Privacy Policy

 

OxFed is committed to protecting the privacy and personal information of people using our website and our services. We take great care in adopting practices and supporting technology to ensure our services remain safe and secure.

As a registered company in England and Wales we are legally obliged to use your information in line with all applicable laws concerning the protection of personal information. This privacy policy explains how we collect, store and use personal data about you when you use our website and our services.

Please read this privacy policy carefully. We recommend that you print and retain a copy for your future reference. OxFed may change this policy from time to time by updating the relevant page on the website. You should check this page from time to time to ensure that you are happy with any changes. This policy was last updated on 31 October 2018.

Who We Are

OxFed Health & Care Ltd. is a provider of NHS services and the not-for-profit trading company of the Oxford Federation for General Practice and Primary Care, a network organisation of the NHS GP Practices in Oxford. Our Company Number is 09368553 and we are registered in England and Wales. Our Registered Address is: Northway Community Centre (2nd Floor), Dora Carr Close, Oxford, OX3 9RF.

We regard the fair and lawful treatment of personal data as very important for maintaining confidence between you and us.

How We Collect and Use Your Personal Information

When you access or browse the website or otherwise deal with us by telephone, email or in other ways, we may collect certain information from you, including:

  • Your name
  • Your address
  • Your phone and email details.

We may use your personal data:

  • To send you email newsletters and other information relating to activities of OxFed
  • To administer your membership
  • To monitor customer use of the web site on an anonymous basis to identify general trends and to understand better our visitors’ behaviours; and
  • To investigate, respond to and comply with any legal, regulatory and similar requirements in relation to our organisation and our business.

We will not sell or share your information with a third party (other than any data processors acting on our behalf) unless you consent to this.

Cookies

A cookie is a small piece of data sent from a website and stored in a user's web browser while the user is browsing that website. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. Use of cookies is industry standard and information contained in cookies will enhance your experience on the website. Cookies can store non-personally identifiable information, such as what web sites, pages, or advertisements your browser has accessed and may be tied to the personal information you knowingly choose to provide to us. Cookies help establish a user session and allow our web servers to correctly provide website users with the appropriate information and services.

We may use two types of cookies - session cookies and persistent cookies - to enable us to collect aggregate information on the usage patterns of the website, such as what areas of the site are visited most often, so that we can tailor the site to user preferences. Session cookies exist only for as long as your Internet browser remains open. When the session ends, the Internet browser is closed and the cookies go away. Persistent cookies, in contrast, last from visit to visit. Persistent cookies are saved on a visitor's computer by the Internet browser and do not go away when you exit your Internet browser. It is recommended that a user clears, or deletes, cookies and other user-related information in the browser when not needed.

You have control over cookies. Most Internet browsers can be set to refuse to accept cookies, although this may affect your experience when using our website. You can also erase cookies that are already on your computer, block all cookies or receive a warning before a cookie is stored. Please refer to your Internet browser instructions or “help” screen to learn more about these functions. If you choose to have your Internet browser refuse cookies our website may not function properly for you. When a search is performed, the web site may use a small number of cookies during each visit, some of which may be stored permanently on your computer. A standard acceptance dialogue box will appear on the site, and your acceptance here will constitute acceptance of receipt of the cookies.

Information for patients and healthcare service users

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 to provide you with the best possible healthcare and help 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 may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form. The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments.

 

 

Details we collect about patients and users of our healthcare services

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP Surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

Records which we may hold about you may include the following:

 

  • Details about you, such as your address and next of kin
  • Any contact our services have had with you, such as appointments, clinic visits, emergency appointments, etc.
  • Notes and reports about your health
  • Details about your treatment and care
  • Results of investigations such as blood tests, x-rays, etc.
  • Relevant information from other health professionals, relatives or those who care for you.

How we keep your information confidential and safe

Everyone working for our organisation is subject to the Common Law Duty of Confidence.  Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law.  The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.  All our staff are expected to make sure information is kept confidential and they receive regular training on how to do this.

 

The health records we use may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure.  Your records are backed up securely in line with NHS standard procedures.  We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

  • Data Protection Act 1998
  • Human Rights Act
  • Common Law Duty of Confidentiality
  • NHS Codes of Confidentiality and Information Security
  • Health and Social Care Act 2015
  • And all applicable legislation.

 

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

How we use and share 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 your permission when your usual GP Practice is closed.  This is explained further in the Local Information Sharing section below.

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from NHS healthcare providers without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.

You may choose to withdraw your consent to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we will display prominent notices in our clinics and on our website at least four weeks before the scheme is due to start. Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.

You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the staff will explain this to you at the time you object.

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS.

Child Health Information

It is important that your child has the opportunity to have immunisations and health checks when they are due. Where necessary, information about childhood immunisations, the 6-8 week new baby check and breast-feeding status will be shared with NHS Oxford Health Foundation Trust health visitors and school nurses, and with NHS South Central and West Commissioning Support Unit, who provide the Child Health Information Service in Oxfordshire on behalf of NHS England. 

