

  • We collect information about you to help provide you with the best possible care
  • We have a legal duty to keep your information secure. We have regular audits and independent reviews to make sure that we do
  • We share your information with other health and social care organisations involved in your care
  • We also use your information to contribute to planning, service improvements and medical research. In the case of research, we remove any information that identifies you personally
  • We use other organisations to help us process your information – we ensure that your information is also handled securely by them, including when they are based outside of the UK
  • We will only use your information for these reasons if it is lawful
  • For most patients information is retained for a minimum of eight years from when you were last seen
  • You can request access to the information we hold about you and you can ask us to correct any errors

Why do you collect my information?

We collect information about you to help us provide you with the best possible care. The information we collect includes your name, date of birth, NHS number, contact details and notes and correspondence about your health and care.

This information also helps us to plan and improve our services and contributes to medical research. For research purposes, we remove any information that identifies you personally.

What are your legal duties as an NHS Trust?

The law allows us to use your information for your care, for service improvement and for research. We are bound by the General Data Protection Regulation to use your information fairly and lawfully.

In certain circumstances, there may be other reasons why we would use your information – for example, to share information with the police in order to prevent a serious crime – but it will always be in line with our legal duty.

Will my information be shared with anyone else?

We share your information with other health and social care organisations involved in your care. In turn, health and social care organisations involved in your care share your information with us.

We share your information with other NHS organisations to contribute to planning or service improvements.

We share with our research partners to undertake medical research. For these purposes, we remove any information that identifies you personally.

We use other organisations to help us process your information, for example to run our electronic patient records system. The information can only be used in the way that we instruct them to use it. Read our leaflet Using technology to give more time for patient care to learn more.

How is my information kept secure?

We have a legal duty to keep your information secure. Our staff undertake annual training about information security and we have regular audits and independent reviews to make sure that we do keep your information safe. We use other organisations to help us process your information. We make sure these organisations also comply with their legal obligations to keep your information secure, including when they are based outside of the UK.

How long will you keep my information?

Information is retained for a minimum of eight years from when you were last seen for most patients. For some types of information, we retain the information a longer period. For example, maternity and children’s records must be retained for at least 25 years.

What are my rights regarding my information?

You have the right to request a copy of the information that we hold about you – this is called a ‘subject access request.’ We will provide this on paper or electronically within one month of your request in most cases.

If the information that we hold about you is incorrect, you have the right to have it corrected.

More information and contacts

You can find out more by reading our patient privacy notice.

Our Data Protection Officer is Philip Robinson, you can contact him at:

ICT Division, Charing Cross Hospital, London, W6 8RF
Email: imperial.dpo@nhs.net
Telephone: 020 3311 7344

If you want to access the information that we hold about you, please email: imperial.accesstohealthrecords@nhs.net

Imperial College Healthcare NHS Trust is a registered data controller under the Information Commissioner’s Office.

You can contact the Information Commissioner’s Office at:

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: www.ico.org.uk/concerns
Telephone: 0303 123 1113

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information may 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 within any NHS organisation. These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for 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 may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form.

The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments.

Details we collect about you

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP Surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

Records which this GP Practice may hold about you include the following:

  • Details about you, such as your address and next of kin
  • Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments,
  • Notes and reports about your health
  • Details about your treatment and care
  • Results of investigations, such as laboratory tests, x-rays,
  • Relevant information from other health professionals, relatives or your carers

How we keep your information confidential and safe

Everyone working for our organisation is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law. The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared. All our staff are expected to make sure information is kept confidential and receive regular training on how to do this.

The health records we use may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Your records are backed up securely in line with NHS standard procedures. We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

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

  • Data Protection Act 2018
  • Human Rights Act
  • Common Law Duty of Confidentiality
  • NHS Codes of Confidentiality and Information Security
  • Health and Social Care Act 2015
  • And all applicable legislation

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that 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 (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for 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. This is explained further in the Local Information Sharing section below.

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.

You may choose to withdraw your consent to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we aim to display prominent notices in the Practice and on our website four weeks before the scheme is due to start.

Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.

You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.

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.

Child Health Information

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS CLCH health visitors and school nurses, and with NWL Commissioning Support Unit, who provide the Child Health Information Service on behalf of NHS England.

Clinical audit

Information may be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

Clinical Research

Sometimes anonymised data may be used for research purposes – but we will always ask your permission before releasing any information for this purpose which could be used to identify you.

Improving Diabetes Care and long-term condition management

Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led local diabetes and long term condition management review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.

