Supplementary Privacy Notice – COVID-19
This Privacy Notice is to run alongside our standard Practice Privacy Notice
Due to the unprecedented challenges that the NHS and we, Alexandra Surgery, face due to the worldwide Covid-19 pandemic, there is a greater need for public bodies to require additional collection and sharing of personal data to protect against serious threats to public health.
In order to look after your healthcare needs in the most efficient way we, Alexandra Surgery. may therefore need to share your personal information, including medical records, with staff from other GP Practices including Practices within our Primary Care Network, as well as other health organisations (i.e. Clinical Commissioning Groups, Commissioning Support Units, Local authorities etc.) and bodies engaged in disease surveillance for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
The Secretary of State has served notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) to require organisations to process confidential patient information in the manner set out below for purposes set out in Regulation 3(1) of COPI.
The notice can be seen at Gov: Coronavirus (COVID-19): notification to organisations to share information.
Purpose of this Notice
The purpose of this Notice is to require organisations such as Alexandra Surgery to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI.
This Notice is necessary to require organisations such as Alexandra Surgery to lawfully and efficiently process confidential patient information as set out in Regulation 3(2) of COPI for purposes defined in regulation 3(1), for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
Requirement to Process Confidential Patient Information
The Secretary of State has served notice to recipients under Regulation 3(4) that requires Alexandra Surgery to process confidential patient information, including disseminating to a person or organisation permitted to process confidential patient information under Regulation 3(3) of COPI.
Alexandra Surgery is only required to process such confidential patient information:
Where the confidential patient information to be processed is required for a Covid-19 Purpose and will be processed solely for that Covid-19 Purpose in accordance with Regulation 7 of COPI from 20th March 2020 until end of March 2021 for a Covid-19 Purpose.
A Covid-19 Purpose includes but is not limited to the following:
- Understanding Covid-19 risks and controlling them
- Identifying and understanding information about patients or potential patients with or at risk of Covid-19
- Monitoring and managing the response to Covid-19
- Delivering services to patients, clinicians, health services and adult social care services
- Supporting research and planning
A record will be kept by Alexandra Surgery of all data processed under this Notice.
Sending Public Health Messages
Data protection and electronic communication laws will not stop Alexandra Surgery from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.
It may also be necessary, where the latest technology allows Alexandra Surgery to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.
Visitors to the Practice
We have an obligation to protect our staff and employees’ health, so it is reasonable for staff at Alexandra Surgery to ask any visitors to our practice to tell us if they have visited a particular country, or are experiencing Covid-19 symptoms. This must only be in pre-approved circumstances and we would also ask all patients to consider government advice on the NHS 111 website and not attend the practice.
Where it is necessary for us to collect information and specific health data about visitors to our practice, we will not collect more information than we need, and we will ensure that any information collected is treated with the appropriate safeguards.
Review and Expiry of this Notice
This Notice will be reviewed end of March 2021 and may be extended by The Secretary of State.
Our Data Protection Officer
The Practice has appointed Umar Sabat as its Data Protection Officer.
He can be contacted on the following email address: firstname.lastname@example.org
If you have any concerns about how your data is shared, or if you would like to know more about your rights in respect of the personal data we hold about you, then please contact the Practice Data Protection Officer.
How to contact the appropriate authorities
If you have any concerns about your information is managed then we would encourage you to first speak to our Data Protection Officer in the first instance.
If you are still unhappy following our Data Protection Officer’s review you have the right to lodge a complaint with the Information Commissioners Office at the following address:
Tel: 01625 545745