Privacy Notice: PCN Data Sharing

Primary Care Networks (PCNs) are a key part of the NHS Long Term Plan, with all general practices being required to be in a network. 

This practice is part of the CLOCK TOWER Primary Care Network. 

CLOCK TOWER is made up of a number GP Practices created to work collaboratively to ensure the health care system within our area works effectively by sharing knowledge and resources.

To enable us to work collaboratively in delivering care, we may share data about you with local partner practices who are also part of CLOCK TOWER Primary Care Network (PCN) to provide the most flexible and accessible services for patients.  

This will mean that GPs from other local practices will at times have access to your full GP record but only when providing direct care to you.

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.

Your data may also be shared with CLOCK TOWER for the following purposes:

• CONTINUITY AND MANAGEMENT OF CARE

1) Controller contact details

The Westwood Surgery
24 Westwood Lane 
Welling 
Kent
DA16 2HE
020 8303 5353

2) Data Protection Officer contact details

GP Data Protection Officer
gpdpo@selondonics.nhs.uk

3) Purpose of the processing

To provide the clinician with the 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) ‘…The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

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 Primary Care Networks

6) Rights to object

You have the right under Article 21 of the 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.

For purposes of providing direct care, GP Practices process personal data under Article 6(1)(c) on a lawful and legitimate basis where the organisation is obliged under law to comply with

• The General Data Protection Regulations (GDPR)
• The Freedom of Information Act
• The NHS Constitution
• The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009

By complying with these laws, the Practice has compelling legitimate grounds for the processing which override the interests, rights and freedoms in the right to object.

7) Right to access and correct

Under GDPR and the Data Protection Act 2018, you have the right to see or be given a copy of any personal data we hold about you. To gain access to a copy of your information, you will need to make a Subject Access Request (SAR) to the Practice.

You also have the right to have incorrect data held about you corrected.

8) Retention period

The data will be retained for the period as specified in the national NHS records retention schedule.

9) Right to Complain.

You have the right to complain to the Information Commissioner's Office

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)