A collaboration of General Practice Surgeries in Bromley, Biggin Hill, and Locksbottom within the London Borough of Bromley
Privacy Notice: Commissioning, Planning, Risk Stratification, Patient Identification
The records we keep enable us to plan for your care.
This PCN keeps data on you that we apply searches and algorithms to in order to identify from preventive interventions.
This means using only the data we hold or in certain circumstances linking that data to data held elsewhere by other organisations, and usually processed by organisations within or bound by contracts with the NHS.
If any processing of this data occurs outside the PCN your identity will not be visible to the processors. Only this practice will be able to identify you and the results of any calculated factors, such as your risk of having a heart attack in the next 10 years or your risk of being admitted to hospital with a complication of chest disease.
You have the right to object to our processing your data in these circumstances and before any decision based upon that processing is made about you. Processing of this type is only lawfully allowed where it results in individuals being identified with their associated calculated risk. It is not lawful for this processing to be used for other ill-defined purposes, such as “health analytics”.
Despite this we have an overriding responsibility to do what is in your best interests. If we identify you as being at significant risk of having, for example a heart attack or stroke, we are justified in performing that processing to provide you with medical care.
1) Controller Contact Details
Five Elms PCN
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2) Data Protection Officer Contact Details
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3) Purpose of the Processing
The PCN performs computerised searches of some or all of the records our system holds to identify individuals who may be at increased risk of certain conditions or diagnoses i.e., Diabetes, heart disease, risk of falling).
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Your records may be amongst those searched. This is often called “risk stratification” or “case finding”. These searches are sometimes carried out by Processors who link our records to other records that they access, such as hospital attendance records. The results of these searches and assessment may then be shared with other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.
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4) Lawfulness Basis for Processing
The legal basis for this processing is
Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’.
And
Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”
We will recognise your rights under UK Law collectively known as the “Common Law Duty of Confidentiality”
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5) Recipient or Categories of Recipients of the Shared Data
The data will be shared for processing with your own GP practice and for subsequent healthcare with SEL ICS
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6) Rights to object
You have the right under Article 21 of the UK GDPR to object to your personal information being processed. Please contact the PCN if you wish to object to the processing of your data. You should be aware that this is a right to raise an objection which is not the same as having an absolute right to have your wishes granted in every circumstance.
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7) Right to access and correct
The data will be retained for active use during the processing and thereafter according to NHS Policies and the law.
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8) Retention Period
The data will be retained for active use during the processing and thereafter according to NHS Policies and the law.​
9) Right to complain
​You have the right to complain to the Information Commissioner’s Office, you can use this link https://ico.org.uk/make-a-complaint/data-protection-complaints/
or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website)
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There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website)​​​​​​​​
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