We have allocated a Named Accountable GP for all of our registered patients. If you do not know who your named GP is, please ask a member of our reception team. Unfortunately, we are unable to notify patients in writing of any change of GP due to the costs involved.

We aim to keep our surgery clean and tidy and offer a safe environment to our patients and staff. We are proud of our modern, purpose built Practice and endeavour to keep it clean and well maintained at all times.

If you have any concerns about cleanliness or infection control, please report these to our Reception staff.

Our GPs and nursing staff follow our Infection Control Policy to ensure the care we deliver and the equipment we use is safe.

We take additional measures to ensure we maintain the highest standards:

• Encourage staff and patients to raise any issues or report any incidents relating to cleanliness and infection control.  We can discuss these and identify improvements we can make to avoid any future problems.
• Carry out an annual infection control audit to make sure our infection control procedures are working.
• Provide annual staff updates and training on cleanliness and infection control
• Review our policies and procedures to make sure they are adequate and meet national guidance.
• Maintain the premises and equipment to a high standard within the available financial resources and ensure that all reasonable steps are taken to reduce or remove all infection risk.
• Use washable or disposable materials for items such as couch rolls, modesty curtains, floor coverings, towels etc., and ensure that these are laundered, cleaned or changed frequently to minimise risk of infection.
• Make Alcohol Hand Rub Gel available throughout the building

OLDFIELD FAMILY PRACTICE

PRACTICE FAIR PROCESSING & PRIVACY NOTICE – DATE: 21.05.2018

 Your Information, Your Rights

 Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR).

The following notice reminds you of your rights in respect of the above legislation and how your GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.

This notice reflects how we use information for:

• The management of patient records;
• Communication concerning your clinical, social and supported care;
• Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
• Participation in health and social care research; and
• The management and clinical planning of services to ensure that appropriate care is in place for our patients today and in the future.

 Data Controller

As your registered GP practice, we are the data controller for any personal data that we hold about you.

 What information do we collect and use?

All personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to the your care.

We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:

• ‘Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data.  This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS number

 And

‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.

Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services).  These records may be electronic, a paper record or a mixture of both.  We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.

 Why do we collect this information?

 The NHS  Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training.  To do this we will need to process your information in accordance with current data protection legislation to:

• Protect your vital interests;
• Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
• Perform tasks in the public’s interest;
• Deliver preventative medicine, medical diagnosis, medical research; and
• Manage the health and social care system and services.

 How is the information collected?

 Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection.  In addition physical information will be sent to your practice.  This information will be retained within your GP’s electronic patient record or within your physical medical records.

 Who will we share your information with?

 In order to deliver and coordinate your health and social care, we may share information with the following organisations:

• Local GP Practices in order to deliver extended primary care services
• NHS [All local Hospitals/Health boards and CCG]
• 111 and Out of Hours Service
• Local Social Services and Community Care services
• Voluntary Support Organisations commissioned to provide services by [Ealing CCG/Health Boards]

Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.

Your information will not be transferred outside of the European Union.

Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.

[In addition we received data from NHS Digital (as directed by the Department of Health) such as the uptake of flu vaccinations and disease prevalence in order to assist us to improve “out of hospital care”]

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information that has been collected lawfully.  Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.  We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.

Information is not held for longer than is necessary.   We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.

Consent and Objections

Do I need to give my consent?

The GDPR sets a high standard for consent.  Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation.  However consent is only one potential lawful basis for processing information.  Therefore your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice.  Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice.  Your consent will be documented within your electronic patient record.

  What will happen if I withhold my consent or raise an objection?

You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing.  Please contact your GP Practice for further information and to raise your objection.

Health Risk Screening / Risk Stratification

Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health.  By using selected information such as age, gender, [NHS number], diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.

To summarise Risk Stratification is used in the NHS to:

• Help decide if a patient is at a greater risk of suffering from a particular condition;
• Prevent an emergency admission;
• Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
• Review and amend provision of current health and social care services.

