Following changes to data protection laws (GDPR) that came into effect on 25th May 2018 Choices LBG needs to explain how we collect and process your data
Data controller
Choices will be the ‘data controller’ of personal information collected and used. This means we are responsible for deciding what personal data about you is required and how it should be protected.
What data is held?
Healthcare 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 us to provide you with the best possible medical care.
Where is it from and where is it sent?
We may keep your information in a written form and/or a digital form. The records will include basic details about you, such as your name, address and date of birth but they may also include more sensitive data (known as ‘special category data’) such as information about your health, your problems, medical investigations, treatments and outcomes of treatments, your habits, appointments you have attended, referrals to specialists and other healthcare providers, the observations and opinions of other healthcare workers within and outside of Choices, as well as comments and aide memoires reasonably made by healthcare professionals who are appropriately involved in your Healthcare.
In some situations your health needs may require care from other healthcare providers or healthcare services outside of this Practice, such as a referral to see a specialist at the Medical Specialist Group. In these situations we will exchange with them information about you that is necessary for them to provide that care. Anyone with whom we share this information will have a professional and contractual duty of confidentiality.
Primary care manage the cervical cancer screening programme. If a patient wishes to have this screening undertaken at Choices the results will be shared with their primary care practitioner but not without your permission to do so.
We are also obliged to inform the States of Guernsey, Health and Social Care Department of Public Health of any notifiable illnesses and this may require some sharing of personal information.
Your consent to this sharing of data, within Choices LBG and with those outside the service under these circumstances is assumed and is allowed by the Law. In all these situations we would only share your information with others involved in your care who have a genuine need for it and only the minimum amount of information required to serve that purpose would be released. However, you do have a right to object to our sharing of your data
We would not share your information with any other third parties without your explicit consent unless there were exceptional circumstances (i.e. a life and death situation) or where disclosure is in the public interest or when there is a legal duty to do so, for example a court order.
If you are aged 13 but under 16, you have the same rights to confidentiality as an adult. However there may be circumstances surrounding safeguarding concerns where information may need to be shared in order to safeguard you.
Who will have access to your data and why?
Only staff who have an authorised reason in order to provide a service to you will have access to your data and will only access it as and when they are providing a service to you; this includes both clinical and administrative staff within Choices LBG.
On registration with Choices LBG you will be asked to complete a handwritten form with personal data and contact preferences. This form will be disposed of by shredding on completion of the registration process. You will be allocated a unique number by the Inform healthcare system.
On return visits you may complete an attendance request form to indicate the services needed. This form will also be destroyed by shredding on completion of the updating process.
For patients over 21: For Choices to receive a small grant payment from the States of Guernsey, in respect of the annual fee paid by you to Choices, an active GY (social security) number is required. On occasion It may be necessary, with your permission, for the clinic staff to contact social security to obtain this number on your behalf. You will be asked to sign a slip agreeing to information such as Name and date of birth being shared. If you do not wish this information to be shared, a higher annual fee will be charged to compensate for the loss of the grant payment.
For patients under 21: anonymised data only will be shared with the Director of Public Health for the purposes of financial renumeration and data analysis e.g contraception uptake by method.
Social Security medical bill claims: In order for Choices to claim on your behalf from social security, basic information will be shared securely, with the department in the form of date of attendance, name , address, GY number and cost of services provided.
Pathology department Princess Elizabeth Hospital: all sexual health tests are submitted to pathology at the PEH using a unique individual coding system. Results referred to a UK reference lab (e.g. Birmingham) will also use this unique identifier. Named Patient matching of results will only take place within the Inform healthcare system by clinical staff at Choices.
Cervical screening –Bristol: the cervical screening request form will need to contain your name and address as well as GP name (where applicable) . This information is sent to the pathology department at the PEH before onward transmission to Bristol for analysis.
Where is data stored?
All clinical information and appointments are stored by Choices on our clinical patient system known Inform health. The server is web based and hosted by Inform.
A log of test requests and results is stored on a password protected database for use by clinical staff only within Choices.
Mobile phone use:
The clinic mobile number is used to send and receive texts and as such personal information will be shared to the staff at Choices. The memory log will be cleared daily for both SMS and calls and the phone locked away outside clinic operating hours.
Your rights
You may ask for a copy of the information we hold on you. If at any point the information we hold on you is wrong you may request it is corrected,
If you wish to raise a complaint about how we handle your personal data, please contact us to have the matter investigated. You may also contact the Office of the Data Protection Commissioner.
Tel No: (01481) 742074 or email: enquiries@dataci.org
Keep us informed
It is important that information held on you is accurate and current. Please keep us informed of any personal detail changes particularly a change of address and phone number.
GDPR compliance
Choices will endeavour to:
- Treat all information about an individual confidentially and respectfully
- Share confidential information only when it is needed for the direct care of an individual
- Not share confidential information which will allow a person to be identified unless it is for direct care
- Respect an individual’s request that information is not shared beyond their own care and treatment