Privacy Notice

Your information, what you need to know

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

We collect and hold data for the purpose of 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 will collect information about you which helps us respond to your queries or secure specialist services. Your information is held in digital form and is supported by written records as appropriate.

Our commitment to data privacy and confidentiality issues

As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation.  This includes the General Data Protection Regulation (EU) 2016/679 (GDPR) now known as the UK GDPR, the Data Protection Act (DPA) 2018, the Data (Use and Access) (DUA) Act 2025, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time.  The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations. 

Data we collect about you

Records which this GP Practice will hold or share about you will include the following:

Personal data

Means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

Special categories of personal data

This term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data,biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.  

Confidential patient information

This term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence.  Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.

Pseudonymised

The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.

Anonymised

Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place

Aggregated

Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

How we use your information 

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of 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 or without your permission when the practice is closed.  Where your record is accessed without your permission it is necessary for them to have a legitimate basis in law. This is explained further in the Local Information Sharing at Appendix A.

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service.  Collecting this information helps to ensure you get the best possible care and treatment.  

The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• improving the quality and standards of care provided 
• research into the development of new treatments
• preventing illness and diseases
• monitoring safety
• planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

Most often, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

Safeguarding of children or vulnerable adults

If we have significant concerns or hear about an individual child or vulnerable adult being at risk of harm, we may share relevant information with other organisations, such as local authorities and the Police, involved in ensuring their safety.

Statutory disclosures

Sometimes we are duty bound by laws to disclose information to organisations such as the Care Quality Commission, the Driver and Vehicle Licencing Agency, the General Medical Council, His Majesty’s Revenue and Customs and Counter Fraud services.  In these circumstances we will always try to inform you before we are required to disclose, and we only disclose the minimum information that the law requires us to do so

This may only take place when there is a clear legal basis to use this information.  All these uses help to provide better health and care for you, your family and future generations.  Confidential patient information about your health and care is only used like this where allowed by law or with consent. 

Pseudonymised or anonymised data is generally used for research and planning so that you cannot be identified.

A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from Records Management Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is.  Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for 2021.

Individuals rights under UK GDPR 

Under UK GDPR 2016 the Law provides the following rights for individuals.  The NHS upholds these rights in a number of ways:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure (not an absolute right) only applies in certain circumstances
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

Your right to opt out of data sharing and processing

The NHS Constitution states, ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’. 

Type 1 opt out

This is an objection that prevents an individual's personal confidential information from being shared outside of their general practice except when it is being used for the purposes of their individual direct care, or in particular circumstances required by law, such as a public health screening, or an emergency like an outbreak of a pandemic disease. If patients wish to apply a Type 1 Opt Out to their record, they should make their wishes known to the Practice Manager.

National data opt-out (NDOO)

The mandatory implementation of the National Data Opt-Out (NDOO) was 31 July 2022, enabling patients to opt-out from the use of their data for research or planning purposes.

For more information go to National data opt out programme 

To find out more or to register your choice to opt out, please visit the NHS website. On this web page you will:

• See what is meant by confidential patient information
• Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
• Find out more about the benefits of sharing data
• Understand more about who uses the dat
• Find out how your data is protected
• Be able to access the system to view, set or change your opt-out setting
• Find the contact telephone number if you want to know any more or to set/change your opt-out by phone 
• See the situations where the opt-out will not apply

You can also find out more about how patient information is used at:

• NHS Health Research Authority (which covers health and care research); and
• Understanding Patient Data (which covers how and why patient information is used, the safeguards and how decisions are made).

You can change your mind about your choice at any time.

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.

Right of access to your information (subject access request)

Under Data Protection Legislation everybody has the right of access to, or request a copy of, information we hold that can identify them, this includes medical records.  The patient is only entitled to confirmation, personal data and other information that the provider is able to provide based on a reasonable and proportionate search for the information. There are some safeguards regarding what patients will have access to and they may find information has been redacted or removed for the following reasons;

• It may be deemed to risk causing harm to the patient or others
• The information within the record may relate to third parties who are entitled to their confidentiality, or who have not given their permission for the information to be shared.

