Online Access / Making a Subject Access Request (SAR)

Introduction
The Data Protection Act gives every living person (or authorised representative) the right to apply for access to their health records.

Online Access to Medical Records
As of March 2016, Coded information from Medical Records can be accessed as part of the Practice’s online services. For security reasons, you will have to visit the practice to undertake an identity check before you are granted access to these records.

To make a subject access request
A request for your medical health records held at Blacketts Medical Practice must be made in writing (e-mails accepted) to the data controller who is: Sarah Stelling, Practice Manager. Please contact the practice for alternative methods of access if you are unable to make a request in writing).

You can apply using an Application for Access to Medical Records Form which are available from reception if you wish.

Costs
Under the Data Protection Act you will not normally be charged a fee to view your health records or to be provided with a copy of them unless the request is judged to be unfounded or excessive.

CCTV Images

CCTV images will not be retained longer than is considered necessary, and will be then be deleted.

All images will be held securely, and all access requests, and access to images will be documented.

Except for law enforcement bodies, images will not be provided to third parties.

Images may record individuals and/or record incidents. Not all recordings are designed to identify persons.

Other than in accordance with statutory rights, the release or availability of images will be at the discretion of the Data Controller(s) for the purposes of the Data Protection Act 2017.

Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime, and images may be provided to police or other bodies.

Where access is granted in response to an application received, the image may be edited to exclude images of third parties who are also included within the requested image. This may be necessary to protect the identity of the third parties. In these circumstances the image released as part of the application may identify the “data subject” only.

Images will be located by the Data Controller or authorised person.

The practice regularly reviews compliance with the ICO’s CCTV Code of Practice; continued operational effectiveness and whether the system continues to meet its purposes and remains justified.

Complaints

If you have any complaints about any aspect of your application to obtain access to your health records, you should first discuss this with the Practice. All complaints will be acknowledged within three working days and a full response will be provided.

Alternatively you can contact the Information Commissioners Office (responsible for governing Data Protection compliance) –

Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Tel 01625 545745 or  visit www.ico.org.uk/

Blacketts Medical Practice is committed to providing a safe, comfortable environment where patients and staff can be confident that best practice is being followed at all times and the safety of everyone is of paramount importance.

All patients are entitled to have a chaperone present for any consultation, examination or procedure where they consider one is required. The chaperone may be a family member or friend, but on occasions a formal chaperone may be preferred for example a Practice Nurse or other member of The Practice Team.

The Healthcare Professional may also require a chaperone to be present for certain consultations.

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Introduction

The Data Protection Act 2018 (DPA) requires a clear direction on policy for security of information held within the practice and provides individuals with a right of access to a copy of information held about them.

The practice needs to collect personal information about people with whom it deals in order to carry out its business and provide its services. Such people include patients, employees (present, past and prospective), suppliers and other business contacts. The information we hold will include personal, sensitive and corporate information. In addition, we may occasionally be required to collect and use certain types of such personal information to comply with the requirements of the law. No matter how it is collected, recorded and used (e.g. on a computer or on paper) this personal information must be dealt with properly to ensure compliance with the Data Protection Act 2018.

The lawful and proper treatment of personal information by the practice is extremely important to the success of our business and in order to maintain the confidence of our service users and employees. We ensure that the practice treats personal information lawfully and correctly.

This policy provides direction on security against unauthorised access, unlawful processing, and loss or destruction of personal information.

See also: Access to Medical Records policy, which covers Subject Access Requests under the Data Protection Act.

1.0 Data Protection Principles

We support fully and comply with the six principles of the Act which are summarised below:

1. Personal data shall be processed fairly and lawfully.
2. Personal data shall be obtained/processed for specific lawful purposes, and will only be used for the purpose for which it was collected.
3. Personal data held must be adequate, relevant and not excessive.
4. Personal data must be accurate and kept up to date, and every reasonable step will be taken to ensure any personal data that is inaccurate is erased or rectified without delay.
5. Personal data shall not be kept for longer than necessary.
6. Personal data shall be processed in a manner that ensures appropriate security of the personal data.

2.0 Employee Responsibilities

All employees will, through appropriate training and responsible management:

• comply at all times with the above Data Protection Act principles
• observe all forms of guidance, codes of practice and procedures about the collection and use of personal information
• understand fully the purposes for which the practice uses personal information
• collect and process appropriate information, and only in accordance with the purposes for which it is to be used by the practice to meet its service needs or legal requirements
• ensure the information is correctly input into the practice’s systems
• ensure the information is destroyed (in accordance with the provisions of the Act) when it is no longer required
• on receipt of a request from an individual for information held about them by or on behalf of immediately notify the practice manager
• not send any personal information outside of the United Kingdom without the authority of the Caldicott Guardian / IG Lead
• understand that breaches of this Policy may result in disciplinary action, including dismissal