Individual Funding Request

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for funding of specialised healthcare which falls outside the range of services and treatments that CCG has agreed to commission for the local population. An Individual Funding Request is taken under

consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition

who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to check which CCG is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

Local Information Sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a local health or care professional outside of your usual practice services, such as in an Evening and Weekend GP HUB services, Emergency Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them. If those services use a TPP clinical system your full SystmOne medical record will only be shared with your express consent.

Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to

view either parts of your GP electronic patient record (e.g. your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. TPP SystmOne medical records or EMIS remote consulting system).

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).

National Fraud Initiative – Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see:

https://www.gov.uk/government/publications/code-of-data-matching-practice-for-national-fraud- initiative

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

Risk Stratification

‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.

Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health.

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the NWL Clinical Commissioning Groups. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from: https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification /

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.

Safeguarding

To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.

Summary Care Record (SCR)

The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.

Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, fax or phone. If you wish to opt- out of having an SCR please return a completed opt-out form to the practice.

Supporting Medicines Management

NWL CCGs use pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the CCG medicines management team may provide relating to obtaining medications on behalf of your GP Practice to support your care.

Supporting Locally Commissioned Services

CCGs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality. The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

Suspected Cancer

Data may be analysed in cases of suspected cancer by The Royal Marsden NHS Trust, The Royal Brompton Hospital, Imperial College Healthcare NHS Trust , Chelsea and Westminster Hospital NHS Foundation Trust, London North West Healthcare NHS Trust and University College London Hospitals NHS Foundation Trust to facilitate the prevention, early diagnosis and management of illness. Measures are taken to ensure the data for analysis does not identify individual patients.

Data Retention

We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.

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
  • Specialist Trusts
  • GP Federations
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Clinical Commissioning Groups
  • Social Care Services
  • Local Authorities
  • Education Services
  • Fire and Rescue Services
  • Police
  • Other ‘data processors’

Specific details of the organisations with whom we share your data can be seen here [Include only relevant CCG below]:

H&F – http://www.hammersmithfulhamccg.nhs.uk/what-we-do/your-patient-record.aspx

Central London – http://www.centrallondonccg.nhs.uk/what-we-do/your-patient-record.aspx

West London – http://www.westlondonccg.nhs.uk/about-us/patientrecord.aspx

Hounslow – http://www.hounslowccg.nhs.uk/about-us/patient-record.aspx

Ealing – http://www.ealingccg.nhs.uk/about-us/patient-record.aspx

Brent – http://brentccg.nhs.uk/en/about-us/your-patient-record

Harrow – https://www.harrowccg.nhs.uk/your-patient-record

Hounslow – https://www.hillingdonccg.nhs.uk/your-patient-record​

 

We will never share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function.

Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below).

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued. Our guiding principle is that we are holding your records in strictest confidence.

Right to withdraw consent to share personal information (Opt- Out)

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you do not want your information to be used for

any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.

There are two main types of opt-out.

Type 1 Opt-Out

If you do not want information that identifies you to be shared outside the practice, for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’. This prevents your personal confidential information from being used other than in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease.

Type 2 Opt-Out

NHS Digital collects information from a range of places where people receive care, such as hospitals and community services. If you do not want your personal confidential information to be shared outside of NHS Digital, for purposes other than for your direct care, you can register a ‘Type 2 Opt-Out’. For further information about Type 2 Opt-Outs, please contact NHS Digital Contact Centre at enquiries@hscic.gov.uk referencing ‘Type 2 Opt-Outs – Data Requests’ in the subject line; or call NHS Digital on (0300) 303 5678; or visit the website http://content.digital.nhs.uk/article/7092/Information-on-type-2-opt-outs

If you wish to discuss or change your opt-out preferences at any time please contact: info@earcarelab.co.uk

 

NHS Digital is developing a new system to give you more control over how your identifiable information is used. Details on the national data opt-out may be found at https://digital.nhs.uk/services/national-data-opt-out-programme

Access to your information

Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.

If you wish to have a copy of the information we hold about you, please contact: info@earcarelab.co.uk

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.

Mobile telephone number

If you provide us with your mobile phone number we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.

Notification

The Data Protection Act 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Complaints

If you have concerns or are unhappy about any of our services, please contact the Practice Manager [Insert Name and contact details]

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

 

Further Information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found here:

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under the Data Protection Act 2018.

http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf

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 programmes 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

NHS Digital

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

http://content.digital.nhs.uk/article/4963/What-we-collect

Reviews of and Changes to our Privacy Notice

We will keep our Privacy Notice under regular review. This notice was last reviewed in Jan 2019.

 

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