If you would like to give us any feedback or wish to make a complaint, please contact the Practice to speak to our Patient Experience Manager

We are committed to protecting your privacy. You can access our website without giving us any information about yourself. But sometimes we do need information to provide services that you request, and this statement of privacy explains data collection and use in those situations.

In general, you can visit our web site without telling us who you are and without revealing any information about yourself. However there may be occasions when you choose to give us personal information, for example, when you choose to contact us or request information from us. We will ask you when we need information that personally identifies you or allows us to contact you.

We collect the personal data that you may volunteer while using our services. We do not collect information about our visitors from other sources, such as public records or bodies, or private organisations. We do not collect or use personal data for any purpose other than that indicated below:

• To send you confirmation of requests that you have made to us
• To send you information when you request it.

We intend to protect the quality and integrity of your personally identifiable information and we have implemented appropriate technical and organisational measures to do so. We ensure that your personal data will not be disclosed to State institutions and authorities except if required by law or other regulation.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should be aware that we don’t have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites.

Our website and the services it enables are provided by Silicon Practice. Silicon Practice is a data processor which means that they will only process your personal data on the instruction of the practice, the data controller, unless otherwise required by law. The practice has entered into a data processing agreement with Silicon Practice which is a binding contract setting out the obligations of each party in relation to the processing of personal data.

If you would like to find out more about Silicon Practice you can access details of how they protect data and deliver services in their Data Processing Agreement.

The NHS operate a zero tolerance policy with regard to violence and abuse and the practice has the right to remove violent patients from the list with immediate effect in order to safeguard practice staff, patients and other persons. Violence in this context includes actual or threatened physical violence or verbal abuse which leads to fear for a person’s safety.

In this situation we will notify the patient in writing of their removal from the list and record in the patient’s medical records the fact of the removal and the circumstances leading to it.

Our staff work under constraints whilst endeavouring to offer the best possible service with the resources and facilities available.

There is a Central NHS Computer System called the Summary Care Record (SCR).

It is an electronic record which contains information about the medicines you take, allergies you suffer from and any bad reactions to medicines you have had.

Why Do I Need A Summary Care Record?

Storing information in one place makes it easier for healthcare staff to treat you in an emergency, or when your GP practice is closed. Please visit our Opening Hours Page.

This information could make a difference to how a doctor decides to care for you, for example which medicines they choose to prescribe for you.

Who Can See It?

Only healthcare staff involved in your care can see your Summary Care Record.

How Do I Know If I Have One?

Over half of the population of England now have a Summary Care Record.

Do I Have To Have One?

No, it is not compulsory.

If you choose to opt out of the scheme, then you will need to complete a Summary Care Record Opt-Out form to let the surgery know.

More Information

For further information visit the NHS Care records website.

Click here to view our Statement of purpose policy

This privacy notice is to run alongside our standard practice Privacy Notice.

Due to the unprecedented challenges that the NHS and we, Tower Hill Partnership Medical practice 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, Tower Hill Partnership Medical Practice 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 (ie 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.

Purpose of this Notice

The purpose of this Notice is to require organisations such as Tower Hill Partnership Medical Practice 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 Tower Hill Partnership Medical Practice to lawfully and efficiently process confidential patient information as set out in Regulation 3(2) of COPI for purposes defined in regulation 3(1)

Requirement to Process Confidential Patient Information

The Secretary of State has served notice to recipients under Regulation 3(4) that requires Tower Hill Partnership Medical Practice to process confidential patient information, including disseminating to a person or organisation permitted to process confidential patient information under Regulation 3(3) of COPI.

Tower Hill Partnership Medical Practice 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 20^th March 2020 until 31^st March 2021.

Covid-19 Purpose.

A Covid-19 Purpose includes but is not limited to the following:

• Understanding Covid-19 and risks to public health, trends in Covid-19 and such risks, and controlling and preventing the spread of Covid-19 and such risks.
• Identifying and understanding information about patients or potential patients with or at risk of Covid-19, information about incidents of patient exposure to Covid-19 and the management of patients with or at risk of Covid-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from Covid-19.
• Understanding information about patient access to health services and adult social care services and the need for wider care of patients and vulnerable groups as a direct or indirect result of Covid-19 and the availability and capacity of those services or that care.
• Monitoring and managing the response to Covid-19 by health and social care bodies and the Government including providing information to the public about Covid-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services.
• Delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with Covid-19, including the provision of information, fit notes and the provision of health care and adult social care services.
• Research and planning in relation to Covid-19.

Summary Care Records

Summary Care Records (SCR) are an electronic record of important patient information, created from the GP medical records held at Tower Hill Partnership Medical Practice. They can be seen and used by authorised staff who work in other areas of the health and care system who are involved in your direct care. Patients who have already consented to having additional information added to their SCR will have additional information shared, which will include Anticipatory Care Plans for vulnerable, frail or elderly patients, although particularly sensitive information will not be automatically included in the sharing. The SCR will help a wide variety of organisation in response to COVID-19, as detailed above.

