Privacy Notice - Appendix A

The Practice will share patient information with these organisations where there is a legal basis to do so.

Commissioning and contractual purposes - Planning Quality and Performance

Purpose

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

Legal Basis

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

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

Processor

Thames Valley 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. The form 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

Research

Purpose

We may share anonymous or pseudonymised 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

NIHR South Central Regional Research Delivery Network (RRDN). 

Individual Funding Requests 

Purpose

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

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

Legal Basis

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

Data processor

Thames Valley ICB

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

Oxfordshire Safeguarding Board - adults

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

Oxfordshire Safeguarding Board - children

Risk Stratification – Preventative Care

Purpose

‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops. 

Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information.

This can help us identify and offer you additional services to improve your health.

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.

Type of Data

Identifiable/Pseudonymised/Anonymised/Aggregate Data

Legal Basis

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

Processors

Thames Valley ICB

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 GOV website.

You can also 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

Oxford Public Health - Oxfordshire County Council

Direct Care

NHS Trusts, Community Providers, Pharmacies, Enhanced care providers, Nursing Homes, Other Care Providers

Purpose

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

Legal Basis

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

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

Processors

Oxford University Hospitals, Oxford Health, Oxford Health NHS Foundation Trust.

Care Quality Commission 

Purpose

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

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

Legal Basis

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

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

Legal Basis

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

Data Processors

Optum, Cerner

Payments  

Purpose

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

GP Clinical System

Purpose

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

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

Legal Basis

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

Processor

EMIS, Docman 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 report 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.

Processor

Solicitors and insurance organisations

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’

Processor

Medicines Optimisation Team – Thames Valley ICB

GP Federation

home visits, urgent care centre, social prescribing, vaccines at home

Purpose

Your medical record will be shared with the Oxford City Primary Care Services (OCPC) 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’

Processor

Oxford City Primary Care Services(OCPC)

Primary Care Network (PCN)

Purpose

Your medical record will be shared with the OX3+ PCN in order that they can provide direct care services to the patient population. 

Legal Basis

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

Processor

Hedena Health and Manor Surgery Group

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

Stop for Life Oxon

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

Oxford City Primary Care Services

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

Oxfordshire Medical Examiners’ Service - c/o Bereavement Office

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 Oxford University Hospitals 

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 – Oxford University Hospitals

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

Bupa, Virgin Care, Aviva etc

Messaging Service

Purpose

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

Legal Basis

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

Provider

AccuRX,  NHSAPP, Emis, Medlink

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

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

Oxford Health, Oxford Foundation Trust, Oxford University Hospitals

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.

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

ICB, NHS England

Shared Care Record

Purpose

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

Learn more about GP Connect

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

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

Legal Basis

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

Processor

NHS England 

Local shared care record 

Thames Valley and Surrey Care Records (TVS)

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

Oxford University Trust & Hospital (HIE)

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

Oxford University Hospital

Transcription services for consultations

Purpose

To provide cloud-based real-time transcription services for patient consultations administered by the practice. This helps the practice to accurately capture the content of patient consultations.

Artificial intelligence (‘AI’) is not used to make diagnoses or automatically action any tasks or next steps, but instead is designed to provide decision support to the end-user, thereby achieving efficiencies and time savings when compared to performing these tasks manually. This involves transcribed data (including patient health data) being processed by Anima’s in-house proprietary data model. All data is encrypted and is stored in the UK.

Coding and actions which are suggested by the AI are accepted/declined, as appropriate, by the user in Anima; once this processing is complete, the document, comments and clinical codes are filed into the EHR.

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 will be asked for consent to use this technology and it will not affect patient care if they decline. 

Processor

Accurx

Self-booking for appointments

Purpose

To provide digital technology to improve patient access to the practice and streamline the appointment booking process. By adopting AccuRx Self Book, patients can book and manage their appointments directly through the digital interface.

The booking module(s) are designed to be user-friendly and secure, ensuring that patients can easily book appointments for specific clinics, e.g. for general consultations, blood tests, and flu clinics, (and all from their own devices).

End to end encryption is used to ensure the privacy and safety of data.

The patient consents by clicking on the link that submits their message to the healthcare professional. By submitting a request the expectation is for them to be contacted by a healthcare professional with next steps, which in this case is a solicited booking.

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

AccuRx

Patient Triage

Purpose

To provide a quick and simple online triage form to triage all routine and urgent appointment requests and to assist you with medical and administrative queries. This can be accessed through the ptactice website, or alternatively via the NHS app as Accurx is automatically integrated with the app.

End to end encryption is used to ensure the privacy and safety of 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’

The patient consents by clicking on the link that submits their triage to the healthcare professional. By submitting a request the expectation is for them to be contacted by a healthcare professional with next steps, which in this case is a solicited booking.

Processor

AccuRx

DA Languages Limited (Dals Limited)

Purpose

The use of DA Languages Limited (Dals Limited) is to provide language services to NHS patients accessing primary care from General Practices, Dental Practices, Pharmacies and Optometrists across BOB. 

