Practice Policies & Patient Information

Our staff are committed to providing quality healthcare for the benefit of all of our patients. View our policies to see how this is achieved.

Accessing someone else’s information

As a parent, family member or carer, you may be able to access services for someone else. We call this having proxy access. We can set this up for you if you are both registered with us.

To requests proxy access:

collect a proxy access form from reception from 10am to 6pm

Linked profiles in your NHS account

Once proxy access is set up, you can access the other person’s profile in your NHS account, using the NHS App or website.

The NHS website has information about using linked profiles to access services for someone else.

Chaperones

The Surgery prides itself in maintaining professional standards. For certain examinations during consultations an impartial observer (a “Chaperone”) will be required.

This impartial observer will be a practice Nurse, Health Care Assistant or a member of our reception team who is familiar with the procedure and be available to reassure and raise any concerns on your behalf. If a nurse in unavailable at the time of your consultation then your examination may be re-scheduled for another time.

You are free to decline any examination or chose an alternative examiner or chaperone. You may also request a chaperone for any examination or consultation if one is not offered to you. The GP may not undertake an examination if a chaperone is declined.

The role of a Chaperone:

Maintains professional boundaries during intimate examinations.
Acknowledges a patient’s vulnerability.
Provides emotional comfort and reassurance.
Assists in the examination.
Assists with undressing patients, if required.

Confidentiality

What do we record?

Information about you, your medical treatment, and family background may be recorded, either on paper or in computer files, as part of providing you with health services. This information is vital to the proper operation of the NHS, and is needed to give you and others the best possible healthcare.

What you can do?

Please read the rest of this notice in order to better understand how we use medical information about you.

Other Agencies

The NHS is not the only government service to provide you with care, and it will be necessary for us to provide other agencies with appropriate information, but only with your consent (or that of your relatives if you are too ill).

How do we protect your information?

The sensitivity of patient information is well understood within the NHS. All staff and contractors are trained to respect their duty of confidentiality to you. We keep paper and electronic records securely to prevent unauthorised access or misuse. Wherever practicable, we also remove references to personal details such as your name and address, and often restrict it further to reduce the chances of anyone identifying a record as relating to you.

Other questions?

You can have a say in how the NHS uses information about you. If you want to find out more or have any concerns you can phone NHS Direct on 0845 4647 and request a booklet giving more details; go online at www.nhs.uk\confidentiality; or you can contact the Patient Liaison Team at the following address: Bromley CCG, Beckenham Beacon, BR3 3QL. Tel. No. 01689 866544

Freedom of Information

The ICO has published a new Model Publication Scheme that all public authorities are required to adopt by 1st January 2009.

Model Publication Scheme – further information

How information about you helps us to provide better care.

Confidential information from your medical records can be used by the NHS to improve the services offered so we can provide the best possible care for everyone. This information along with your postcode and NHS number but not your name, are sent to a secure system where it can be linked with other health information. This allows those planning NHS services or carrying out medical research to use information from different parts of the NHS in a way which does not identify you. You have a choice. If you are happy for your information to be used in this way you do not have to do anything. If you have any concerns or wish to prevent this from happening, please see the leaflet “How information about you helps us to provide better care” in the waiting Room.

Useful Websites

Confidentiality NHS Code of Practice
• Confidentiality and Mental Health
• Confidentiality Guidance

Freedom of Information

The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:

Have a publication scheme in place
Allow public access to information held by public authorities.

The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.

Public authorities include government departments, local authorities, the NHS, state schools and police forces.

The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.

The Surgery publication scheme

A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:

who we are and what we do
what we spend and how we spend it
what our priorities are and how we are doing it
how we make decisions
our policies and procedures
lists and registers
the services we offer

You can request our publication scheme leaflet at the surgery.

Who can request information?

Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use.

How should requests be made?

Requests must:

be made in writing (this can be electronically e.g. email/fax)
state the name of the applicant and an address for correspondence
describe the information requested.

What cannot be requested?

Personal data about staff and patients covered under Data Protection Act.

For more information see these websites:

General Data Protection Regulation

GP surgeries in Bromley work hard to provide the public and patients with clear and accurate information relating to how their personal information is used. Privacy Notices are put in place on the Bromley Clinical Commissioning Group website to inform service users of these uses of data by your GP surgery.

Please find further information regarding privacy notices here.

