Fair Processing Notice
This page explains our fair processing notice and how we will use and protect any information about you that you give us when you are referred to us as a patient.
Your consent to use your personal information
Ravenscroft Healthcare Ltd (or the referrer) is required to obtain your consent to use your personal data. This consent must be a ‘positive opt-in’ and in all circumstances before we proceed we need your permission to access your data.
We will record your consent to use your personal information in your patient record in our Patient Administration System.
At any time you can inform us that you no longer wish us to use your personal information. Whilst it is not a precondition of receiving your NHS service, the Ravenscroft clinicians and other staff have a duty to care for you safely. If they cannot ensure your care safety with the withdrawal of your information which they need, they may well discharge you from the Service and ask you to return to your GP.
This course of action is of course a last resort and Ravenscroft will endeavour in all circumstances to continue your care.
How we use your personal information
This fair processing notice explains why Ravenscroft collects information about you and how that information may be used.
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. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.
The health records 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. These records are a Special Category under the law and as such our responsiveness to handle and process your personal data are even more sensitive. Records which Ravenscroft hold about you may include the following information:
- Details about you, such as your address and emergency contact details
- Any contact the service has had with you, such as appointments and clinic visits
- Notes and reports about your health
- Details about your treatment and care
- Results of investigations such as laboratory tests and x-rays
- Relevant information from other health professionals, relatives or those who care for you
To ensure you receive the best possible care, your records are used to inform the care you receive. Information held about you may be used to help protect the health of the public. Information may be used within the service for clinical audit to monitor the quality of the service provided.
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.
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:
- General Data Protection Regulation (GDPR) 2018
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality and Information Security
- Information: To Share or Not to Share Review
Accessing your records
Every member of staff who works for a healthcare organisation has a legal obligation to keep information about you confidential. Individual staff may only view your records with a legitimate reason for a legitimate purpose. This would of course include the clinician(s) directly involved in your care or other staff who might be ordering or receiving diagnostic results linked to your care.
Other administration or management staff may need to access and use your records to contact you regarding appointments or your care. Our Patient Administration System where your records are stored creates a record of who has accessed your record for control and audit purposes.
Accessing or allowing someone else to access, your record without a legitimate purpose by a Ravenscroft member of staff is a serious data breach and is dealt with under our disciplinary procedures.
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 3rd party without your explicit 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 new 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. They should be supported by the policies of their employers, regulators and professional bodies.
Verifying your identity
We are required to verify your identity each time you contact us. You will be asked to provide identity information (for example full name, address, date of birth and NHS number) so your records can be located.
If you wish a spouse, relative or carer to communicate with us on your behalf we will need to obtain your explicit consent before doing so.
Where we use your personal data
Your personal data is stored securely within the United Kingdom in databases accessed with multiple levels of security. This ensures that only authorised Ravenscroft staff access your record.
The databases are held on IT systems using highly regulated and mandated NHS equipment, software and security.
Our Patient Administration Systems are not accessible outside of the United Kingdom. We do not send your data outside the United Kingdom.
Your right to have your records changed
You have a right to have inaccurate personal data rectified or completed if it is incomplete. Clinical notes and clinical opinions will not generally be altered but may of course be supplemented by additional personal data.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements and your consent on how it will be used, with the following organisations:
- NHS Trusts / Foundation Trusts
- GPs
- NHS Commissioning Support Units
- Private Sector Providers
- Voluntary Sector Providers
- Clinical Commissioning Groups
- Social Care Services
- NHS Digital
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Voluntary Sector Providers
You will be informed who your data will be shared with and you will be asked for explicit consent for this when this is required. In all circumstances we will transit your personal data securely.
How we will communicate with you
In order to communicate with you, we are likely to do this by telephone, SMS, email, and/or post. If we contact you using the telephone number(s) which you have provided (landline and/or mobile), and you are not available which results in the call being directed to a voicemail and/or answering service, we may leave a voice message on your voicemail and/or answering service as appropriate.
Any message left will be discrete and will not contain confidential information. In almost all circumstances the message will simply ask you to contact us.
In your initial patient registration with us we will seek your consent to contact you and via which route. If your preference for how we communicate with us changes please contact us so that we may amend your preferences.
Right of access to your personal information
You have a right under the General Data Protection Regulation (GDPR) 2018 to request access to obtain copies of what information the service holds about you and to have it amended should it be inaccurate. Your data is provided without cost to you. In order to request this, you need to do the following:
- Your request can be made to the Service in person in the clinic, on the telephone or in writing (letter or e-mail). We are required to respond to you within 30 days
Retaining your personal information
Unlike many other types of personal information, under GDPR there is no ‘Right to Erasure’ of records. Indeed the Health Act requires us to retain your records for a minimum of 7 years after we have finished your care (discharge). Where your care record is part of your GP record retention is for a minimum of 20 years or 8 years post death. We are of course still bound by the strict rules of GDPR on how we store, access and release your patient information.
Marketing and other promotional contact
Ravenscroft is commissioned to provide your NHS service. We will never contact you to promote either other Ravenscroft services or those of a third party. If someone purporting to represent Ravenscroft contacts you please report it immediately to our Data Protection Officer who will deal with the matter.
Objections and Complaints
Should you have any concerns about how your information is managed, please contact the Service Manager or our Data Protection Officer. If you are still unhappy following interaction with Ravenscroft, you can then complain to the Information Commissioners Office (ICO) via their website (www.ico.gov.uk).
Data Protection Officer
You are able to contact our Data Protection Officer by e-mail on therapy@ravenscroftphysio.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 such as date of birth is 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 for you.
The General Data Protection Regulation 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information. Ravenscroft is registered with the Information Commissioners Office (ICO).
This information is publicly available on the Information Commissioners Office website www.ico.org.uk.
What you need to do now
If you are happy for your data to be extracted and used for the purposes described in this fair processing notice then you do not need to do anything.
If you do not want your personal data being extracted and leaving the service for any of the purposes described, you need to let us know as soon as possible.
We will then ensure your records are prevented from leaving the service and / or leaving the central information system at the Health and Social Care Information Centre (HSCIC) for use by secondary providers.