It is the policy of this practice to respect the privacy, dignity, religious and cultural beliefs of our patients.

If you feel you would like a chaperone to be present during a physical examination by a doctor or any other health professional you may be consulting at the surgery (or if you prefer to be examined by a doctor or health professional of the same sex as yourself) please let us know and we will do our best to comply with your wishes.

How do we maintain the confidentiality of your records?

Should you have any concerns about how your information is managed or wish to object to any of the data collection at the Practice, please contact the Practice Manager or your healthcare professional to discuss how the disclosure of your personal information can be restricted. All patients have the right to change their minds and reverse a previous decision. Please contact the practice if you change your mind regarding any previous choice.

If you would like to make a ‘data subject access request’ please contact the practice in writing. We will endeavour to respond to your request within one calendar month or two months if the request is complex.

Any changes to this notice will be published on our website and on the Practice notice board.

Suspected breaches in data protection can be reported to the independent OHP Data Protection Officer Naomi Frazer or Leanne Hoye on 0121 422 1366. Breaches in data protection will result in an incident investigation. Serious breaches will be reported to the ICO.

It is the responsibility of all employees of the practice to report suspected breaches of information security to the Practice lead and Data Protection Officer without delay.

The Practice is registered as a data controller with the ICO. The registration number is ZA188128 and can be viewed online in the public register at: ico.org.uk. You can contact the ICO on 0303 123 1113 or via email ico.org.uk/global/contact-us/email/ or at the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

We always try to provide the best services possible, but there may be times when you feel this has not happened. The following information explains our in-house complaints procedure, drawn up to respond to patient grievances. Our practice procedure is not able to deal with questions of legal liability or compensation. We hope you will use it to allow us to look into and, if necessary, correct any problems that you have identified, or mistakes that have been made. If you use this procedure it will not affect your right to complain to the Birmingham Primary Care Shared Services Agency (formerly Birmingham Health Authority). Please note that we have to respect our duty of confidentiality to patients and a patient’s consent will be necessary if a complaint is not made by the patient in person. If you wish to make a complaint, please telephone or write to our practice manager. Full details will be taken and a decision made on how best to undertake the investigation.

We believe it is important to deal with complaints swiftly, so you will be offered an appointment for a meeting to discuss the details within seven days. Occasionally it may take longer, but we will keep you informed throughout. You may bring a friend or relative with you to the meeting. We will try to address your concerns, provide you with an explanation and discuss any action that may be needed.

F.A.O Trevorlyn Kerr – Practice Manager

Swan Medical Centre
4 Willard road
Yardley
Birmingham
Postcode B25 8AA
Telephone: 0121 706 0337 or 3957

Complaint Procedure

On 25 May 2018, the General Data Protection Regulation (GDPR)  will be enforced across Europe, including the UK. The law aims to give citizens more control over their data and to create a uniformity of rules to enforce across the continent.

• GDPR leaflet
• Access to Service Information
• Equality Act 2010
• What are PECR? | ICO

All GP practices are required to declare the mean earnings (e.g. average pay) for GP’s working to deliver NHS services to patients at each practice.

The average pay for GP’s working at the Swan Medical Centre in the last financial year was £99,754.40 before tax and national insurance. This is for 4 full time GPs.

All earnings reported are pre-tax, national insurance (NI) and employee pension contributions and the figures are net of practice expenses incurred.

If you have received treatment within the NHS, access to your personal information may be required to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.

This information would most likely include information such as your name, address, date of treatment and may be passed on to enable the billing process. These details are held in a secure environment and kept confidential. This information will only be used to validate invoices and will not be shared for any further purposes.

Section 54 of the UK Modern Slavery Act (2015) requires commercial organisations operating in the UK with an annual turnover in excess of £36m to produce a ‘slavery and human trafficking statement for each financial year of the organisation’.

Organisational Structure and Business

Our Health Partnership is one of the UK’s biggest GP partnerships. It brings together 52 surgeries in the Midlands and Shropshire. By using our shared expertise to tackle the challenges of GP practice today, we can keep local surgeries thriving and provide the excellent care that our patients need now and into the future.

Our approach to slavery and human trafficking

We are committed to tackling modern slavery within every part of our business and its supply chains. Our Anti-slavery statement, in combination with the establishment of effective policies, demonstrates our commitment to the issue of modern slavery and ensures that appropriate and coordinated action is taken throughout the business.

Due diligence

We have taken action to understand and address the risks of modern slavery within our operations, including:

• The development of robust processes around whistleblowing, grievance, disciplinary and bullying and harassment policies, to provide both staff and patients with assurance that modern slavery concerns will be raised and dealt with appropriately
• Staff training and increasing awareness of modern slavery, on how to spot signs and raise complaints within the organisation, and monitoring the delivery of this training to staff
• Putting in place Strict standards for conduct in the workplace, mirroring the NHS code of conduct, as referenced within our staff handbook and code of conduct policy
• Ensuring inappropriate employment practices are avoided by adhering to our Illegal Working Prevention, DBS, and Recruitment policies, to ensure identity checks, DBS, qualifications and references are in place
• Continued development of policies around safeguarding.

Dr Emamoke Ubogu (m)

Dr S Mirza

Risk stratification is a process for identifying and managing patients who are at a higher risk of emergency hospital admission. Typically, this is because patients have a long-term condition such as COPD or cancer. NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help prevent avoidable admissions.