[Your GP will use computer based algorithms or calculations to identify their registered patients who are at most risk, with support from the local Commissioning Support Unit and/or a third party accredited Risk Stratification provider.  The risk stratification contracts are arranged by [your local CCG/Health Board] in Accordance with the current Section 251 Agreement. Neither the CSU nor your local CCG will at any time have access to your personal or confidential data.  They will only act on behalf of your GP to organise the risk stratification service with appropriate contractual technical and security measures in place]

Your GP will routinely conduct the risk stratification process outside of your GP appointment.  This process is conducted electronically and without human intervention.  The resulting report is then reviewed by a multidisciplinary team of staff within the Practice.  This may result in contact being made with you if alterations to the provision of your care are identified.

[A Section 251 Agreement is where the Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers]

As mentioned above, you have the right to object to your information being used in this way.  However you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care.  Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.

Sharing of Electronic Patient Records within the NHS

Electronic patient records are kept in most places where you receive healthcare.  Our local electronic systems (such as SystmOne) enable your record to be shared with organisations involved in your direct care, such as:

• GP practices
• Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
• Child health services that undertake routine treatment or health screening
• Urgent care organisations, minor injury units or out of hours services
• Community hospitals
• Palliative care hospitals
• Care Homes
• Mental Health Trusts
• Hospitals
• Social Care organisations
• Pharmacies

In addition, [NHS England] have implemented the [Summary Care Record/ Emergency Care Summary/ Individual Health Record] which contains information including medication you are taking and any bad reactions to medication that you have had in the past.

In most cases, particularly for patients with complex conditions and care arrangements, the shared electronic health record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health.  Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so.  The shared record means patients do not have to repeat their medical history at every care setting.

Your record will be automatically setup to be shared with the organisations listed above; however you have the right to ask your GP to disable this function or restrict access to specific elements of your record.  This will mean that the information recorded by your GP will not be visible at any other care setting.

You can also reinstate your consent at any time by giving your permission to override your previous dissent.

 Invoice Validation

[If you have received treatment within the NHS, the local Commissioning Support Unit (CSU) may require access to your personal information to determine which Clinical Commissioning Group is responsible for payment for the treatment or procedures you have received.  Information such as your name, address, date of treatment and associated treatment code may be passed onto the CSU to enable them to process the bill.  These details are held in a secure environment and kept confidential.  This information is only used to validate invoices in accordance with the current Section 251 Agreement, and will not be shared for any further commissioning purposes]

Your Right of Access to Your Records

The Data Protection Act and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format.  This is known as the “right of subject access”.  If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information.  This can be your GP, or a provider that is or has delivered your treatment and care.  You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party.  If you would like access to your GP record please submit your request in writing to:

Oldfield Family Practice 285 Greenford Road Greenford Middlesex UB6 8RA

 Complaints

In the event that you feel your GP Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager at:

Oldfield Family Practice 285 Greenford Road Greenford Middlesex UB6 8RA

 If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wimslow, Cheshire SK9 5AF Enquiry Line: 01625 545700 or online at www.ico.gov.uk

GP2GP – The Electronic Transfer of Patient Records

By the end of March 2015 your GP practice will able to send computer held patient records electronically to a patient’s new surgery so they arrive much quicker than the paper notes, helping the doctors and nurses know the best way to treat you. This is called the GP2GP electronic transfer of patient records. The paper notes will continue to be sent via an NHS delivery service.

With GP2GP, your medical record is available to your new doctor within a few minutes of registration, enabling much safer care.

For more information about GP2GP visit the HSCIC website.

All GP Practices are required to declare mean earnings (i.e. average pay) for GPs working to deliver NHS services to patients at each practice.

The average pay for GPs working in the practice of Oldfield Family Practice in the last financial year was £50,235 before tax and National Insurance.

This is for 1 full time GP, 1 part time GP and 1 salaried GP who worked in the practice for more than six months.

The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:

• Have a publication scheme in place
• Allow public access to information held by public authorities.

The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.

Public authorities include government departments, local authorities, the NHS, state schools and police forces.

The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.

The Surgery publication scheme

A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:

• who we are and what we do
• what we spend and how we spend it
• what our priorities are and how we are doing it
• how we make decisions
• our policies and procedures
• lists and registers
• the services we offer

You can request our publication scheme leaflet at the surgery.

Who can request information?

Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use. 

How should requests be made?

Requests must:

• be made in writing (this can be electronically e.g. email/fax)
• state the name of the applicant and an address for correspondence
• describe the information requested.

What cannot be requested?

Personal data about staff and patients covered under Data Protection Act.

For more information see these websites:

• Legislation GOV.UK
• Information Commissioners Office

We aim to provide you with the best possible medical service. At times you may feel that we have not achieved this and want to make your feelings known.  Most problems can be sorted out quickly and easily, often at the time they arise with the person concerned and this may be the approach you try first.

Where you are not able to resolve your complaint in this way and wish to make a formal complaint you should do so, preferably within writing, as soon as possible after the event and ideally within a few days as this helps us to establish what happened more easily.

The period for making a complaint is normally:

• 12 months from the date on which the event which is the subject of the complaint occurred or
• 12 months from the date on which the event which is the subject of the complaint comes to the complainant’s notice.

If you are a registered patient you can complain about your own care.  You are unable to complain about someone else’s treatment without their written authority.  We are able to provide you with a separate complaints form to register your complaint and this includes a third-party authority form to enable a complaint to be made by someone else.  Please ask at reception for this.  You can provide this in your own format if you wish.

Please leave feedback online or send your written complaint to:

• Practice Management, Oldfield Family Practice, 285 Greenford Road, Greenford, Middlesex, UB6 8RA

Complaining on Behalf of Someone Else

We keep to the strict rules of medical and personal confidentiality.  If you wish to make a complaint but are not the patient involved, we will require the written consent of the patient to confirm that they are unhappy with their treatment and that we can deal with someone else about it.  Please ask at reception for the complaints form which includes a statement of authority that the patient can sign.  Where the patient is incapable of providing consent due to illness or accident it may still be possible to deal with the complaint.  Please provide the precise details of the circumstances which prevent this in your covering letter. Please note that we are unable to discuss any issue relating to someone else without their express permission, which must be in writing, unless the above circumstances apply.

Confidentiality 

All complaints must be treated in the strictest confidence.

Where the investigation of the complaint requires consideration of the patient’s medical records, the Practice Manager must inform the patient or person acting on his or her behalf if the investigation will involve disclosure of information contained in those records to a person other than the practice or an employee of the practice.

The practice must keep a record of all complaints and copies of all correspondence relating to complaints but such records must be kept separate from patients’ medical records.

The practice has an annual review of complaints received within the year and the learning issues or changes to procedures which have arisen are documented.

The Fair Processing Notice is intended to inform you about the type of patient information that GP Practices hold, how that information might be used, with whom we may share that information, and how we ensure it is kept secure.

Fair Processing Notice

• Fair Processing Notice – OFP March 2020
• Fair Processing Notice – Whole Systems Integrated Care 

Further Information

• Whole Systems dashboard program – healthiernorthwestlondon.nhs.uk
• Your Personal information Choices – content.digital.nhs.uk/yourinfo
• How information is used – content.digital.nhs.uk/article
• Review of health and care data security and consent – www.gov.uk
• Records management code of practice for health and social care – www.gov.uk
• Fair Processing NHS England – www.england.nhs.uk
• The information Governance Review – www.gov.uk
• NHS Choices – Your health and care records – www.nhs.uk

If you have any special needs please let our staff know so that we can help and ensure you get the same support in the future.

Wheelchair access

Wheelchair access is available at the front and back of the surgery and we have toilets for the disabled.

Disabled Parking – Blue Badge Scheme

The Blue Badge scheme is for people with severe mobility problems. It allows Blue Badge holders to park close to where they need to go. There is a disabled parking space at the side of the practice on Croyde Avenue.

Blind/Partially Sighted

If you or family members are blind or partially sighted we can give you a CD or large print of our practice leaflet upon request. Please ask Reception for further information.

For more advice and support for blind people please see the following websites:

• Royal National Institute of Blind People (RIND)
• British Wireless for the Blind Fund
• British Blind Sport

Guide Dogs

Guide dogs are welcome at the surgery but we ask that you be aware of other patients and staff who may have an allergy or fear of dogs.