Recording of processing

A record will be kept by Tower Hill Partnership Medical Practice of all data processed under this Notice.

Sending Public Health Messages

Data protection and electronic communication laws will not stop Tower Hill Partnership Medical Practice from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.

Digital Consultations

It may also be necessary, where the latest technology allows Tower Hill Partnership Medical Practice 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.

e-Consult Online Consultations

Tower Hill Partnership Medical Practice uses eConsult as an online tool, enabling our GPs to provide consultations online to patients, meaning they do not have to come into the practice to have an appointment.  Due to a collaboration between NHS England and NHSX, eConsult is now available through the NHS App.  This integration means that NHS App users that are registered Tower Hill Partnership Medical Practice using the eConsult solution will be able to go through an eConsult appointment with a GP from within the NHS App. For the purposes of GDPR, Tower Hill Partnership Medical Practice and NHS England will act as Joint Data Controllers for the provision of the integrated service provided by eConsult via the NHS App. The NHS App is provided by NHS Digital, so both NHS Digital and eConsult will be Processors for this service.

Visitors to The Practice

We have an obligation to protect our staff and employees’ health, so it is reasonable for staff at Tower Hill Partnership Medical Practice 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 on or before 31^st March 2021 and may be extended by The Secretary of State. If no further notice is sent to Tower Hill Partnership Medical Practice by The Secretary of State this Notice will expire on 31^st March 2021.

What is a Privacy Notice?

A Privacy Notice (or ‘Fair Processing Notice’) is an explanation of what information the practice collects on patients, and how it is used. Being transparent and providing clear information to patients about how a practice uses their personal data is an essential requirement of the Data Protection Act 2018.

Under the DPA, the first principle is to process personal data in a fair and lawful manner, and applies to everything that is done with patient’s personal information. In practice, this means that the practice must;

• Have legitimate reasons for the use or collection of personal data
• Not use the data in a way that may cause adverse effects on the individuals (e.g. improper sharing of their information with 3^rd parties)
• Be transparent about how you the data will be used, and give appropriate privacy notices when collecting their personal data
• Handle personal data only as reasonably expected to do so
• Make no unlawful use of the collected data

Fair Processing

Personal data must be processed in a fair manner – the DPA says that information should be treated as being obtained fairly if it is provided by a person who is legally authorised or required to provide it. Fair Processing means that the practice has to be clear and open with people about how their information is used.

Providing a ‘Privacy Notice’ is a way of stating the practice’s commitment to being transparent and is a part of fair processing, however you also need to consider the effects of processing on the individuals and patients concerned;

• What information are we collecting?
• Who collects the data?
• How is it collected?
• Why do we collect it?
• How will we use the data?
• Who will we share it with?
• What is the effect on the individuals?
• If we use it as intended, will it cause individuals to object or complain?

Conducting a Privacy Impact Assessment is an effective way of assessing whether you can safely collect or use patient data according to the DPA and Information Governance requirements. The Information Commissioners’ Office has published guidance on carrying out a PIA.

Data Controllers

Under the Data Protection Act, the data controller is the person or organisation that will decide the purpose and the manner in which any personal data will be processed – they have overall control of the data they collect, and decide how and why it will be processed.

A GP practice is a data controller for the patient information it collects, and should already have data processing arrangements with third parties (e.g. IT systems providers) to ensure they do not use or access data unlawfully; the data controllers will have ultimate responsibility for the practices’ compliance with the DPA.

Risk Stratification

This is a process to identify and manage patients that are more likely to need secondary care – information is collected in order to assess their ‘Risk Score’ and is sent to NHS organisations to assess and return the results to the GP practice. This is an acceptable way of assessing patients’ needs and prevent ill health, however, it is also regarded as a disclosure of personal information, and patients have the option to opt out of any data collection at the practice, and needs to be made clear to them.

Invoice Validations

If a patient has had NHS treatment, their personal information may be shared within a secure and confidential environment to determine which CCG should pay for the treatment received. This means sharing identifiable information such as name, address, date of treatment etc. to enable the billing process.

Partner Organisations

If the practice shares information with any external organisations (within or outside the NHS), then let patients know by listing them. Partner organisations will usually include NHS organisations (hospitals, CCGs, NHS England etc.) other public sectors (Education, Police, Fire etc.) and any other Data Processors that may be carrying out specific project work with the practice (e.g. Diabetes UK).

Public Health England

Patient information is shared from time to time with Public Health England – From 02/12/16 information regarding Latent TB will be shared with Public Health England, the information will help them see how well they are reaching people at risk of latent TB, this will hep to protect your community. Only relevant outcomes that cannot identify you will be shared.

Head of Public Accountability
Public health England
Wellington House
133-155 Waterloo Road
London
SE1 8UG

Data Protection Privacy Notice for Patients

Introduction

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you.

This privacy notice applies to personal information processed by or on behalf of the practice.

This notice explains

• Who we are, how we use your information and our Data Protection Officer
• What kinds of personal information about you do we process?
• What are the legal grounds for our processing of your personal information (including when we share it with others)?
• What should you do if your personal information changes?
• For how long your personal information is retained by us?
• What are your rights under data protection laws?

