f. Data Processors

EMIS Health and Egton

Purpose if the processing: EMIS Health and Egton are responsible for the provision of a clinical system, software and IT services used by the Practice to securely store and process your medical record.

All information about your personal health records are stored in your GP electronic record. This information is then available to practice staff & external bodies as outlined in this document.

Data retention period: All records held in the Practice EMIS  system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority. The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: In line with the GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

NHS Camden Clinical Commissioning Group (Camden CCG)

Purpose of the processing: NHS Camden Clinical Commissioning Group (Camden CCG) is responsible for securing, planning, designing and paying for your NHS services, including planned and emergency hospital care, mental health, rehabilitation, community and primary medical care (GP) services, Information Communication Technology (ICT), providing risk stratification services.

The CCG act as the Data Processor for Care Integrated Digital Record (CIDR) and EMIS Systems Local Record Sharing and, process personal data from your GP record in accordance with instructions from the Practice.

The source of the information shared in this way is your electronic GP record.

Data retention period: All records held in the Practice EMIS  system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph:Article 6(1) (e) - public interest or in the exercise of official authority. The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with CCG.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

North East London Commissioning Support Unit (NEL CSU) - GP Practice Data Extraction Services

Purpose of the processing:The GP Practice Data Extraction Services enables NEL CSU to extract personal data from GP Practice covering all currently registered patients and those ever registered since April 2009 except where patients have explicitly dissented from their information being extracted, for the provision of services back to the practice which may include:

Risk stratification; linking data to other data sets;

financial reporting;
business intelligence;
statistical analysis and;
information to support delivery of patient care.

The source of the information shared in this way is your electronic GP record.

Data retention period: All records held in the Practice EMIS  system be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority. The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared with NEL CSU.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

Health Information Exchange (provided by Cerner)

HIE Privacy Notice

Purpose of the processing: Cerner is responsible for the provision of IT clinical systems that enables safe, digitised patient care across the healthcare facilities. Cerner is the supplier of Health Information Exchange (HIE) - an Electronic Health Record (EHR) that links system and brings together patient data across the health and care system irrespective of traditional organisational or technological boundaries. This means health and care professionals in North London can access subsets of their patients/service users’ medical or social records from a single system in order to provide the best possible care.

The source of the information shared in this way is your electronic GP record for the purposes of direct patient care and population health management.

Data retention period: All records held in the Practice EMIS system and the HIE system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph:Article 6(1) (e) - public interest or in the exercise of official authority. The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being in Cerner HIE.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

Campus Doctor

Purpose of the processing: The data supplied by you is processed by CampusDoctor in line with the laws on data protection and confidentiality.

CampusDoctor processes your information so that it can be sent to your medical practice to enable your registration at the practice as a patient to receive general medical services.

CampusDoctor may send you health promotion information on behalf of the medical practice based on information supplied by you in the health questionnaire, but only if you have opted to receive this communication.

This data is processed using a secure server based in the European Union and forwarded using encrypted communication to the medical practice. There is no profiling or automatic decision making in this process.

It is your choice to provide your information to CampusDoctor. If you chose not to do so you will need to attend the medical practice in person to register with them.

Data Retention period: CampusDoctor has no other interest in your data other than the two uses above. It will not share this data with any other party. The data will be retained for 336 hours before being deleted.

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority. The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being used by Campus Doctor.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

Docman and Docmail

Purpose of the processing: Docman Limited act as a data processor and provides cloud-based storage software for electronic patient document. This includes letters that we receive, scan and upload to the patient record, as well as letters that we receive in an electronic format.

Generally, Docman enables primary health care organisations capture, file, workflow, view and manage primary care documents efficiently.

Docmail (Currently Ridgmount Practice does not use Docmail) enables primary health care organisations send letters, invoices and documents directly from computers and other portable devices.

The source of the information shared in this way is your electronic GP record for the purposes of direct administrative patient care.

Data retention period:All records held in the Practice EMIS system and the Docman vault are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority.

The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: In line with the GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

iPlato

Purpose of the processing: iPlato is cloud-based text messaging service used by GPs to communicate with their patients.

The source of the information shared in this way is your electronic GP record for the purposes of direct administrative patient care.

Data retention period: All personal health records held in the Practice EMIS system and the iPlato system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

Lawful basis General Data Protection Regulation  The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority. The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: In line with the GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

Quality Medical Solutions UK (QMS-UK):

Purpose of the processing: QMS-UK are commissioned by NHS England to provide secure data processing solutions for two services:

Child Health Information Service – information relating to children’s vaccinations is shared with North East London Foundation Trust who run one of 4 Child Health Information Services across London.

National Diabetic Retinal Screening Service – Diabetic eye screening is carried out in north central London by the North Central London Diabetic Eye Screening Programme (NCL-DESP).

NCL-DESP is provided by North Middlesex University Hospital NHS Trust which conducts screening across five London boroughs: Barnet, Camden, Enfield, Haringey and Islington.

The source of the information shared in this way is your electronic GP record.

Data retention period: All records held in the Practice EMIS system and the QMS database are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority.