Further Information:

• Guide Dogs

Other Disability Websites

• BID Services
• Disability Go
• Disabled People, your Rights, Benefits, Carers and the Equality Act
• Disability Rights UK
• Living with a Disability NHS Choices
• Disability Action
• Mencap

Child Safeguarding is the responsibility of all everybody and is highly regarded at the Surgery. We make every effort to recognise issues and address as they occur in the practice. By raising safeguarding children issues within the practice all staff will be aware of how they may access advice, understand their role in protection, and understand the importance of effective Inter-agency communication.

It is very important that all Practice staff understand the need for early identification, assessment and intervention when they have concerns about a child.  Case discussion and reflective practice is encouraged.  Child protection issues in general practice require a robust system of note-keeping and recording, message handling and communication of any concerns.

Key Factors to be aware of in safeguarding children

• The welfare of the child is paramount
• Be prepared to consult with colleagues
• Be prepared to take advice from local experts
• Keep comprehensive, clear, contemporaneous records
• Be aware of GMC guidance about sharing confidential information

Risk Factors and Identification – Child Sexual Exploitation

A child in need is defined as a child whose vulnerability is such that they are unlikely to reach or maintain a satisfactory level of health or development without the provision of services (section 17, Children’s Act 1989). This includes disabled children. The Children’s Acts 1984 and 2004 define a child as someone who has not reached their 18th birthday. The fact that a child has reached their 16th birthday and may be living independently, working, or be members of the armed forces does not remove their childhood status under the Acts.

Local authority social services departments working with other local authority departments and health services have a duty to safeguard and promote the welfare of children in their area who are in need. If you are considering making a referral to Social Services as a child in need, it is essential to discuss the referral with the child’s parents or carers and to obtain consent for the sharing of information. Social Services will then follow local procedures to undertake an assessment of the child and their family.

Child Protection Plan

Children judged to be at continuing risk have a child protection plan in place, this list is maintained by children’s social care (CSC).CSC, police and health professionals have 24 hour access to this. A child on the register has a “key worker” to whom reference can be made.

Recognising Child Abuse

(for full details please ref to Working Together to Safeguard Children 2013)

There are 4 main categories of child abuse:

• Physical abuse
• Sexual abuse
• Emotional abuse
• Neglect/failure to thrive

These are not however exclusive, and a number of abuse types can often coexist.

Physical abuse may include:

Injuries in children under 1 years of age or non-mobile children should be treated with a high degree of care

• Hitting, shaking, throwing, poisoning, burning or scalding, or other forms of physical harm

• Where a parent or carer deliberately causes ill-health of a child

• Single traumatic events or repeated incidents
• FGM

Sexual abuse may include:

• Forcing or enticing a child under 18 to take part in sexual activities where the child is unaware of what is happening
• May include both physical contact acts and non—contact acts

Emotional abuse may include:

• Persistent ill-treatment which has an effect on emotional development

• Conveyance of a message of being un-loved, worthlessness or inadequacy

• May instill a feeling of danger, being afraid

• May involve child exploitation or corruption
• Living in families where domestic violence is taking place

Neglect may include:

• Failure to meet the child’s physical or psychological needs

• Failure to provide adequate food or shelter

• Failure to protect from physical harm
• Neglect of a child’s emotional needs

Common presentations and situations in which child abuse may be suspected include:

• Disclosure by a child or young person

• Physical signs and symptoms giving rise to suspicion of any category of abuse

• The history is inconsistent or changes

• A delay in seeking medical help

• Extreme or worrying behaviour of a child, taking account of the developmental age of the child

• Accumulation of minor incidents giving rise to a level of concern, including frequent A&E attendances

Some other situations which need careful consideration are:

• Disclosure by an adult of abusive activities

• Girls under 16 presenting with pregnancy or sexually transmitted disease, especially those with learning difficulties

• Very young girls requesting contraception, especially emergency contraception

• Situations where parental mental health problems may impact on children

• Parental/ carer alcohol, drug or substance misuse which may impact on children

• Parents with learning difficulties

• Violence or domestic abuse in the family (please see separate document in safeguarding folder on domestic violence)
• Acuminous separation of parents with alleged allegation