The General Data Protection Regulation (GDPR) became law on 24th May 2016. This is a single EU-wide regulation on the protection of confidential and sensitive information. It enters into force in the UK on the 25th May 2018, repealing the Data Protection Act (1998).

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the Data Protection Act 2018 (currently in Bill format before Parliament) the practice responsible for your personal data is Tower Hill Partnership.

This Notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights

How we use your information and the law

Tower Hill Partnership Medical practice will be what’s known as the ‘Controller’ of the personal data you provide to us.

We collect basic personal data about you which does not include any special types of information or location-based information.  This does however include name, address, contact details such as email and mobile number etc.

We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare setting) ethnicity, and sex during the services we provide to you and or linked to your healthcare through other health providers or third parties.

Why do we need your information?

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which the practice hold about you may include the following information;

• Details about you, such as your address, carer, legal representative, emergency contact details
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
• Notes and reports about your health
• Details about your treatment and care
• Results of investigations such as laboratory tests, x-rays etc
• Relevant information from other health professionals, relatives or those who care for you

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.

How do we lawfully use your data?

We need to know your personal, sensitive and confidential data in order to provide you with Healthcare services as a General Practice, under the General Data Protection Regulation we will be lawfully using your information in accordance with: –

• Article 6, 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, (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

This privacy notice applies to the personal data of our patients and the data you have given us about your carers/family members.

Risk Stratification

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP practice. A risk score is then arrived at through an analysis of your de-identified information is only provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way.

Medicines Management

The practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• Data Protection Act 2018
• The General Data Protection Regulations 2016
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management
• Information: To Share or Not to Share Review

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.

We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles.

Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.

All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary.  If a sub-contractor acts as a data processor for Tower Hill Partnership Medical Practice an appropriate contract (art 24-28) will be established for the processing of your information.

In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent.  If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.

Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose in an identifiable format.   In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes.

With your consent we would also like to use your information to…

We would however like to use your name, contact details and email address to inform you of services that may benefit you, with your consent only.  There may be occasions were authorised research facilities would like you to take part on innovations, research, improving services or identifying trends.

At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place.

This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO as below.

Where do we store your information Electronically?

All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.

No 3rd parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place.  We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;

• NHS Trusts / Foundation Trusts
• GP’s
• NHS Commissioning Support Units
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• NHS England (NHSE) and NHS Digital (NHSD)
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Voluntary Sector Providers
• Private Sector Providers
• Other ‘data processors’ which you will be informed of

You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.

We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.  All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for Tower Hill Partnership Medical Practice an appropriate contract (art 24-28) will be established for the processing of your information.

How long will we store your information?

We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.

More information on records retention can be found online on the NHS Digital website.

How can you access, amend move the personal data that you have given to us?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes

Access to your personal information

Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:

• Your request should be made to the Practice – for information from the hospital you should write direct to them
• There is no charge to have a copy of the information held about you
• We are required to respond to you within one month
• You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.

What should you do if your personal information changes?

You should tell us so that we can update our records please contact the practice as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.

Objections / Complaints

Should you have any concerns about how your information is managed at the GP, please contact the GP practice Manager or the Data Protection Officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.

Information Commissioner:

Wycliffe house
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 01625 545745
Website: www.ico.org.uk

If you are happy for your data to be extracted and used for the purposes described in this privacy notice, then you do not need to do anything.  If you have any concerns about how your data is shared, then please contact the practice Data Protection Officer.

If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.

Data Protection Officer

Any queries in regard to Data Protection issues should be addressed to:

DPO – Judith Jordan, Head of Integrated Governance
NHS Arden and Greater East Midlands
Westgate House
Market Street
Warwick
CV34 4DE

Tel: 0121 611 0730
Email: agem.dpo@nhs.net

Changes

It is important to point out that we may amend this Privacy Notice from time to time.  If you are dissatisfied with any aspect of our Privacy Notice, please contact the practice Data Protection Officer.

Some services provided are not covered under our contract with the NHS and therefore attract charges.

Examples include the following:

• Medicals for pre-employment, sports and driving requirements (HGV, PSV etc.)
• Insurance claim forms
• Prescriptions for taking medication abroad
• Private sick notes
• Vaccination certificates

The practice charges range from £30 – £40 per half hour of work required, this may vary depending on the complexity of work required to complete requests.

The fees charged are based on the British Medical Association (BMA) suggested scales and our reception staff will be happy to advise you about them along with appointment availability.

Click here to view a full statement of private and non-NHS fees.

We have allocated a named accountable GP for all of our registered patients. If you do not know who your named GP is, please complete our Contact The Practice Form.

Unfortunately, we are unable to notify patients in writing of any change of GP due to the costs involved.

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 Tower Hill Partnership in the 2023/24 financial year was £91,309 before tax and National Insurance. This is for 5 full time GPs and 4 part time GPs who worked in the practice for more than 6 months.