Legal Basis

• DPIA section 6(1)e - It is necessary for the performance of a task carried out in the public interest or under official authority vested in the controller.
• DPIA section 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 on the basis of union or member state law or pursuant to contract with a health professional and subject to conditions and safeguards

Processor

A Languages Limited (Dals Limited)

NHS OpenSAFELY Data Analytics Service

Purpose

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

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

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

Legal basis

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

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

Find additional information about OpenSAFELY

Processors

NHS England, The Phoenix Partnership, EMIS

GP Connect

Purpose

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

• GP Connect - NHS England Digital

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

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

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

GP Connect transparency notice - NHS England Digital

Legal Basis

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

Processor:

NHS England

Off-site storage of medical records

Purpose

The practice has contracted the facility of an offsite storage facility to provide secure offsite storage for all Lloyd George medical records. The practice can assure patients that their medical records will remain in control of the practice and robust mechanisms are in place to protect the security of the patient’s personal confidential data.

Legal Basis

The movement and storage of patient records will be undertaken by contractual obligation between the practice and the companies undertaking the work.

• Under UK GDPR Article 6 1(b) contractual obligation
• Article 6 1 (e) Public Task
• Article 9 2 (h) Health data.

Processor

Oasis

Online access

Purpose

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

Legal Basis

UK GDPR:

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

Common Law Duty of Confidentiality (CLDC)

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

Processor

NHS Digital, Optum

EMIS Consultation Writeback

Purpose

Our GP practice uses a system functionality called EMIS consultation writeback. It allows other authorised NHS organisations involved in your direct care to add relevant clinical information directly into your GP record. 

Legal Basis

• Article 6(1)e – Task carried out in the public interest. 
• Article 9(2)h – Provision of Health or Social Care. 

Processor

Optum, GP Connect

Electronic reporting solution – Managed Service

Purpose

The iGPR Electronic Reporting Solution provides GP Practices a solution to manage Subject Access Requests (SARs) under UK GDPR and other requests for information that are received from patients and third parties. The solution integrates directly with the practice clinical system. iGPR acts as a data Processor and securely reviews, prepares and supplies copies of medical records or reports when we as your GP practice are either legally required or when you have given your consent.

Legal Basis: Under GDPR the surgery has used its legal basis of

• Article 6 1(c) it is necessary under a legal obligation to which the controller is subject
• Article 6 1 (e) Public Task - it is necessary for the performance of a task carried out in the public interest or under official authority vested in the controller
• Article 9 2 (a) health data - the data subject has given explicit consent

Processor

iGPR Technologies Ltd

NHSMail and Office 365 (N365 Applications and SharePoint)

Purpose

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

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

Legal Basis:

• Article 6(1)e - “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”;
• Article 9(2)h - “processing is necessary for the purposes of preventive or occupational medicine”;

Processor

Accenture

Sub-processor

Microsoft

Child Health Information Services (CHIS)

Purpose

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

For more information, read the Fair Processing Notice Child Health Information Services

Legal Basis

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

Processor

SCW, Apollo Medical Software Solutions, SystemC

Medlink

Purpose

To support the management of patients’ long-term conditions and routine care through the use of digital tools that:

• Identify patients due for review
• Collect information directly from patients via online questionnaires
• Enable communication between patients and the practice
• Support clinical review, coding, and integration into the patient record

Legal Basis

• Article 6(1)(e) – Public Task - Processing is necessary for the performance of a task carried out in the public interest by the GP practice.
• Article 9(2)(h) – Health or Social Care - Processing of special category data is necessary for the provision and management of health and social care services. 

Processor

• MedLink Solutions Ltd

Octolink

Purpose

To support the delivery of the Community Health and Wellbeing Worker (CHWW) service, including:

• Providing personalised support to patients in their homes and community
• Recording contacts, visits, and interventions
• Coordinating care and signposting to NHS, local authority, and voluntary sector services
• Supporting prevention, early identification, and management of health and wellbeing needs
• Managing and monitoring service activity using digital systems 

Legal Basis

• Article 6(1)(e) – Public Task - Processing is necessary for the performance of a task carried out in the public interest by the GP practice. 
• Article 9(2)(h) – Health or Social Care(applies in practice based on DPIA context) - Processing of special category (health) data is necessary for the provision of health and social care support. 

Processor

OctoLink

Interface – COPD & Asthma reviews

Purpose

To identify and provide clinical review services for patients with COPD and or Asthma by:

• Running searches on the GP clinical system to identify eligible patients
• Screening and inviting patients for review
• Undertaking clinical reviews and documenting outcomes
• Reviewing and updating patient records, including medication and care plans
• Producing anonymised, aggregated data for service evaluation and reporting

Legal Basis

• Article 6(1)(e) – Public Task - Processing is necessary for the performance of a task carried out in the public interest by the GP practice, specifically the provision of NHS clinical care services.
• Article 9(2)(h) – Health or Social Care - Processing of special category (health) data is necessary for the provision of clinical care and treatment for patients with COPD.
• Common Law Duty of Confidentiality - Processing is based on the reasonable expectation that patient information will be accessed by appropriately authorised clinical pharmacists in order to deliver direct care services on behalf of the practice. 

Processor

Interface Clinical Services Ltd

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