3.0 Practice Responsibilities

The practice will:

• Ensure that there is always one person with overall responsibility for data protection. Currently this person is Jayne Turner, should you have any questions about data protection. Sandi Wood will take on these responsibilities if the first named individual is absent with illness or on annual leave.
• Maintain its registration with the Information Commissioner’s Office
• Ensure that all subject access requests are dealt with as per our Access to Medical Records policy
• Provide training for all staff members who handle personal information
• Provide clear lines of report and supervision for compliance with data protection and also have a system for breach reporting
• Carry out regular checks to monitor and assess new processing of personal data and to ensure the practice’s notification to the Information Commissioner is updated to take account of any
  changes in processing of personal data
• Develop and maintain DPA procedures to include: roles and responsibilities, notification, subject access, training and compliance testing
• Display a poster in the waiting room explaining to patients the practice policy (see Data Protection Act – Patient information) plus a copy of the Information Commissioners certificate
• Make available a leaflet and or a poster in reception on Access to Medical Records for the information of patients. Also display the certificate of registration with the Information Commissioners office.
• Take steps to ensure that individual patient information is not deliberately or accidentally released or (by default) made available or accessible to a third party without the patient’s consent, unless otherwise legally compliant. This will include training on confidentiality issues, DPA principles, working security procedures, and the application of best practice in the workplace.
• Undertake prudence in the use of, and testing of, arrangements for the backup and recovery of data in the event of an adverse event.
• Maintain a system of “Significant Event Reporting” through a no-blame culture to capture and address incidents which threaten compliance.
• Include DPA issues as part of the practice general procedures for the management of risk.
• Ensure confidentiality clauses are included in all contracts of employment.
• Ensure that all aspects of confidentiality and information security are promoted to all staff.
• Remain committed to the security of patient and staff records.
• Ensure that any personal staff data requested by the CCG or NHS, i.e. age, sexual orientation and religion etc., is not released without the written consent of the staff member
  

  Data Protection Act – Patient Information

  We need to hold personal information about you on our computer system and in paper records to help us to look after your health needs, and your doctor is responsible for their accuracy and safe-keeping. Please help to keep your record up to date by informing us of any changes to your circumstances.

  Doctors and staff in the practice have access to your medical records to enable them to do their jobs. From time to time information may be shared with others involved in your care if it is necessary.
  Anyone with access to your record is properly trained in confidentiality issues and is governed by both a legal and contractual duty to keep your details private.

  All information about you is held securely and appropriate safeguards are in place to prevent accidental loss.

  In some circumstances we may be required by law to release your details to statutory or other official bodies, for example if a court order is presented, or in the case of public health issues. In other
  circumstances you may be required to give written consent before information is released – such as for medical reports for insurance, solicitors etc.

  To ensure your privacy, we will not disclose information over the telephone or fax unless we are sure that we are talking to you. Information will not be disclosed to family, friends, or spouses unless we have prior written consent, and we do not leave messages with others.

  You have a right to see your records if you wish. Please ask at reception if you would like further details and our patient information leaflet. An appointment will be required. In some circumstances a fee may be payable.

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

Wheelchair access

The Practice has been specially designed to make it easier for disabled patients to visit. There are no steps at the entrance of the building giving patients easy access. Due to fire regulations, we do have heavy fire doors, however if you have trouble opening these please ask a member of staff for assistance as they are always happy to help.

There are several dedicated disabled car parking spaces available immediately outside the front entrance of The Practice.

We have a wheelchair for patient’s use, at their own risk, should you require one whilst visiting our premises.

We have two disabled toilets one on each floor.

Disabled parking – Blue badge scheme

The Blue Badge Scheme is for people with severe mobility problems. It allows Blue Badge holders to park close to where they need to go.

Guide Dogs

Guide dogs are welcome at the practice but we ask that you be aware of other patients and staff who may have an allergy or fear of dogs. Our Guide Dog Policy available to download.

Privacy Policy

We aim to keep our practice clean and tidy and offer a safe environment to our patients and staff.  We are proud of our modern, purpose built Health Centre and endeavour to ensure it is kept clean and well maintained at all times.

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

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

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

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

Significant events

In the past year there have been no significant events raised that related to infection control.

Cleaning specifications

The cleaning staff work to structured cleaning schedules and the daily cleaning of the Health Centre is contracted to a company who follow national NHS guidance.  The public areas are cleaned every evening.

Infection control policy

The Infection Control Policy is reviewed and updated annually if appropriate and updated on an ongoing basis as current advice changes.

When a patient registers at a practice a transaction is sent to the Primary Care Support Service notifying them that they are a new patient. Your paper medical records from your previous practice will then be sent to the Primary Care Support Service and transferred to your new practice. The process of receiving your paper medical records normally runs smoothly but it can sometimes take up to three months. Once the practice receives these records they are summarised so that everything the GP needs to know about your health is made available on our computer Medical Records.