Patients do not need to give a reason to see their data. And requests can be made verbally or in writing.  Although we may ask them to complete a form in order that we can ensure that they have the correct information required.

Where multiple copies of the same information is requested, the surgery may charge a reasonable fee for the additional copies. 

Patients will need to provide proof of identity to receive this information. We will not share information relating to you with other individuals without your explicit instruction or without sight of a legal document.

Patients may also request to have online access to their data; they may do this via the NHS app and your NHS account  or via the practice’s system. If you would like to access your GP record online, visit our policy page. Further information about the service can be found at the privacy notices for the NHS app managed by NHS England.

Change of details

It is important that you tell the surgery if any of your contact details such as your name or address have changed, or if any of your other contacts details are incorrect including third party emergency contact details.  It is important that we are made aware of any changes immediately in order that no information is shared in error. 

Mobile telephone number

If you provide us with your mobile phone number, we will use this to send you text reminders about your appointments or other health related information.  It is within our legal duty as a public authority to keep our patients updated with important information. 

We also use the NHS Account Messaging Service provided by NHS England to send you messages relating to your health and care. You need to be an NHS App user to receive these messages. Further information about the service can be found at the privacy notice for the NHS app managed by NHS England.

Research opportunities

We may contact you by text message to invite you to take part in health and care research activities on behalf of the research organisation. The message will include details of how to sign up if you are interested.  Your details will not be shared with the research organisation.

If you do not wish to receive these types of messages, you can opt out by replying to the text message with the words ‘opt out’  

Email address

Where you have provided us with your email address, we will use this to send you information relating to your health and the services we provide.  If you do not wish to receive communications by email, please let us know.  

Notification

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

We are registered as a Data Controller and our registration can be viewed online in the public register via the ICO 

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

Data protection officer

Should you have any data protection questions or concerns, please contact our Data Protection Officer via the surgery

What is the right to know?

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector.  You can request any non-personal information that the GP Practice holds, that does not fall under an exemption.  You may not ask for information that is covered by the Data Protection Legislation under FOIA.  However, you can request this under a right of access request – see section above ‘Access to your information’.  

Right to complain

If you have concerns or are unhappy about any of our services, please contact the Practice Manager. Or via the Information Commissioner’s Office (ICO) details listed below.

For independent advice about data protection, privacy, and data-sharing issues, you can contact: 

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF 

• Phone: 0303 123 1113   
• Visit the ICO website

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 programs available to you, confidentiality, information, and your right to complain if things go wrong.

In our use of health and care information, we satisfy the common law duty of confidentiality because:

• you have provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses)
• we have support from the Secretary of State for Health and Care following an application to the Confidentiality Advisory Group (CAG) who are satisfied that it isn’t possible or practical to seek consent
• we have a legal requirement to collect, share and use the data
• for specific individual cases, we have assessed that the public interest to share the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime). This will always be considered on a case-by-case basis, with careful assessment of whether it is appropriate to share the particular information, balanced against the public interest in maintaining a confidential health service.

Document control

This document was created by NHS South Central and West Commissioning Support Unit (SCW) and as such the Intellectual Property Rights of this document belong to SCW.

Privacy Notice Primary Care template 3.6. Published by NHS SCW Information Governance Services

Document objectives

This document supports Practice staff in compliance with Data Protection legislation, achieving best practice in the area of Information Governance and in meeting the requirements of the Data Security and Protection Toolkit

Target audience

All staff

Monitoring arrangements and indicators

This document will be monitored by NHS SCW Information Governance Services to ensure any legislative changes that occur before the review date are incorporated. 

Review frequency

SCW reviews customer documents in line with our planned schedule 

SCW Planned Review date

1 October 2024

Approved and ratified by practice

Holbrook Surgery. Date 9 June 2026

Date issued by practice

9 June 2026

GP Review date

9 June 2029

Change record

• 21 July 2020 Review for Website publication
• 25 August 2021 Review for Website publication, minor changes made to links and addition of covid and online access. 
• 24 December 2021 NHS Care Record guarantee link and Document control page updated
• 31 May 2022 Reviewed 
• 28 September 2022 NHS Care Record Guarantee & NHS Constitution removed as per NHSE guidance
• 30 November 2022 NHS Constitution - new link provided by NHSE
• 23 August 2023 Addition of NHS Account Messaging service
• 29 September 2023 Final review
• 27 October 2023 Reviewed and updated link for NHS app Privacy notices
• 22 May 2025 Removal of detail to Covid Passport.
• 17 December 2025 Inclusion of DUA Act and updated links as needed

Appendix A – The practice will share patient information with these organisations where there is a legal basis to do so

Commissioning and contractual purposes planning, quality and performance

Purpose

Anonymous data is used by the Integrated Care Board (ICB) for planning, performance and commissioning purposes, as directed in the practices contract, to provide services as a public authority.

