Data Protection Privacy Notice

 
  1. About Bruntsfield Medical Practice
  2. Bruntsfield Medical Practice is an independent contractor providing primary medical services by way of a contract with NHS Lothian, made under the National Health Service (Scotland) Act 1978 (the 1978 Act).

  3. About the personal information we use
  4. We use personal information on different groups of individuals including:

    • Patients
    • Staff
    • Contractors
    • Suppliers
    • Complainants, enquirers
    • Survey respondents
    • Professional experts and consultants
    • Individuals captured by CCTV



    We keep different types of information depending on the group or individual, as listed above. The personal information we use includes information that can identify people like name, address, date of birth and postcode.

    We also use more sensitive types of personal information, including information about racial or ethnic origin; religious or philosophical beliefs; genetic data, health; sex life or sexual orientation.
    The information we use can relate to personal and family details; education, training and employment details; financial details; lifestyle and social circumstances; goods and services; visual images; details held in the patient record; responses to surveys.

  5. Our purposes for using personal information
  6. Under the 1978 Act Bruntsfield Medical Practice and NHS Lothian has the statutory responsibility to provide or arrange for the provision of a range of healthcare, health improvement and health protection services. We are given these tasks so that we can help to promote the improvement of the physical and mental health of the patients of Bruntsfield Medical Practice and assist in operating a comprehensive and integrated national health service in Scotland.

    We use personal information to enable us to provide healthcare services for patients (including reminding you of appointments), data matching under the national fraud initiative; research; supporting and managing our employees; maintaining our accounts and records and the use of CCTV systems for crime prevention.

  7. Our legal basis for using personal information
  8. Bruntsfield Medical Practice (along with NHS Lothian), as data controller, is required to have a legal basis when using personal information. Bruntsfield Medical Practice considers that performance of our tasks and functions are in the public interest. So when using personal information our legal basis is usually that its use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us. In some situations we may rely on a different legal basis; for example, when we are using personal information to pay a supplier, our legal basis is that its use is necessary for the purposes of our legitimate interests as a buyer of goods and services. Another example would be for compliance with a legal obligation to which Bruntsfield Medical Practice is subject to, for example under the Public Health etc (Scotland) Act 2008 we are required to notify Health Protection Scotland when someone contracts a specific disease.

    When we are using more sensitive types of personal information, including health information, our legal basis is usually that the use is necessary:

    • for the provision of health or social care or treatment or the management of health or social care systems and services; or
    • for reasons of public interest in the area of public health; or
    • for reasons of substantial public interest for aims that are proportionate and respect people’s rights, for example research; or
    • in order to protect the vital interests of an individual; or
    • for the establishment, exercise or defence of legal claims or in the case of a court order.



    On rare occasions we may rely on your explicit consent as our legal basis for using your personal information. When we do this we will explain what it means, and the rights that are available, to you. You should be aware that we will continue to ask for your consent for other things like taking part in a drug trial, or when you are having an operation.

  9. Who provides the personal information
  10. When you do not provide information directly to us, we receive it from other individuals and organisations involved in the delivery of health and care services in Scotland. These include other NHS Boards, NHS and as well as private hospitals and clinics, other primary care contractors such as other GPs, dentists, pharmacists and opticians; other public bodies e.g. Local Authorities and suppliers of goods and services.

  11. Sharing personal information with others
  12. Depending on the situation, where necessary we will share appropriate, relevant and proportionate personal information in compliance with the law, with the following:

    • Our patients and their chosen representatives or carers
    • Staff
    • Current, past and potential employers
    • Healthcare social and welfare organisations
    • Suppliers, service providers, legal representatives
    • Auditors and audit bodies
    • Educators and examining bodies
    • Research organisations(1)
    • People making an enquiry or complaint
    • Financial organisations
    • Professional bodies
    • Trade Unions
    • Business associates
    • Police forces
    • Security organisations
    • Central and local government
    • Voluntary and charitable organisations


    (1) Bruntsfield Medical Practice participation in research
    As a practice, we feel that research is essential for progress in the NHS and is of considerable benefit for individual patients and the public as a whole. We therefore regularly take part in research studies with the help of experienced NHS staff who help us search medical records for people who might be suitable for research studies so that we can write to them asking if they are interested.
    No personal identifiable data is removed from the NHS or provided to any researchers without specific consent from patients.

  13. Transferring personal information abroad
  14. It is sometimes necessary to transfer personal health information overseas for example if you require urgent medical treatment abroad. When this is needed information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with NHSScotland Information Security Policy.