Currently many practices country wide including our own are using a computer record system called SystmOnline. If a patient moves from one SystmOnline practice to another, all relevant medical information is ready to be seen by the GP on the patient’s screen on the computer as soon as the patient has registered, although paper medical records are still thoroughly checked once they are received later.

NHS England require that the net earnings of doctors engaged in the practice is publicised, and the required disclosure is shown below for 2021/22. However it should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time doctors spend working in the practice, and should not be used to form any judgement about GP earnings, nor to make any comparison with any other practice. All GP practices are required to declare the mean earnings (e.g. average pay) for GPs working to deliver NHS services to patients at each practice. The average pay for GPs working in this practice in the last full financial year was £73,869 before Tax and National insurance. This is for four full time GPs, one part time GPs, three salaried GPs and zero locum GPs who worked in the practice for more than six months.

Blacketts is proud to be a training practice, training junior doctors. GP Registrars are fully qualified doctors gaining specialist training in general practice. They are attached to The Practice for a year and hold clinics in the same way as a GP.

Additionally as an essential part of their training, Student Doctors regularly observe our doctors during consultations. If you do not wish a Medical Student to be present during your consultation or examination then please inform a member of reception or the relevant clinician.

We are committed to giving you the best possible service. This will be achieved by working together.

Patient’s rights

Help us to help you. You have a right to, and the practice will try to ensure that:

• You will be treated with courtesy and respect
• You will be treated as a partner in the care and attention that you receive
• All aspects of your visit will be dealt with in privacy and confidence
• You will be seen by a clinician of your choice, subject to availability
• In an emergency, out of normal opening hours, if you telephone the practice you will be given the number to receive assistance, which will require no more than one further call
• You can bring someone with you, however you may be asked to be seen on your own during the consultation
• Repeat prescriptions will normally be available for collection within two working days of your request
• Information about our services on offer will be made available to you by way of posters, notice boards, newsletters and on our website.
• You have the right to see your medical records or have a copy subject to certain laws. A small fee may be charged to cover costs. If you would like access to health records please see our Medical Records Page

Patient’s responsibilities

With these rights come responsibilities and for patients we would respectfully request that you:

• Treat practice staff and doctors with the same consideration and courtesy that you would like yourself. Remember that they are trying to help you
• Please request home visits before 11.00am, if possible
• Please ensure that you order your repeat medication in plenty of time allowing 48 working hours
• Please ensure that you have a basic first aid kit at home and initiate minor illness and self-care for you and your family
• Please attend any specialist appointments that have been arranged for you or cancel them if your condition has resolved or you no longer wish to attend
• Please follow up any test or investigations done for you with the person who has requested the investigation
• Attend appointments on time and check in with one of our Patient Navigators
• Patients who are more than 10 minutes late for their appointment may not be seen
• If you are unable to make your appointment or no longer need it, please give the practice adequate notice that you wish to cancel. Appointments are heavily in demand and missed appointments waste time and delay more urgent patients receiving the treatment they need
• An appointment is for one person only. Where another family member needs to be seen or discussed, another appointment should be made
• Patients should make every effort to present at the practice to ensure the best use of nursing and medical time. Home visits should be medically justifiable and not requested for social convenience
• Please inform us when you move home, change your name or telephone number, so that we can keep our records correct and up to date
• Read the practice leaflets and other information that we give you. They are there to help you use our services. If you do not understand their content please tell us
• Let us have your views. Your ideas and suggestions whether complimentary or critical are important in helping us to provide a first class, safe, friendly service in pleasant surroundings

The practice fully supports the NHS Zero Tolerance Policy. The aim of this policy is to tackle the increasing problem of violence against staff working in the NHS and ensures that doctors and all other staff have a right to care for others without fear of being attacked or abused.

We understand that ill patients do not always act in a reasonable manner and will take this into consideration when trying to deal with a misunderstanding or complaint. We ask you to treat your doctors and all other staff courteously and act reasonably.

All incidents will be followed up and you will be sent a formal warning after a second incident or removed from the practice list after a third incident if your behaviour has been unreasonable.

However, aggressive behaviour, be it violent or verbal abusive, will not be tolerated and may result in you being removed from The Practice list and, in extreme cases, the Police will be contacted if an incident is taking place and the patient is posing a threat to staff or other patients.

Removal from the practice list

A good patient-doctor relationship, based on mutual respect and trust, is the cornerstone of good patient care. The removal of patients from our list is an exceptional and rare event and is a last resort in an impaired patient-practice relationship. When trust has irretrievably broken down, it is in the patient’s interest, just as much as that of The Practice, that they should find a new practice. An exception to this is on immediate removal on the grounds of violence e.g. when the Police are involved.