Privacy Notice: Research

This Practice sometimes participates in research, or research studies.

We will only agree to participate if there is an agreed clearly defined reason for the research that is likely to benefit healthcare and patients. Such proposals will normally have a consent process, ethics committee approval, and will be in line with the principles of Article 89(1) of UK GDPR.

Research organisations do not usually approach patients directly but may ask us to contact suitable patients to seek their consent.

Where identifiable data is required for research, patient consent will be needed, unless there is a legitimate reason under law to do so or there is support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales.

Sharing of aggregated non-identifiable data is permitted.

We may share information with the following medical research organisations with your explicit consent or when the law allows: Southampton University and Nottingham University.

You have the right to object to your identifiable information being used or shared for medical research purposes. Please speak to the practice if you wish to object.

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

Medical research.

4) Lawful basis for processing

Identifiable data will be shared with researchers either with explicit consent or, where the law allows, without consent. The lawful justifications are.

• Article 6(1)(a) “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”.

or

• Article 6(1)(e) may apply “necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.”

And in addition, there are three possible Article 9 justifications. 

• Article 9(2)(a) – ‘the data subject has given explicit consent…’

or

• Article 9(2)(j) – ‘processing is necessary for… scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member States law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject’.

or

• Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services...’

5) Recipient or categories of recipients of the processed data

The data will be shared with Attack Clinical trial

6) Who are our partner organisations?

Below are just some of the organisations that we may have to share your information with.  This would only be done in line with the lawful basis for sharing information under the data protection laws.

• NHS Trusts / Foundation Trusts
• Other 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 Digital
• Primary Care Support England
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police & Judicial Services
• Other ‘data processors’ which you will be informed of
• BHNC Clock tower PCN
• Southampton University and Nottingham University

7) Rights to object

You do not have to consent to your data being used for research. You can change your mind and withdraw your consent at any time. Contact the Controller or the practice.

You can also register a National Data Opt-out, which removes your data from certain research and planning. You can find out more here

Where you have opted out of having your identifiable information shared for planning or research using the above, your information will not be shared.

8) Right to access and correct

You have the right to access copies any identifiable data that is being shared and have any inaccuracies corrected.

9) Retention period

The data will be retained for the period as specified in the specific research protocol(s).

10) Sharing information for research purposes

NHS England has been directed by the government to establish and operate the \open Safely COVID19 service and the Open Safely data analytics service. These services provide a secure environment that supports research, clinical audit, service evaluation and health surveillance for COVID -19 and other purposes.

Each GP practice remains the controller of its own GP patient data but is requited to let approved users run queries on pseudonymised patient data. This means identifiers are removed and replaced with a pseudonym.

Only approved users are allowed to run theses queries, and they will not be able to access information that directly or indirectly identifies individuals.

Patients who do not wish for their data to be used as part of this process can register a type 1 opt out with their GP.

11) 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)