GDPR Privacy Notice

The Park Practice keeps data on you relating to who you are, where you live, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care. When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS data. GPs have always delegated tasks and responsibilities to others that work with them in their surgeries, on average an NHS GP has between 1,500 to 2,500 patients for whom he or she is accountable. It is not possible for the GP to provide hands on personal care for each and every one of those patients in those circumstances, for this reason GPs share your care with others, predominantly within the surgery but occasionally with outside organisations. If your health needs require care from others elsewhere outside this practice we will exchange with them whatever information about you that is necessary for them to provide that care. When you make contact with healthcare providers outside the practice but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all of those reports. Normally we will receive equivalent reports of contacts you have with non NHS services but this is not always the case. Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law. People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments, the practice nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst the GP you see or speak to will normally have access to everything in your record. You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests. Please see below. We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.
1) Data Controller contact details	The Park Practice, Oaks Park Medical Centre 17 Oakfield Road, London, SE20 8QA Tel: 020 8778 8027 Email: [email protected]
2) Data Protection Officer contact details	David Bennett
3) Purpose of the processing	Direct Care is care delivered to the individual alone, most of which is provided in the surgery. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the 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.
4) Lawful basis for processing	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 and 9 conditions of the 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…’. 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 also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”^*
5) Recipient or categories of recipients of the processed data	The data will be shared with Health and care professionals and support staff in this surgery and at hospitals, diagnostic and treatment centres who contribute to your personal care. This will include but is not exclusively Princess Royal University Hospital, Orpington Hospital, Beckenham Beacon, Kings College Hospital, Croydon University Hospital, University Hospital Lewisham.
6) Rights to object	You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.
7) Right to access and correct	You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.
8) Retention period	The data will be retained in line with the law and national guidance – https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016 or speak to the practice.
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/global/contact-us/ 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)

* “Common Law Duty of Confidentiality”, common law is not written out in one document like an Act of Parliament. It is a form of law based on previous court cases decided by judges; hence, it is also referred to as ‘judge-made’ or case law. The law is applied by reference to those previous cases, so common law is also said to be based on precedent.

The general position is that if information is given in circumstances where it is expected that a duty of confidence applies, that information cannot normally be disclosed without the information provider’s consent.

In practice, this means that all patient information, whether held on paper, computer, visually or audio recorded, or held in the memory of the professional, must not normally be disclosed without the consent of the patient. It is irrelevant how old the patient is or what the state of their mental health is; the duty still applies.

Three circumstances making disclosure of confidential information lawful are:

where the individual to whom the information relates has consented;
where disclosure is in the public interest; and
where there is a legal duty to do so, for example a court order.

GP Earnings

How We Use Your Information

To Provide You with Treatment

Doctors need to make notes about any diagnosis, test results, treatments including drugs prescriptions, and other information that you may provide, that seems relevant to the treatment of your condition. We need to keep this information in order to provide proper care for you (for later treatment, or if you should be seen by another doctor) and to allow others to check the treatment that you have received.

Nurses and other health professionals also need access to these records, and will add their own notes, as part of the overall healthcare provision. Secretaries, receptionists, and other clerical staff need access to some of your records in order to do administrative tasks, such as: booking appointments and communicating with you and other parts of the NHS.

Your doctor may also need to provide information under certain Acts of Parliament (e.g. the Communicable Diseases Act 1978, which is necessary to prevent the outbreak of certain highly contagious diseases) to protect you and others.

The Health Service

In order to manage the NHS, some restricted information concerning treatments, drugs prescribed, numbers of patients seen etc. is needed, and hospitals and general practices must provide this information in returns to various central bodies. This information has personal details such as your name and address removed wherever possible. It is necessary from time to time to check these returns to prevent fraud as part of the NHS’s statutory obligations. This may result in your being contacted by an NHS Fraud Office to see if you will consent to your records being checked. Only if you provide your consent will the auditors be allowed to access your records.

Teaching Clinicians

Some medical files are needed to teach student clinicians. Without such materials, new doctors and nurses would be not be properly prepared to treat you.

Planning

We need to be able to plan ahead about treatments, patient numbers, etc., but this uses summary information, not personal information.

Medical Research

Some medical research will require your direct involvement (especially if taking part in clinical trials) in which case the circumstances will be fully explained to you, and your express consent required. If you do not consent, then you will not be included in the trial.

Other researchers only require access to medical statistics, and can greatly improve our understanding of health, and how to treat patients more effectively. Generally, researchers only need information about groups of people, so that no individual information is apparent. In some cases, they need individual records, but wherever we can we will provide these in an anonymous form (so individuals cannot be identified). Sometimes, researchers need access to individual medical files. We will contact you first for your consent (and before this the researchers must present their case before an Ethics Committee to check that their research is appropriate and worthwhile). Rarely, it may not be practicable (or even possible) to contact individuals for their consent, in which case the researchers must make their case before a Confidentiality Committee to show that there is enough benefit to the public at large to justify this.

