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. We will keep your information in written form and/or in digital form.

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 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 by the service
• Research into the development of new treatments and care pathways
• Preventing illness and diseases
• Monitoring safety
• Planning services
• Risk stratification
• Population Health Management
• Medical reporting

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, Her 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.

For a full list of details including the legal basis, any Data Processor involvement and the purposes for processing information please contact the practice.

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 - NHSX. 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 national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs. 

The national data opt-out replaces the previous ‘Type 2’ opt-out, which required NHS Digital not to use a patient’s confidential patient information for purposes beyond their individual care, for Planning or Research. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out.  For more information go to National data opt out programme

To find out more or to register your choice to opt-out, please visit Your NHS Data Matters.  

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 data
• 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

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. 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, or via the practice's system. Access your GP record online.

Patients may access their Covid passport, the practice cannot provide this document as it is not held in the practice record. If you have any issues gaining access to your Covid Passport or letter you should call: 119.

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.

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.

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, in the first instance please contact the practice manager and select ‘Comments and  Suggestions’ and then ‘Patient Support’.  The practice manager will forward any queries to our named Data Protection Officer Emile Douilhet.

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 submit an online submission form via the website, or via the ICO details listed below.

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

The Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone: 0303 123 1113

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under Data Protection Legislation.

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.

Appendix A

The Practice will share patient information with these organisations where there is a legal basis to do so.
We keep our Privacy Notice under regular review. This notice was last reviewed in January 2024.

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 apply a National Data Opt Out

Processor

BOB 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 the form which can be downloaded here 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 and NHS Digital

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)(a) – 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

Velocity Clinical Research, NIHR Clinical Research Network (CRN)

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

• Under UK GDPR Article 6 1(a) consent is required
• 6 1 (e) Public Task Article 9 2 (h) health data

Data Processor

Data processor – The IFR & Prior Approvals Team, NHS South, Central & West

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

Data Processor: All current Safeguarding Teams, to include:

• Designated Nurse for Safeguarding Adults
• Designated Nurse for Safeguarding Adults 
• Named GP for Safeguarding Adults, ICB 
• MASH – Health Administrator 
• Exploitation Hub Specialist Nurse 
• ICB Generic Safeguarding Contact Details, ICB 
• Bucks Safeguarding Adults Board, BC 
• Safeguarding Adults Team 
• Victims First The Willow Project/ NRM Referral 
• Joint Mental Capacity Act Coordinator and Deprivation of Liberty Safeguards Lead, Bucks Council 
• Women’s Aid 
• Domestic Abuse support 
• Rape Crisis 
• Solace Sexual Assault Referral Centre

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

• Designated Nurse for Safeguarding Children and Looked After Children, ICB
• Designated Nurse for Safeguarding Adults 
• Designated Nurse for Safeguarding Adults 
• Designated Doctor Child Protection and Looked After Children, ICB
• Named GP for Safeguarding Children, ICB
• Named GP for Safeguarding Adults, ICB 
• Named Nurse Looked After Children, BHT Designated Doctor 
• Unexpected Deaths in Childhood, BHT 
• MASH – Health Administrator 
• Exploitation Hub Specialist Nurse 
• CCG Generic Safeguarding Contact Details, 

Bucks Safeguarding Children Partnership, BC 

• Bucks Safeguarding Adults Board, BC 
• Children’s Social Care 
• Safeguarding Adults Team 
• Victims First The Willow Project/ NRM Referral 
• Joint Mental Capacity Act Coordinator and Deprivation of Liberty 
• Safeguards Lead, Bucks Council 
• Women’s Aid
• Domestic Abuse support 
• Rape Crisis 
• Solace Sexual Assault Referral Centre

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

• UK GDPR Art. 6(1) (e) Public task and Art.9 (2) (h) Health data. The use of identifiable data by ICBs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)
• (a)/2013)) and this approval has been extended to the end of September 2022 NHS England » Risk Stratification which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.

Processors

SCW and Graphnet, Ardens

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 Population Screening Programmes webpage 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

Public Health Buckinghamshire

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' 

In some cases patients may be required to consent to having their record opened by the third party provider before patients information is accessed. Where there is an overriding need to access the GP record in order to provide patients with life saving care, their consent will not be required. 

Processors

BHT, OUH, OHFT

Care Quality Commission (CQC)

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

• 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) as stated below

Processors

Care Quality Commission

Population Health Management

Purpose

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

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 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' 

Data Processors

NHS England, ICB, Public Health

Patient Record database

Purpose

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' 

Data Processors

EMIS Web and PCSE

Medical Reports - 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)(a) – consent for personal data; and
• Article 9(2)(a) – explicit consent for special-category data.

