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Privacy Policy

What is a Privacy Notice?

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

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

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  • 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 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 Organisation has to be clear and open with people about how their information is used.

 

Providing a ‘Privacy Notice’ is a way of stating the Organisation’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.

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  • 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?

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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 Commissioner’s Office has published guidance on carrying out a PIA, which can be found here. https://ico.org.uk/media/for-organisations/documents/1595/pia-code-of-organisation.pdf

Data Controllers

Under the Data Protection Act, the data controller is the person or organisation 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 organisation 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 Organisations’ compliance with the DPA.

Risk Stratification

This is an acceptable way of assessing patients’ needs and preventing 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 Organisation, and this needs to be made clear to them.

Partner Organisations

Partner organisations will usually include NHS organisations (GP surgeries, hospitals, CCGs, NHS England, etc.), other public sectors (Education, Police, Fire, etc.), and any other Data Processors that may be carrying out specific project work with the Organisation (e.g., Diabetes UK).

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 organisation registration number by entering your Organisation name in the ‘Name’ box here: https://ico.org.uk/ESDWebPages/Search

How we use your information

This privacy notice explains why we, as an Organisation collect information about our patients and how we

use that information.

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NEURODEV manages patient information in accordance with existing laws and with guidance from organisations that govern the provision of healthcare in England, such as the Department of Health and the General Medical Council.

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

with:

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  • GDPR

  • Data Protection Act 2018

  • Human Rights Act 1998

  • Common Law Duty of Confidentiality

  • Health and Social Care Act 2012

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As data controllers, clinicians have fair processing responsibilities under the GDPR & Data Protection Act

2018. In an organisation, this means ensuring that your personal confidential data (PCD) is handled clearly and transparently, and in a reasonably expected way.

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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 they have an opportunity to object and know how to do so.

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The Clinicians who provide telehealth medicine clinical service maintain records about your health and any medication that you have received. These records help to provide you with the best possible healthcare.

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

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  • Details about you, such as address and next of kin

  • Any contact the organisation has had with you

  • Notes and reports about your health

  • Details about the telehealth medicine consultations

 

The organisation 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:

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a) It is required by law

b) You provide consent – either implicitly or for the sake of their own care, or explicitly for other purposes

c) It is justified to be in the public interest

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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.

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

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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.

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Patients can choose to withdraw their consent to their data being used in this way. When the organisation is about to participate in any new data-sharing scheme, we will make patients aware by displaying prominent notices in the organisation 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 they can receive, then the clinician will explain this to you at the time.

Organisation Website

Our Website does 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 conditions at risk of sudden worsening.

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A risk score is derived through an analysis of your de-identified information using the software as the data processor

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Risk stratification enables best practices for our telehealth medicine consultation service. Your clinician will be able to focus on preventing ill health and not just the treatment of sickness during their remote clinical consultation. If necessary, your clinician may be able to offer you additional services or refer you to secondary care for further investigation.

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

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

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

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 the GDPR & Data Protection Act 2018 (which is overseen by the Information Commissioner’s Office), Human Rights Act, and the Common Law Duty of Confidentiality.

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All of our clinicians receive appropriate and regular training to ensure they are aware of their personal responsibilities and have legal and contractual obligations to uphold confidentiality, enforceable through disciplinary procedures. Only a limited number of authorised staff have access to personal information where it is appropriate to their role and is strictly on a need-to-know basis.

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We maintain our duty of confidentiality to you at all times. 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), or where the law requires information to be passed on.

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:

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  • GP Practices

  • NHS Trusts

  • Specialist Trusts

  • 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’

Access to personal information

You have a right under the GDPR & Data Protection Act 2018 to access/view information the organisation holds about you, and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject access’. If we do hold information about you we will:

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  • give you a description of it

  • tell you why we are holding it

  • tell you who it could be disclosed to

  • let you have a copy of the information in an intelligible form

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If you would like to make a ‘subject access request’, please contact the organisation manager in writing.

There may be a charge for this service. Any changes to this notice will be published on our website and on the organisation notice board.

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The organisation is registered as a data controller under the GDPR  Data Protection Act 2018.

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Change of Details

It is important that you inform the clinician responsible for the online consultation if any of your details, such as your name or address, have changed or if any of your details, such as your date of birth, are incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date.

Notification

The GDPR &  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. This information is publicly available on the Information Commissioner's Office website www.ico.org.uk. The organisation is registered with the Information Commissioner's Office (ICO).

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential, is ANTOINETTE PHANG. Any changes to this notice will be published on our website and displayed in prominent notices in the organisation.

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The Organisation is registered as a data controller under the GDPR & Data Protection Act 2018.

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