How do we manage your information?

We need to be able to move electronic information from system to system, extracting the data and modifying it for the next system. Occasionally, tests will need to be made on the data to check that it has been transferred correctly. This will only be done under carefully controlled conditions and all employees and contractors will be under strict contractual obligations to protect your confidentiality.

Infection Control Statement

We aim to keep our surgery clean and tidy and offer a safe environment to our patients and staff. We are proud of our modern, purpose built Practice and endeavour to keep it 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

Named GP

Privacy Notice – Accurx

As part of the Digital First National programme of work, GP Practices are required to provide a tool for patients to access primary care services. The aim of the Accurx platform is to improve communications between healthcare staff and patients resulting in improved outcomes and productivity. The platform facilitates digital communications between the practice and our patients. Using the Accurx platform will require the processing of special category data by Accurx, their sub-processors and by default the GP Practice as a Controller. This will include; exchanging and storing messages in relation to patients and medical staff, performing video consultations (these will not be recorded or stored) between healthcare staff and their patients This will allow you to respond to the Practice in multiple ways such as; free text, questionnaires and submitting images/documents. If you have a non-urgent healthcare concern or need to contact the Practice for any medical or admin reason, click on the online via our website or via NHS app or via NHS website. Fill out the online form, which will then be reviewed and processed by our healthcare professionals to decide the right care for you. We will respond to online requests within 2 working days for medical queries and 5 working days for admin queries. Accurx is approved by NHS England to be used by GP practices and the other systems involved in patient care. NHS England has a lengthy assurance process to make sure they meet the highest standards of safety and security. Your data is safe and is shared only with your GP Practice for the purposes of your direct care. Your data is stored and sent securely using industry best practices, and Accurx only collect the data that is necessary to allow your GP Practice to provide you with care. The Practice uses the following Accurx features: · Online consultations · Video consultations · AccuMail · SMS · Friends and Family test · Record Views The Accurx privacy notice can be found on their website here: Accurx \| Privacy Policy.
1) Controller contact details	Park Group Practice
2) Data Protection Officer contact details	GP Data Protection Officer [email protected]
3) Purpose of the processing	The aim of the Accurx platform is to improve communications between healthcare staff and patients resulting in improved outcomes and productivity. The platform facilitates digital communications between the practice and our patients.
4) Lawful basis for processing	Under UK GDPR and DPA 2018 – 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’. 9(2)(h) ‘…medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems…’
5) Recipient or categories of recipients of the shared data	Data may be shared with Accurx, and their sub-processors such as cloud services used for Accurx’ own storage, communications, security, engineering, and similar purposes.
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 Practice 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.
7) Right to access and correct	You have the right to access copies of the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.
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 us about the way your data is handled or processed. To so, please contact the Practice using the following details: Park Group Practice 17-19 Oakfield Road, Penge SE20 8QA If you remain unsatisfied with our response, you have a right to complain to the Information Commissioner’s Office. To do so, you can use this link https://ico.org.uk/make-a-complaint/data-protection-complaints/ or call 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).

Statement of Intent

New contractual requirements came into force from 1 April 2014 requiring that GP Practices should make available a statement of intent in relation to the following IT developments:

Summary Care Record (SCR)
GP to GP Record Transfers
Patient Online Access to Their GP Record
Data for commissioning and other secondary care purposes

The same contractual obligations require that we have a statement of intent regarding these developments in place and publicised by 30 September 2014.

Please find below details of the practices stance with regards to these points.

Summary Care Record (SCR)

NHS England require practices to enable successful automated uploads of any changes to patient’s summary information, at least on a daily basis, to the summary care record (SCR) or have published plans in place to achieve this by 31st of March 2015.

Having your Summary Care Record (SCR) available will help anyone treating you without your full medical record. They will have access to information about any medication you may be taking and any drugs that you have a recorded allergy or sensitivity to.

Of course, if you do not want your medical records to be available in this way then you will need to let us know so that we can update your record. You can do this via the opt out form.

The practice confirms that your SCR is automatically updated on at least a daily basis to ensure that your information is as up to date as it can possibly be.

GP to GP Record Transfers

NHS England require practices to utilise the GP2GP facility for the transfer of patient records between practices, when a patient registers or de-registers (not for temporary registration).
It is very important that you are registered with a doctor at all times. If you leave your GP and register with a new GP, your medical records will be removed from your previous doctor and forwarded on to your new GP via NHS England. It can take your paper records up to two weeks to reach your new surgery.

With GP to GP record transfers your electronic record is transferred to your new practice much sooner.