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Patients may opt out of having their personal confidential data used for Planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to the NHS website to apply a National Data Opt Out

Processor

West Sussex ICB

Summary care record including additional information

Purpose

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.

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Patients have the right to opt out of having their information shared with the SCR by completion of a form and returned to the practice. 

Please note that by opting out of having your information shared with the Summary Care Record could result in a delay to care that may be required in an emergency. 

Processor

NHS England

Research

Purpose

We may share anonymous patient information with research companies for the purpose of exploring new ways of providing healthcare and treatment for patients with certain conditions. This data will not be used for any other purpose. 

Where personal confidential data is shared your consent will be required.

Where you have opted out of having your identifiable information shared for this Planning or Research your information will not be shared.

Legal basis

• Articles 6(1)(a) and 9(1)(h) – explicit consent; or 
• Article 6(1)(c) (where we are legally obligated to share your personal data) for your standard personal data and Article 9(2)(j) (scientific research) for your health data.

Where identifiable data is required for research, patient consent will be needed, unless there is a legitimate reason under law to do so or there is support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales.

Sharing of aggregated non identifiable data is permitted.

Processor

Clinical Practice Research Datalink

Individual funding requests

Purpose

We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our standard NHS contract.

The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time but this may affect the decision to provide individual funding. 

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Data processor

Blueteq

Safeguarding adults

Purpose

We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of individuals.

Consent is not required to share information for this purpose.

Legal basis

Direct Care under UK GDPR:

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine 

Data processor

NHS Sussex ICB

Safeguarding children

Purpose

We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children.

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Consent may not be required to share this information.

Data processor

NHS Sussex ICB

Risk stratification – preventative care

Purpose

‘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. 

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.

Type of data

• Identifiable
• Pseudonymised
• Anonymised
• Aggregate Data

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processors

Apollo Medical

Public health, screening programmes (identifiable), notifiable disease information (identifiable), smoking cessation (anonymous), sexual health (anonymous), vaccination programmes

Purpose

Personal identifiable and anonymous data is shared.

The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service to name a few. The law allows us to share your contact information, and certain aspects of information relating to the screening with Public Health England so that you can be appropriately invited to the relevant screening programme.

More information can be found on the UK government website or speak to the practice.

Patients may not opt out of having their personal information shared for Public Health reasons.

Patients may opt out of being screened at the time of receiving an invitation.

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Data processors

Surry and Sussex

Direct care, NHS trusts, community providers, pharmacies, enhanced care providers, nursing homes, other care providers

Purpose

Personal information is shared with other secondary care trusts and providers in order to provide you with individual direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service. 

Legal basis

The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following:

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine 

Processors

• Surrey and Sussex Health Care Trust (SASH)
• Brighton and Sussex University Hospitals (BSUH)
• Sussex Partnership (Mental Health)
• Sussex Community NHS Trust

Care quality commission

Purpose

The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.

More detail on how they ensure compliance with data protection law (including UK GDPR) and their privacy statement is available on their website.

Legal basis 

• Article 6(1)(c) ‘…processing is necessary for compliance with a legal obligation’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine 

Processor

Care Quality Commission

Population health management

Purpose

Population health management aims to shift the focus from reactive care to proactive, preventative care. It is a critical function of our new integrated care systems and the foundation to building a healthier future together.

Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data in order to:

• Understand the health and care needs of the care system’s population, including health inequalities
• Provide support to where it will have the most impact
• Identify early actions to keep people well, not only focusing on people in direct contact with services but looking to join up care across different partners.