Information about you is collected from several sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your anonymous information using computer programmes. Your information is only provided back to your GP or member of your care team in an identifiable form. Risk stratification enables your GP to focus on the prevention of ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services.

Under the GDPR we require your explicit consent to be able to perform this process. Please note the purpose of risk stratification is to prevent and detect health issues therefore we will ask our Patients for their consent to be included in this.

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.

Zero tolerance Policy

What is it?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come in to such possession. The processing of personal data is governed by the General Data Protection Regulation (the ‘GDPR’).

Sharing your personal data

Sometimes information about you may be requested to be used for research purposes. The Practice will always endeavour to gain your consent before releasing the information.

Under the powers of the Health and Social Care Act 2012 (HSCA) the Health and Social Care Information Centre (HSCIC) can request Personal Confidential Data (PCD) from GP Practices without seeking the patient’s consent. Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.

Any patient can choose to exercise their right of objection specified under the GDPR regarding their PCD being used in this way. When the Practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-in’ of each new scheme.

Though a patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

How do we process your personal data?

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

NHS health records may be processed electronically, on paper or a mixture of both, and a combination of working practices and technology are used to ensure that your information is kept confidential and secure. Records held by this GP Practice may include the following information:

• Details about you, such as address, telephone numbers, DOB and next of kin
• 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.

What is the legal basis for processing your personal data?

This GP Practice collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that information is kept confidential. We can disclose personal information if:

It is required by law
You consent – either implicitly for the sake of your own care or explicitly for other purposes

It is justified in the public interest
Some of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict measures to ensure that individual patients cannot be identified.

Sharing your personal data
Sometimes information about you may be requested to be used for research purposes. The Practice will always endeavour to gain your consent before releasing the information.

Under the powers of the Health and Social Care Act 2012 (HSCA) the Health and Social Care Information Centre (HSCIC) can request Personal Confidential Data (PCD) from GP Practices without seeking the patient’s consent. Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.

Any patient can choose to exercise their right of objection specified under the GDPR regarding their PCD being used in this way. When the Practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks before the scheme is due to start. We will also explain clearly what you have to do to ‘opt-in’ of each new scheme.

Though a patient can object to their personal information being shared with other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at the time.

Risk Stratification
Risk stratification is a process for identifying and managing patients who are at a higher risk of emergency hospital admission. Typically, this is because patients have a long-term condition such as COPD or cancer. NHS England encourages GPs to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help prevent avoidable admissions.

Information about you is collected from several sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your anonymous information using computer programmes. Your information is only provided back to your GP or member of your care team in an identifiable form. Risk stratification enables your GP to focus on the prevention of ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services.

Under the GDPR we require your explicit consent to be able to perform this process. Please note the purpose of risk stratification is to prevent and detect health issues therefore we will ask our Patients for their consent to be included in this.

Invoice Validation
If you have received treatment within the NHS, access to your personal information may be required to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.

This information would most likely include information such as your name, address, date of treatment and may be passed on to enable the billing process. These details are held in a secure environment and kept confidential. This information will only be used to validate invoices and will not be shared for any further purposes.

NHS Health Checks
All of our patients aged 40-74 not previously diagnosed with cardiovascular disease are eligible to be invited for an NHS Health Check. Nobody outside the healthcare team in the practice will see confidential information about you during the invitation process and only contact details would be securely transferred to a data processor (if that method was employed). You may be ‘given the chance to attend your health check either within the practice or at a community venue. If your health check is at a community venue all data collected will be securely transferred back into the practice system and nobody outside the healthcare team in the practice will see confidential information about you during this process.

CCTV (Closed Circuit Television)
Images will be retained for 31 days and then deleted.

All images will be held securely, and all access requests and access to images will be documented.

Images may record individuals and / or record incidents. Not all recordings are designed to identify persons.

The lawful basis of recording CCTV images is for legitimate interests. Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime, and images may be provided to police or other bodies.

Other than in accordance with statutory rights, the release or availability of images will be at the discretion of the Partners of the Practice, who are Data Controllers for the purposes of the Data Protection Act.

Where access is granted in response to an application received, the image may be edited to exclude images of third parties who may be also included within the requested image. This may be necessary to protect the identity of the third parties. In these circumstances the image released as part of the application may record / identify the “data subject” only.

Images will be located by the Data Controller or authorised person.

When assessing the content of the image to be released the decision will be taken by the Data Controllers having due regard to the requirements of the Data Protection Act and Code of Conduct.

Your Care Connected
Your Care Connected (YCC) is an electronic record sharing system that allows authorised health and care staff to securely view key aspects of the GP record, to provide patients with better and safer care.

Please see the following website for further information: https://midlandsyourcareconnected.nhs.uk

‘The lawful basis for processing this data is for the purposes of provision of health care or treatment’ [Article 9(2) of the GDPR].

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –

• The right to request a copy of your personal data which this practice holds about you;
• The right to request that this practice corrects any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary for the practice to retain such data. Although please note for Patients at this practice, your records will be retained until death;
• The right to withdraw consent to the processing at any time;The right to data portability;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed o further processing;
• The right to lodge a complaint with the Information Commissioners Office.