COVID-19 Privacy Notice
(This Privacy Notice is to run alongside our standard Practice Privacy Notice)
Due to the unprecedented challenges that the NHS and we, INCLUSION HEALTHCARE face due to the worldwide COVID-19 pandemic, there is a greater need forpublic bodies to require additional collection and sharing of personal data to protect against serious threats to public health.
In order to look after your healthcare needs in the most efficient way we, INCLUSION HEALTHCARE may therefore need to share your personal information, including medical records, with staff from other GP Practices including Practices within our Primary Care Network, as well as other health organisations (ie Clinical Commissioning Groups, Commissioning Support Units, Local authorities etc.) and bodies engaged in disease surveillance for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
The Secretary of State has served notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) to require organisations to process confidential patient information in the manner set out below for purposes set out in Regulation 3(1) of COPI.
Purpose of this Notice
The purpose of this Notice is to require organisations such as INCLUSION HEALTHCARE to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI. This Notice is necessary to require organisations such as INCLUSION HEALTHCARE to lawfully and efficiently process confidential patient information as set out in Regulation 3(2) of COPI for purposes defined in regulation 3(1)
Requirement to Process Confidential Patient Information
The Secretary of State has served notice to recipients under Regulation 3(4) that requires INCLUSION HEALTHCARE to process confidential patient information, including disseminating to a person or organisation permitted to process confidential patient information under Regulation 3(3) of COPI.
INCLUSION HEALTHCARE is only required to process such confidential patient information:
- where the confidential patient information to be processed is required for a Covid-19 Purpose and will be processed solely for that Covid-19 Purpose in accordance with Regulation 7 of COPI
- from 20th March 2020 until 31st March 2021.
A Covid-19 Purpose includes but is not limited to the following:
- understanding Covid-19 and risks to public health, trends in Covid-19 and such risks, and controlling and preventing the spread of Covid-19 and such risks
- identifying and understanding information about patients or potential patients with or at risk of Covid-19, information about incidents of patient exposure to Covid-19 and the management of patients with or at risk of Covid-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from Covid-19
- understanding information about patient access to health services and adult social care services and the need for wider care of patients and vulnerable groups as a direct or indirect result of Covid-19 and the availability and capacity of those services or that care
- monitoring and managing the response to Covid-19 by health and social care bodies and the Government including providing information to the public about Covid-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services
- delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with Covid-19, including the provision of information, fit notes and the provision of health care and adult social care services
- research and planning in relation to Covid-19.
Summary Care Records
Summary Care Records (SCR) are an electronic record of important patient information, created from the GP medical records held at INCLUSION HEALTHCARE. They can be seen and used by authorised staff who work in other areas of the health and care system who are involved in your direct care. Patients who have already consented to having additional information added to their SCR will have additional information shared, which will include Anticipatory Care Plans for vulnerable, frail or elderly patients, although particularly sensitive information will not be automatically included in the sharing. The SCR will help a wide variety of organisation in response to COVID-19, as detailed above.
Recording of processing
A record will be kept by INCLUSION HEALTHCARE of all data processed under this Notice.
Sending Public Health Messages
Data protection and electronic communication laws will not stop INCLUSION HEALTHCARE from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.
It may also be necessary, where the latest technology allows INCLUSION HEALTHCARE to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.
e-Consult Online Consultations
INCLUSION HEALTHCARE uses eConsult as an online tool, enabling our GPs to provide consultations online to patients, meaning they do not have to come into the practice to have an appointment. Due to a collaboration between NHS England and NHSX, eConsult is now available through the NHS App. This integration means that NHS App users that are registered INCLUSION HEALTHCARE using the eConsult solution will be able to go through an eConsult appointment with a GP from within the NHS App. For the purposes of GDPR, INCLUSION HEALTHCARE and NHS England will act as Joint Data Controllers for the provision of the integrated service provided by eConsult via the NHS App. The NHS App is provided by NHS Digital, so both NHS Digital and eConsult will be Processors for this service.
Visitors to The Practice
We have an obligation to protect our staff and employees’ health, so it is reasonable for staff at INCLUSION HEALTHCARE to ask any visitors to our practice to tell us if they have visited a particular country, or are experiencing COVID-19 symptoms. This must only be in pre-approved circumstances and we would also ask all patients to consider government advice on the NHS 111 website and not attend the practice.
Where it is necessary for us to collect information and specific health data about visitors to our practice, we will not collect more information than we need, and we will ensure that any information collected is treated with the appropriate safeguards.
Review and Expiry of this Notice
This Notice will be reviewed on or before 31st March 2021 and may be extended by The Secretary of State. If no further notice is sent to INCLUSION HEALTHCARE by The Secretary of State this Notice will expire on 31st March 2021.