General Practice Transparency Notice for GPES Data for Pandemic Planning and Research (COVID-19)
This practice is supporting vital coronavirus (COVID-19) planning and research by sharing your data with NHS Digital.
The health and social care system is facing significant pressures due to the coronavirus (COVID-19) outbreak. Health and care information is essential to deliver care to individuals, to support health, social care and other public services and to protect public health. Information will also be vital in researching, monitoring, tracking and managing the coronavirus outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations. This practice is supporting vital coronavirus planning and research by sharing your data with NHS Digital, the national safe haven for health and social care data in England.
Our legal basis for sharing data with NHS Digital
NHS Digital has been legally directed to collect and analyse patient data from all GP practices in England to support the coronavirus response for the duration of the outbreak. NHS Digital will become the controller under the General Data Protection Regulation 2016 (GDPR) of the personal data collected and analysed jointly with the Secretary of State for Health and Social Care, who has directed NHS Digital to collect and analyse this data under the COVID-19 Public Health Directions 2020 (COVID-19 Direction).
All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the data provision notice issued by NHS Digital to GP practices.
Under GDPR our legal basis for sharing this personal data with NHS Digital is Article 6(1)(c) - legal obligation. Our legal basis for sharing personal data relating to health, is Article 9(2)(g) – substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the COVID-19 Direction.
The type of personal data we are sharing with NHS Digital
The data being shared with NHS Digital will include information about patients who are currently registered with a GP practice or who have a date of death on or after 1 November 2019 whose record contains coded information relevant to coronavirus planning and research. The data contains NHS Number, postcode, address, surname, forename, sex, ethnicity, date of birth and date of death for those patients. It will also include coded health data which is held in your GP record such as details of:
- diagnoses and findings
- medications and other prescribed items
- investigations, tests and results
- treatments and outcomes
- vaccinations and immunisations
How NHS Digital will use and share your data
NHS Digital will analyse the data they collect and securely and lawfully share data with other appropriate organisations, including health and care organisations, bodies engaged in disease surveillance and research organisations for coronavirus response purposes only. These purposes include protecting public health, planning and providing health, social care and public services, identifying coronavirus trends and risks to public health, monitoring and managing the outbreak and carrying out of vital coronavirus research and clinical trials. The British Medical Association, the Royal College of General Practitioners and the National Data Guardian are all supportive of this initiative.
NHS Digital has various legal powers to share data for purposes relating to the coronavirus response. It is also required to share data in certain circumstances set out in the COVID-19 Direction and to share confidential patient information to support the response under a legal notice issued to it by the Secretary of State under the Health Service (Control of Patient Information) Regulations 2002 (COPI Regulations).
Legal notices under the COPI Regulations have also been issued to other health and social care organisations requiring those organisations to process and share confidential patient information to respond to the coronavirus outbreak. Any information used or shared during the outbreak under these legal notices or the COPI Regulations will be limited to the period of the outbreak unless there is another legal basis for organisations to continue to use the information.
Data which is shared by NHS Digital will be subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the coronavirus purpose will be shared. Organisations using your data will also need to have a clear legal basis to do so and will enter into a data sharing agreement with NHS Digital. Information about the data that NHS Digital shares, including who with and for what purpose will be published in the NHS Digital data release register.
For more information about how NHS Digital will use your data please see the NHS Digital Transparency Notice for GP Data for Pandemic Planning and Research (COVID-19).
National Data Opt-Out
The application of the National Data Opt-Out to information shared by NHS Digital will be considered on a case by case basis and may or may not apply depending on the specific purposes for which the data is to be used. This is because during this period of emergency, the National Data Opt-Out will not generally apply where data is used to support the coronavirus outbreak, due to the public interest and legal requirements to share information.
Your rights over your personal data
To read more about the health and care information NHS Digital collects, its legal basis for collecting this information and what choices and rights you have in relation to the processing by NHS Digital of your personal data, see:
Last edited: 14 May 2020 2:10 pm
Patient Privacy Notice
This Privacy Notice explains what information we collect about you, how we store this information, how long we retain it and with whom and for which legal purpose we may share it.
Please click on the link below for further information .
Deputy Director of Information and Acting Data Protection Officer
St Helens and Knowsley Teaching Hospitals NHS Trust
Alexandra Business Park, Court Building, Prescott Road, St Helens,
Tel: 0151 676 5245/5639
Confidentiality & Medical Records
The practice complies with data protection and access to medical records legislation. Identifiable information about you will be shared with others in the following circumstances:
- To provide further medical treatment for you e.g. from district nurses and hospital services.
- To help you get other services e.g. from the social work department. This requires your consent.
- When we have a duty to others e.g. in child protection cases anonymised patient information will also be used at local and national level to help the Health Board and Government plan services e.g. for diabetic care.
If you do not wish anonymous information about you to be used in such a way, please let us know.
Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.
How we use your information
Freedom of Information
Information about the General Practioners and the practice required for disclosure under this act can be made available to the public. All requests for such information should be made to the practice manager.
Access to Records
In accordance with the Data Protection Act 1998 and Access to Health Records Act, patients may request to see their medical records. Such requests should be made through the practice manager. No information will be released without the patient consent unless we are legally obliged to do so.
If you have a complaint or concern about the service you have received from the doctors or any of the staff working in the practice, please let us know.
We operate a practice complaints procedure as part of the NHS system for dealing with complaints. Our complaints system meets national criteria.
We hope that most problems can be sorted out easily and quickly, preferably at the time they arise and with the person concerned. If your problem can not be sorted out in this way and you wish to make a complaint, we would like you to let us know as soon as possible - this will enable us to establish what happened more easily. If it not possible to do that, please let us have details of your complaint.
You may choose to make your complaint orally or in writing
- within 12 months of the incident that caused the problem
- within 6 months of discovering that you have a problem provided this is within 12 months of the incident.
Complaints should be addressed to the Practice Manager, Culcheth Medical Centre at the above address. Alternatively, you may ask for an appointment with the Practice Manager to discuss your concerns.
We will explain the complaints procedure to you and will ensure that your concerns are dealt with promptly. It will be great help if you are as specific as possible about your complaint.
If you wish to discuss your concerns further please contact:
NHS England Contact Centre, PO Box 16738h, Redditch B87 9PT
What we shall do
We shall acknowledge your complaint within 3 working days and aim to have looked into your complaint within 10 working days of the date when you raised it with us. You may then receive a formal reply in writing or you may be invited to meet with us to resolve the issue. If the matter is likely to take longer than this we will let you know and keep you informed as investigations progress.
- Find out what happened and what went wrong
- Make sure you receive an apology, where this is appropriate
- Identify what we can do to make sure the problem does not happen again
If you are complaining on behalf of someone else, we have to know that you have their permission to do so. A note signed by the person concerned will be needed unless they are incapable (because of illness) of providing this.
Where the patient is incapable of providing consent due to illness or accident, it may still be possible to deal with the complaint.
Please provide the precise details of the circumstances which prevent this in your correspondence.
Please note that we keep strictly to the rules of confidentiality.
If you are not satisfied with the practices' response, please refer your complaint to the
The Parliamentary and Health Service Ombudsman, Citygate, Mosley Street, Manchester, M2 3HQ or visit the 'Making a complaint page' at http://www.ombudsman.org.uk/make-a-complaint (to complain online or download a paper form).
Practice Complaints Leaflet
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.
Culcheth Medical Centre Whistleblowing Policy
Practice Protocol for the safe and effective use of AccuRx messaging and video consultations.