Type of data

• Identifiable
• Pseudonymised
• Anonymised
• Aggregate Data

NB only organisations that provide your care will see your identifiable data.

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine 

Data processors

Optum, Cerner

Payments

Purpose

Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amounts paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. 

Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non-patient related elements such as premises. Finally, there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient-based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.

Legal basis

• Article 6(1)(c) ‘processing is necessary for compliance with a legal obligation to which the controller is subject’; and 
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’.

Processor

NHS England, ICB, Public Health

GP clinical system

Purpose

NHS GP surgery clinical systems are digital platforms, that manage patient info, allowing online access via the NHS App for appointments, prescriptions, and viewing records (allergies, medicines, results). These systems ensure data sharing between clinicians through GP Connect, improving care, with all practices mandated to provide online access to new record entries. 

Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date.  Your record will follow you as you change surgeries throughout your life. 

Closed records will be archived by NHS England 

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’.

Processor

TPP And PCSE

Medical reports and subject access requests

Purpose

Your medical record may be shared in order that:

Solicitors/persons acting on your behalf can conduct certain actions as instructed by you. 

Insurance companies seeking a medical reports where you have applied for services offered by then can have a copy to your medical history for a specific purpose. 

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

Solicitors and insurance organisations

Medicines management team and medicines optimisation

Purpose

your medical record is shared with the medicines management team pharmacists, in order that your medication can be kept up to date and any necessary changes to medication can be implemented.

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

West Sussex ICB

Enhanced access service

Purpose

The enhanced access service will improve access for patients to primary care appointments between the hours of 6.30pm and 8pm Mondays to Fridays and between 9 am and 5pm on Saturdays.

Legal basis

UK GDPR:

• Article 6(1)(e) Necessary for the performance of a task carried out in the public interest
• Article 9(2)(h) Necessary for provision of health and/or social care, including preventative or occupational medicine

Processor

Riverside Medical Practice, UCATS (ABC)

Primary care network (PCN)

Purpose

Your medical record will be shared with the Horsham Central PCN in order that they can provide direct care services to the patient population. 

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

Holbrook and Riverside Surgeries

Smoking cessation

Purpose

Personal information is shared in order for the smoking cessation service to be provided.

Only those patients who wish to be party to this service will have their data shared 

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

WSCC

Social prescribers

Purpose

Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their health social care needs.

Only those patients who wish to be party to this service will have their data shared

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

Horsham Central PCN

Police

Purpose

Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared consent will not always be required. 

The Police will require the correct documentation in order to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime. Or where the information is necessary to protect a person or community.

Legal basis

UK GDPR 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 6(1)(f) ‘necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity’

Processor

Police Constabulary

Coroner

Purpose

Personal health records or information relating to a deceased patient may be shared with the coroner.

Legal basis

UK GDPR Article 6(1)(c) - to comply with a legal obligation and article 9(2)(h) health data

Processor

The Coroner

Medical examiner service (change to community ESH)

Purpose

Medical records associated with deceased patients are outside scope of the UK GDPR. However, next of kin details are within the scope of the UK GDPR. We will share specified deceased patient records and next of kin details with the Medical Examiners within ESH 

Legal basis

• Article 6(1)(c) – necessary under a legal obligation to which the controller is subject”; and
• Article 9(2)(h)– “processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services”

Processor

Medical Examiners service – ESH

Non-commissioned, private healthcare providers (e.g. BUPA, Virgin Care, etc.)

Purpose

Personal information shared with private health care providers in order to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with Private Providers.

Legal basis

Articles 6(1)(a) and 9(2)(a) Consented and under contract between the patient and the provider

Provider

Spire, Nuffield Hospital

Messaging service

Purpose

Personal identifiable information shared with the messaging service in order that messages including; appointment reminders; results; campaign messages related to specific patients health needs; and direct messages to patients, can be transferred to the patient in a safe way.

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Provider

AccuRX - NHSAPP, engage consult

Remote consultation, including: video consultation and clinical photography

Purpose

Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice.

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Patients may be videoed or asked to provide photographs with consent.  There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children.

Processor

AccuRX,

MDT meetings

Purpose

For some long term conditions, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions. Personal data will be shared with other agencies in order that mutual care packages can be decided.