Clinical Audit

Information may be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

Clinical Research

Sometimes your information may be requested to be used for research purposes – we will always ask your permission before releasing your information for this purpose.

Improving Diabetes Care

Information that does not identify individual patients is used to enable focussed discussions to take place at local diabetes review meetings between health care professionals. This enables the professionals to improve the management and support of these patients. 

Individual Funding Request

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for funding of specialised healthcare which falls outside the range of services and treatments that CCG has agreed to commission for the local population. An Individual Funding Request is taken under consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to check which CCG is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

Local Information Sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a local health or care professional outside of your usual practice services, such as in an Evening and Weekend GP Access Clinic, GP Federation Service, Emergency Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them.

Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view parts of your GP electronic patient record (e.g. Oxfordshire Care Summary or your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. EMIS remote consulting system).

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) or if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).

National Fraud Initiative - Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 1998. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see:

https://www.gov.uk/government/publications/code-of-data-matching-practice-for-national-fraud-initiative 

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

Risk Stratification

‘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.

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the Oxfordshire NHS Clinical Commissioning Group (OCCG). Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from: https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification /                                             

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.

Safeguarding

To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.

Summary Care Record (SCR)

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.

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.

Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, fax or phone. If you wish to opt-out of having an SCR please return a completed opt-out form to your registered GP Practice.

Supporting Medicines Management

Oxfordshire CCG and some Oxfordshire GP Federations operate pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the CCG medicines management team may order medications on behalf of your GP Practice to support your care.

Supporting Locally Commissioned Services

CCGs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality.  The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

Suspected Cancer

Data may be analysed in cases of suspected cancer by Nuffield Department of Primary Care Health Sciences, Oxford University to facilitate the prevention, early diagnosis and management of illness.  Measures are taken to ensure the data for analysis does not identify individual patients.

 

 

 

Data retention

We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:

  • GP Practices
  • NHS Trusts
  • Specialist Trusts
  • GP Federations
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Clinical Commissioning Groups
  • Social Care Services
  • Local Authorities
  • Education Services
  • Fire and Rescue Services
  • Police
  • Other ‘data processors’

We will never share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function.

Within the health partner organisations (e.g. NHS organisations and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below).

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued.  Our guiding principle is that we are holding your records in strictest confidence.

Your right to object to the sharing of your personal information (Opt-Out)

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. 

If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do this, please inform your registered GP Practice of your request so your record can be coded appropriately. We will respect your decision if you do not wish your information to be used for any purpose other than your care, but in some circumstances we may still be legally required to disclose your data.

There are two main types of opt-out available:

Type 1 Opt-Out

If you do not want information that identifies you to be shared for purposes beyond your direct care, you can register a ‘Type 1 Opt-Out’This prevents your personal confidential information from being used other than in your direct care and in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease.

Type 2 Opt-Out

NHS Digital collects information from a range of places where people receive care, such as hospitals and community services. If you do not want your personal confidential information to be shared outside of NHS Digital, for purposes other than for your direct care, you can register a ‘Type 2 Opt-Out’.   For further information about Type 2 Opt-Outs, please contact  NHS Digital Contact Centre at enquiries@hscic.gov.uk referencing ‘Type 2 Opt-Outs – Data Requests’ in the subject line; or call NHS Digital on (0300) 303 5678; or visit the website http://content.digital.nhs.uk/article/7092/Information-on-type-2-opt-outs

If you wish to discuss or change your opt-out preferences at any time please contact your registered GP Practice.

NHS Digital is developing a new system to give you more control over how your identifiable information is used. We will update this notice with more information once details are released.  

Your rights and how to access your information

Under the Data Protection Act 1998 you have the right to see, or have a copy, of data we hold that can identify you (with some exceptions).  You do not need to give a reason to see your data. If you want to access your data you must make the request in writing. Under special circumstances, some information may be withheld.  We may charge a reasonable fee for the administration of the request.

You also have the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge and the right to opt out of any marketing communications that we may send you.

If you wish to exercise any of the above rights, please contact us at OxFed.admin@nhs.net

Change of details

It is important that you tell the person treating you and your registered GP Practice if any of your details such as your name or address have changed or if any of your details are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.

Mobile telephone number

If you provide us with your mobile phone number we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.

Notification

The Data Protection Act 1998 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 at:  http://ico.org.uk/what_we_cover/register_of_data_controllers

Any changes to this notice will be published on our website.

Complaints and concerns

If you have concerns, a complaint or would like further information, please contact OxFed.admin@nhs.net

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

Website: www.ico.gov.uk

Further information

Further information about the way in which the NHS uses personal information and your rights can be found here:

 

NHS Care Record Guarantee [link to: http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf

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 the Data Protection Act 1998.

 

NHS Constitution [link to: https://www.gov.uk/government/publications/the-nhs-constitution-for-england

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

 

NHS Digital [link to: http://content.digital.nhs.uk/article/4963/what-we-collect

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.