The practice confirms that GP to GP transfers are already active and we send and receive patient records via this system.

Patient Online Access to Their GP Record

NHS England require practices to promote and offer the facility to enable patients online access to appointments, prescriptions, allergies and adverse reactions or have published plans in place to achieve this by 31st of March 2015.

We currently offer the facility for booking and cancelling appointments and also for ordering your repeat prescriptions and viewing a summary of your medical records on-line. If you do not already have a user name and password for this system – please register your interest with our reception staff.

Data for commissioning and other secondary care purposes

It is already a requirement of the Health and Social Care Act that practices must meet the reasonable data requirements of commissioners and other health and social care organisations through appropriate and safe data sharing for secondary uses, as specified in the technical specification for care data.

At our practice we have specific arrangements in place to allow patients to “opt out” of care.data which allows for the removal of data from the practice. Please see the page about care data on our website

The Practice confirm these arrangements are in place and that we undertake annual training and audits to ensure that all our data is handled correctly and safely via the Information Governance Toolkit.

Suggestions, Comments and Complaints

We make every effort to give the best service possible to everyone who attends our practice.

In the majority of cases the best way to resolve your concerns as quickly as possible is with the front line staff or the service or organisation that you are complaining about.

However, we are aware that things can go wrong resulting in a patient feeling that they have a genuine cause for complaint. If this is so, we would wish for the matter to be settled as quickly, and as amicably, as possible.

Simply contact the Practice Manager preferably in writing via our Contact Us page or by completing a complaints form available in surgery, and she/he will set all the necessary wheels in motion. Alternatively please visit our feedback feedback form if you have any suggestions below.

We are continually striving to improve our service. Any helpful suggestions would be much appreciated and a suggestion box is located in the waiting area.

Summary Care Records

About your Summary Care Record

Your Summary Care Record contains important information about any medicines you are taking, any allergies you suffer from and any bad reactions to medicines that you have previously experienced.

Allowing authorised healthcare staff to have access to this information will improve decision making by doctors and other healthcare professionals and has prevented mistakes being made when patients are being cared for in an emergency or when their GP practice is closed.

Your Summary Care Record also includes your name, address, date of birth and your unique NHS Number to help identify you correctly.

You may want to add other details about your care to your Summary Care Record. This will only happen if both you and your GP agree to do this. You should discuss your wishes with your GP practice.

Healthcare staff will have access to this information, so that they can provide safer care, whenever or wherever you need it, anywhere in England.

FAQs

Who can see my Summary Care Record?

Healthcare staff who have access to your Summary Care Record:

need to be directly involved in caring for you
need to have an NHS Smartcard with a chip and passcode
will only see the information they need to do their job and
will have their details recorded every time they look at your record

Healthcare staff will ask for your permission every time they need to look at your Summary Care Record. If they cannot ask you (for example if you are unconscious or otherwise unable to communicate), healthcare staff may look at your record without asking you, because they consider that this is in your best interest.

If they have to do this, this decision will be recorded and checked to ensure that the access was appropriate.

What are my choices?

You can choose to have a Summary Care Record or you can choose to opt out.

If you choose to have a Summary Care Record and are registered with a GP practice, you do not need to do anything as a Summary Care Record is created for you.

If you choose to opt out of having a Summary Care Record and do not want a SCR, you need to let your GP practice know by filling in and returning an opt-out form which can be obtained from your GP practice.

If you are unsure if you have already opted out, you should talk to the staff at your GP practice.

You can change your mind at any time by simply informing your GP and they can create a Summary Care Record for you.

Children and the Summary Care Record

If you are the parent or guardian of a child under 16, you should make this information available to them and support the child to come to a decision as to whether to have a Summary Care Record or not.

If you believe that your child should opt-out of having a Summary Care Record, we strongly recommend that you discuss this with your child’s GP. This will allow your child’s GP to highlight the consequences of opting-out, prior to you finalising your decision.

Where can I get more information?

For more information about Summary Care Records you can:

talk to the staff at your GP practice
phone the Health and Social Care Information Centre on 0300 303 5678
Read the Summary Care Record patient information

Zero Tolerance

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 their 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 their 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 Surgery, 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.

Removing other members of the household

In rare cases, however, because of the possible need to visit patients at home it may be necessary to terminate responsibility for other members of the family or the entire household. The prospect of visiting patients where a relative who is no longer a patient of the practice by virtue of their unacceptable behaviour resides, or being regularly confronted by the removed patient, may make it too difficult for the practice to continue to look after the whole family. This is particularly likely where the patient has been removed because of violence or threatening behaviour and keeping the other family members could put doctors or their staff at risk.