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

St Catherine Hospice,

General Practice Extraction Service (GPES)

1. At risk patients data collection Version 3
2. CVDPREVENT Audit
3. Physical Health Checks for people with Severe Mental Illness

Purpose

GP practices are required to provide data extraction of their patients’ personal confidential information for various purposes to NHS England. The objective of this data collection is on an ongoing basis to identify patients registered at General Practices who fit within a certain criteria, in order to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction; by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work:  

1. At risk patients including severely clinically vulnerable
2. NHS England has directed NHS England to collect and analyse data in connection with Cardiovascular Disease Prevention Audit
3. GPES Physical Health Checks for people with Severe Mental Illness (PHSMI) data collection.
4. National Obesity Audit - NHS Digital

Legal basis

All GP Practices in England are legally required to share data with NHS England for this purpose under section 259(1)(a) and (5) of the The Health and Social Care Act 2012 

Further detailed legal basis can be found in each link. 

Any objections to this data collection should be made directly to NHS England. enquiries@nhsdigital.nhs.uk

Processor

NHS England

Medication/Prescribing

Purpose

Prescriptions containing personal identifiable and health data will be shared with organisations who provide medicines management including chemists/pharmacies, in order to provide patients with essential medication regime management, medicines and or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Pharmacists may be employed to review medication, Patients may be referred to pharmacists to assist with diagnosis and care for minor treatment, patients may have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver care and medication 

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

Pharmacy of choice

Professional training

Purpose

We are a training surgery. Our clinical team are required to be exposed to on the job, clinical experience, as well as continual professional development. On occasion you may be asked if you are happy to be seen by one of our GP registrars, pharmacists or other clinical team to assist with their training as a clinical professional. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE.

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.

Processor

RCGP, HEE, iConnect, Fourteen Fish

Telephony

Purpose

The practice uses an internet-based telephony system that records telephone calls, for their own purpose and to assist with patient consultations. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients.  We record incoming calls only / incoming and outgoing calls.

Our phone system is set to automatically retain calls for 30 days. After this point, the recordings are automatically deleted. The 30-day retention period enables us to download and retain exact and unaltered copies of calls where required for medico-legal purposes. 

Legal basis

While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way.

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Provider

Surgery Connect – X-ON, LouisComm, Gamma Horizon

Learning Disability Mortality Programme LeDer

Purpose

The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with this criteria will be shared with NHS England.

Legal basis

It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information who fit within a certain criteria. 

Processor

ICB, NHS England

Shared care record

Purpose

In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP connect, which is managed by NHS England, to enable a shared care record, which will assist in patient information to be used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population. 

Where data is used for secondary uses no personal identifiable data will be used. 

Where personal confidential data is used for Research explicit consent will be required. 

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

NHS England 

Local shared care record SCFT

Purpose

The shared care record will assist in patient information being used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population. 

Where data is used for secondary uses no personal identifiable data will be used. 

Where personal confidential data is used for research explicit consent will be required. 

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

SCFT

Anticoagulation monitoring

Purpose

Personal Confidential data is shared with LumiraDX in order to provide an anticoagulation clinic to patients who are on anticoagulation medication. This will only affect patients who are within this criteria. 

Legal basis 

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

LumiraDX INRStar

Off-site storage of Lloyd George medical records

Purpose

The practice has commissioned an off-site storage provider for the storage of their Lloyd George Medical Records.

The facility has met the NHS standards as a supplier of this service. The practice can assure patients that their medical records will remain in the control of the practice and robust mechanisms are in place to protect the security of the data held.

Legal basis

Under UK GDPR

• Article 6 1 (b) contract obligation
• Article 6 1 (e) Public Task
• Article 9 2 (h) Health data

Processor

Iron Mountain UK PLC

AI Scribe Software

Purpose

The practice intends to use ‘Heidi’ to process and transcribe clinical conversations, either between a clinician and patients or of a clinician dictating their clinical findings/management plan during, before or following patient consultations. The technology looks to capture relevant details such as different speakers, medical terminology and symptomatology. 