  15. How we protect personal information
  16. We take care to ensure your personal information is only accessible to authorised people. Our staff have a legal and contractual duty to keep personal health information secure, and confidential. The following security measures are in place to protect personal information:

    • All staff undertake mandatory training in Data Protection and IT Security
    • Compliance with NHS Scotland Information Security Policy
    • Organisational policy and procedures on the safe handling of personal information
    • Access controls and audits of electronic systems


  17. Your rights
  18. This section contains a description of your data protection rights within Bruntsfield Medical Practice.

    (i) The right to be informed
    Bruntsfield Medical Practice must explain how we use your personal information. We use a number of ways to communicate how personal information is used, including:

    • This Data Protection Notice
    • Information leaflets
    • Discussions with staff providing your care


    (ii) The right of access
    You have the right to access your own personal information.

    This right includes making you aware of what information we hold along with the opportunity to satisfy you that we are using your information fairly and legally.

    (iii) You have the right to obtain:

    • Confirmation that your personal information is being held or used by us
    • Access to your personal information
    • Additional information about how we use your personal information


    Although we must provide this information free of charge, if your request is considered unfounded or excessive, or if you request the same information more than once, we may charge a reasonable fee.

    If you would like to access your personal information, you can do this by submitting a written request.
    We have a form for this purpose which you can collect in person from reception, complete by hand and return to the Practice, or you can download a copy from our Practice website here.

    If you wish to mail your form back to us, please send it to:

    Data Controller
    Bruntsfield Medical Practice
    11 Forbes Road
    Edinburgh
    EH10 4EY

    Once we have received your request and you have provided us with enough information for us to locate your personal information, we will respond to your request within one month (30 days). However If your request is complex we may take longer, by up to two months, to respond. If this is the case we will tell you and explain the reason for the delay.

    (iv) The right to rectification
    If the personal information we hold about you is inaccurate or incomplete you have the right to have this corrected.

    If it is agreed that your personal information is inaccurate or incomplete we will aim to amend your records accordingly, normally within one month, or within two months where the request is complex. However, we will contact you as quickly as possible to explain this further if the need to extend our timescales applies to your request. Unless there is a risk to patient safety, we can restrict access to your records to ensure that the inaccurate or incomplete information is not used until amended.
    If for any reason we have shared your information with anyone else, perhaps during a referral to another service for example, we will notify them of the changes required so that we can ensure their records are accurate.

    If on consideration of your request Bruntsfield Medical Practice does not consider the personal information to be inaccurate then we may add a comment to your record stating your concerns about the information. If this is case we will contact you within one month to explain our reasons for this.
    If you are unhappy about how Bruntsfield Medical Practice has responded to your request for rectification we will provide you with information on how you can complain to the Information Commissioner’s Office, or how to take legal action.

    (v) The right to object
    When Bruntsfield Medical Practice is processing your personal information for the purpose of the performance of a task carried out in the public interest or in the exercise of official authority you have the right to object to the processing and also seek that further processing of your personal information is restricted. Provided Bruntsfield Medical Practice can demonstrate compelling legitimate grounds for processing your personal information, for instance; patient safety or for evidence to support legal claims, your right will not be upheld.

    Research studies: Patients have the right to opt out of being contacted about research studies. Please let the reception staff or your GP know if you wish to opt out. If you have any questions, please ask to speak to the Practice Manager.

    (vi) Other rights
    There are other rights under current Data Protection Law however these rights only apply in certain circumstances. If you wish further information on these rights see “Your Rights” on the NHS Lothian website.

    (vii) The right to complain
    The Data Controller within Bruntsfield Medical Practice is required to check that we handle personal information in a way that meets data protection law. If you are unhappy with the way in which we use your personal information please tell our Data Controller using the contact details below.

    Data Controller
    Bruntsfield Medical Practice
    11 Forbes Road
    Edinburgh
    EH10 4EY

    Tel – 0131 228 6081

    You also have the right to complain about how we use your personal information to the Information Commissioner’s Office (ICO). Details about this are on their website at www.ico.org.uk.

  19. Translation Service/ Accessibility
  20. If you require a translation service please find details to enquire below.

    Interpretation and Translation Service
    NHS Lothian Staff Bank
    Comely Bank Centre
    13 Crewe Road South
    Edinburgh,
    EH4 2LD

    staffbank.its@nhslothian.scot.nhs.uk

    Telephone: 0131 536 2020 option 5 option 5

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