Data Processors

Solicitors and insurance organisations, iGPR Technologies

Medicines Management Team - 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’

Processors

PCN pharmacists, ICB pharmacy team and Core Prescribing Solutions

GP Federation, GP Extended Access, Video consultations, Minor injuries services

Purpose

Your medical record will be shared with the Fedbucks in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics. The Federation will be acting on behalf of the GP practice.

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

Fedbucks, GP Extended Access, Covid 19 Vaccination Clinics

Primary Care Network (PCN) 

Purpose

Your medical record will be shared with the Arc 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’

Processors

Marlow Medical Group, Cherrymead Surgery, The Simpson Centre, Millbarn Medical Centre, Marlow Medical Group and Highfield Surgery

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

Live Well Stay Well, Health and Wellbeing Buckinghamshire 

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

NHS Mail, EMIS, JOY

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)(c) – to comply with a legal obligation; and
• Article 9(2)(j) – ‘for reasons of substantial public interest’

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) – ‘necessary for the purposes of preventative or occupational medicine’.

Processor

The Coroner

Medical Examiner Service

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 Buckinghamshire. 

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 – Bucks Medical Examiner (BHT)

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) consent by the patient given under contract to the provider.

Provider

All private healthcare providers as chosen by the patient. 

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 – Klinik, Medlink, NHS App

Remote consultation Including – Video Consultation 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, LIVI

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

BHT, Oxford Mental Health, Bucks County Council

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
4. National Obesity Audit

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.

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 use 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.

Our phone system is set to automatically retain calls up to 100 GB.   After this point, the recordings are automatically deleted.  This 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

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

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

My Care Record

Local shared care record (My Care Record)

Purpose

Health and Social care services are developing shared systems to share data efficiently and quickly.  It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment.  It is also quicker for staff to access a shared record than to try to contact other staff by phone or email.

Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job.  Systems do not share all your data, just data which services have agreed is necessary to include.

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

My Care Record

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

Weight and Wellbeing programme

Purpose:

Personal information is shared in order for the Weight and Wellbeing lifestyle intervention programme to be provided. Only those patients who wish to be party to this service will have their data shared.

Legal Basis: 

• Article 6 1 (a) and 
• 9 2 (h) consent

Processor - Xpert Health Training & Education Ltd, CX Services Lt

Communications     

We 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.

Heidi     

Purpose:

Automatic consultation notes. BEWGMC utilises Heidi by recording consultations to create consultation notes.  

• At the recording stage, no one has access as the recording is automatically deleted once transcription is complete.
• During processing, the data is encrypted in transit and de-identified, and no one outside the authorised team can access those details.
• Final storage is entirely controlled by the clinician within their Heidi platform.

Website.

Healthtech1    

Purpose:

Automate registrations and process lap reports.  

Anonymised data is used by Healthtech-1 for evidence generation, reporting service metrics, business intelligence and analysing trends or patterns in the data (such as patient language needs or reasons for moving GP practice). Healthtech-1 anonymises this data at the point of aggregation by deleting personally identifiable information leaving its business intelligence platform

Dyad Better Letter    

Purpose:

Increase staff efficiency, benefit patients with accurate coding of documentation and assist NHS with public health monitoring (through consistent coding).  

All data backups are kept within the platform, and are encrypted at rest. Google Cloud was selected to host the BetterLetter application and protect the special category data because Google Cloud, the Common Google Infrastructure, Google Workspace, Chrome, and Apigee are all certified as ISO/IEC 27001 compliant.  An overview of how Google Cloud meets the requirements for processing NHS patient data can be seen here. All data that is stored by Google is encrypted at the storage layer using the

Advanced Encryption Standard (AES) algorithm, AES-256. Google uses a common cryptographic library, Tink, which includes a FIPS 140-2 validated module (named BoringCrypto) to implement encryption consistently across Google Cloud. Microsoft Azure is similarly high security, and is a preferred provider of cloud services to the NHS. Where we use other web services for delivering the BetterLetter application we undertake similar checks as to their compliance with information security standards, and we keep a registry of our data subprocessors available as part of our DPA which can be viewed here. All data are encrypted during transfer via SHA-256.

Legal Basis:

• Article 6 1 (a) and 
• 9 2 (h) see below

Adult Vaccination: Shingles and Pneumococcal National Immunisation Programmes
    

Purpose:

To ensure patients are up to date with their adult immunisations – To support direct patient care

Legal Basis: 

• Article 6(1)e and
• Article 9(2)h – Direct Care

Processor: CHASE Search and Selection Limited

We keep our Privacy Notice under regular review. This notice was last reviewed in June 2025. 

Lawful basis for processing:

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 and 9 conditions of the 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 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...”