Legal basis

• 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”
• Article 9(2)h “processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services”

Processor

Heidi Health

Self Health Kiosk

Purpose

Personal confidential and special category data is accessed in order for patients to review and update their medical record without needing a doctor’s appointment. Information will be accessed by the patient using the Elephant Kiosk in the waiting room and transferred back to their medical record. No data will be stored within the elephant kiosk.

Legal basis

• 6 1 (e ) Public task
• 9 2 (h) Direct health care

Provider

EK Innovations Health Kiosk

NHSMail and Office 365 (N365 applications and SharePoint)

Purpose

NHSmail and Office 365 help NHS staff work more securely and efficiently which directly benefits our patients: · Security: Emails are encrypted keeping your sensitive information safe. · Collaboration: Staff can easily work together saving time and improving care. · Reliability: The system is supported 24/7 to avoid service disruptions.

• National Reach: Staff can easily connect across different NHS organisations.
• Safety: Advanced protection against viruses and spam keeps information secure.
• Flexibility: Staff can communicate without disruption even if organisations change. These tools support the NHS's goal of improving digital care and collaboration.

Legal basis

• 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”;
• Article 9(2)h - “processing is necessary for the purposes of preventive or occupational medicine”;

Processor

Accenture

Sub-processor

Microsoft

Child health information services (CHIS)

Purpose

South Central and West Child Health Information Services (SCW CHIS) is commissioned by NHS England to support the monitoring of care delivered to children.  Personal data is collected from the child’s GP record to enable health screening, physical examination and vaccination services to be monitored to ensure that every child has access to all relevant health interventions. 

For more information visit Fair Processing Notice Child Health Information Services

Legal basis

• Article 6(1)(e); ‘necessary… in the exercise of official authority vested in the controller’ and Article 9(2)(h) as stated below.

Processor

SCW, Apollo Medical Software Solutions, SystemC

OpenSAFELY covid-19 and data analytics services

Purpose

"NHS England has been directed by the government to establish and operate the OpenSAFELY COVID-19 Service and the OpenSAFELY Data Analytics Service. These services provide a secure environment that supports research, clinical audit, service evaluation and health surveillance for COVID-19 and other purposes.

Each GP practice remains the controller of its own GP patient data but is required to let approved users run queries on pseudonymised patient data. This means identifiers are removed and replaced with a pseudonym.

Only approved users are allowed to run these queries, and they will not be able to access information that directly or indirectly identifies individuals.

Legal basis

UK GDPR – Article 6 basis:

• UK GDPR Article 6(1)(c) - processing is necessary for compliance with a legal obligation to which the controller is subject (the Directions).
• UK GDPR Article 9 basis:
• UK GDPR Article 9(2)(g) - processing is necessary for reasons of substantial public interest, on the basis of domestic law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject, by virtue of compliance with a direction  supplemented by:

Patients who do not wish for their data to be used as part of this process can register a type 1 opt out with their GP.

Here you can find additional information about OpenSAFELY."

Processor

NHS England , The Phoenix Partnership (TPP), 

Online access

Purpose

To allow patients to access their GP medical record online via the NHS App. The view all documents and entries made into their record by the GP, including information sent to the GP Practice where exemptions do not apply. Where a patient has requested third party access (family/friends) to their medical records, it is the patient’s responsibility to ensure removal of this access if no longer required. Proxy access to the patient’s record will be limited unless the patient has requested full access.

Legal basis

UK GDPR

• Article 6(1)(e) Necessary for the performance of a task carried out in the public interest
• Article 9(2)(h) Necessary for provision of health and/or social care, including preventative or occupational medicine

Common Law Duty of Confidentiality (CLDC)

• The CLDC is satisfied as the data subjects are accessing their own data following sign up for a relevant app or platform and selecting the option to view their GP record.

Processor

NHS Digital, TPP

GP connect

Purpose

In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP Connect, which is managed by NHS England.

 GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.

GP Connect is not used for any purpose other than direct care.

GP Connect provides a method of secure information transfer and reduces the need to use less secure or less efficient methods of transferring information, such as email or telephone.  

GP Connect transparency notice

Legal basis

• Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine’

Processor

NHS England

We keep our Privacy Notice under regular review. This notice was last reviewed in June 2026