The processing of special categories of personal data concerning health is permitted under the following paragraph: Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared in QMS.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

eFI
QAdmissions
QRisk
Diabetes Prevention Programme
Breathe –Smokefree Life Camden

Purpose of the processing: Ridgmount Practice performs computerised searches of some or all of our records to identify individuals who may be at increased risk of certain conditions or diagnoses i.e. Diabetes, heart disease, risk of falling). Your records may be amongst those searched. This is often called “risk stratification” or “case finding”. These searches are sometimes carried out by Data Processors who link our records to other records that they access, such as hospital attendance records. The results of these searches and assessment may then be shared with 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.

Risk stratification can be grouped into two purposes namely:

Direct Care – ‘Case Finding’ where carried out by a health professional (e.g. GPs and Provider) involved in an individual’s care or by a data processor acting under contract with such a provider, it is treated as direct care.

Indirect Care - understand the local population needs and plan for future requirement.

The source of the information shared in this way is your electronic GP record.

Data retention period: All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph:Article 6(1) (e) - public interest or in the exercise of official authority.

The processing of special categories of personal data concerning health is permitted under the following paragraph:Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services

Related Legislation:Section 251 NHS Act 2006

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

Currently Ridgmount Practice does not engage with any research organisations but if we do then these data processes apply. This will be updated as and when a research organisation is engaged.

Purpose of the processing: To enable healthcare professionals working for Ridgmount Practice to provide information, derived from GP records, about individuals to accredited research organisations.

This covers research situations where the data controller Ridgmount Practice is approached by research organisations, directly, to recruit patients for studies.
Any research proposal will only be agreed with a clearly defined protocol, consent mechanisms, and relevant research ethics committee approval, and in line with the principles of Article 89(1) of the EU GDPR.
Research organisations do not approach patients directly, rather Ridgmount Practice will invite appropriate patients directly seeking their wish to take part.
This Fair Processing Notice does not cover situations where Ridgmount Practice has been approached by an organisation seeking personal sensitive data to be disclosed in the absence of consent, i.e. via Related Legislation: Section 251 NHS Act 2006 / Health Research Authority (HRA) approval.

The source of the information shared in this way is your electronic GP record.

Data retention period: All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority.

The processing of special categories of personal data is permitted under the following paragraph: Article 9 (2) (j) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law

Related LegislationSection 251 NHS Act 2006

Your Rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

Camden GPIT (Part of Camden CCG)

Purpose of the processing:To provides solutions for, data backup and recovery, secure storage, and accredited data destruction (Hardware).

The source of the information shared in this way is your electronic GP record.

Data retention period: All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph:Article 6(1) (e) - public interest or in the exercise of official authority.

The processing of special categories of personal data is permitted under the following paragraph:Article 9 (2) (j) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law

Your rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

NHS England

Purpose of the processing: NHS England offer a wide range of business assurance services, from internal audit, counter fraud and forensic investigations, risk management and governance.

Data retention period: All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph: Article 6(1) (e) - public interest or in the exercise of official authority.

Your rights

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

IRIS Payroll Bureau

Purpose of the processing:  Iris Payroll Bureau provides practices with a software solution to enable the recording of Human Resources related information of its  employees’ personal data, in particular for the purposes of payroll.

The Practice ensures that personal data it collects from employees are used only for payroll related purposes.

Data retention period: All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Lawful basis General Data Protection Regulation  The processing of personal data is permitted under the following paragraph:(e) (public interest or in the exercise of official authority).

The processing of special categories of personal data is permitted under the following paragraph: Article 9(2) (b): processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject

Your rights

Employees have the  right to:

  • To access, view or request copies of their personal information held by the Practice;
  • request rectification of any inaccuracy to their personal information;
  • restrict the processing of their personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: Employees have a general right to raise an objection to the sharing personal data.

If an employee wishes to exercise his/her rights they can contact the Practice (data controller) or the DPO and their request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here

Ridgmount Practice

Purpose of the processing: Ridgmount Practice provides recording of Human Resources related information of its employees personal data, in particular for the purposes of the recruitment, obligations performance contract of employment, rights and benefits management planning, health and safety, equality and diversity in the workplace, health and safety at work.

The Practice ensures that personal data it collects from employees are used only for employment related purposes or where there is a statutory obligation to share the personal information with regulatory bodies(e.g. courts, police or NHS England).

Data retention period: All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care.

Lawful basis General Data Protection Regulation The processing of personal data is permitted under the following paragraph:(e) (public interest or in the exercise of official authority).

The processing of special categories of personal data is permitted under the following paragraph:Article 9(2) (b): processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject

Your rights:

Employees have the  right to:

  • To access, view or request copies of their personal information held by the Practice;
  • request rectification of any inaccuracy to their personal information;
  • restrict the processing of their personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: Employees have a general right to raise an objection to the sharing personal data.

If an employee wishes to exercise his/her rights they can contact the Practice (data controller) or the DPO and their request will be carefully considered.

Right to complain: If you are dissatisfied with the way Ridgmount Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The Information Commissioners Office can be contacted at: click here