Data Privacy Notice


Fair Processing Notice (Privacy Notice)

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received.  These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form.

Our Commitment to Data Privacy and Confidentiality Issues

As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation.  This includes the General Data Protection Regulation (EU) 2016/679 (GDPR) now known as the UK GDPR, the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time.  The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.

Data we collect about you

Records which this GP Practice will hold or share about you will include the following:

  • Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
  • Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence.  Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.
  • Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
  • Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place


  • Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care.  For example, it is possible for healthcare professionals in other services to access your record with or without your permission when the practice is closed.  Where your record is accessed without your permission it is necessary for them to have a legitimate basis in law. This is explained further in the Local Information Sharing at Appendix A.

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service.  Collecting this information helps to ensure you get the best possible care and treatment.

The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

  • improving the quality and standards of care provided by the service
  • research into the development of new treatments and care pathways
  • preventing illness and diseases
  • monitoring safety
  • planning services
  • risk stratification
  • Population Health Management

Safeguarding of children or vulnerable adults

If we have significant concerns or hear about an individual child or vulnerable adult being at risk of harm, we may share relevant information with other organisations, such as local authorities and the Police, involved in ensuring their safety.

Statutory disclosures

Sometimes we are duty bound by laws to disclose information to organisations such as the Care Quality Commission, the Driver and Vehicle Licencing Agency, the General Medical Council, Her Majesty’s Revenue and Customs and Counter Fraud services.  In these circumstances we will always try to inform you before we are required to disclose and we only disclose the minimum information that the law requires us to do so.

This may only take place when there is a clear legal basis to use this information.  All these uses help to provide better health and care for you, your family and future generations.  Confidential patient information about your health and care is only used like this where allowed by law or with consent.

Pseudonymised or anonymised data is generally used for research and planning so that you cannot be identified.

A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.

How long do we hold information for?

All records held by the Practice will be kept for the duration specified by national guidance from Records Management Code of Practice – NHSX. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is.  Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for 2021.

Individuals Rights under UK GDPR

Under UK GDPR 2016 the Law provides the following rights for individuals.  The NHS upholds these rights in a number of ways:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure (not an absolute right) only applies in certain circumstances
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling.

Your right to opt out of data sharing and processing

The NHS Constitution states, ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’.

Type 1 Opt Out

This is an objection that prevents an individual’s personal confidential information from being shared outside of their general practice except when it is being used for the purposes of their individual direct care, or in particular circumstances required by law, such as a public health screening, or an emergency like an outbreak of a pandemic disease. If patients wish to apply a Type 1 Opt Out to their record, they should make their wishes known to the Practice Manager.

National data opt-out (NDOO)

The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.

The national data opt-out replaces the previous ‘Type 2’ opt-out, which required NHS Digital not to use a patient’s confidential patient information for purposes beyond their individual care, for Planning or Research. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out.  For more information go to National data opt out programme

To find out more or to register your choice to opt out, please visit

On this web page you will:

  • See what is meant by confidential patient information
  • Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
  • Find out more about the benefits of sharing data
  • Understand more about who uses the data
  • Find out how your data is protected
  • Be able to access the system to view, set or change your opt-out setting
  • Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
  • See the situations where the opt-out will not apply

Right of Access to your information (Subject Access Request)

Under Data Protection Legislation everybody has the right of access to, or request a copy of, information we hold that can identify them, this includes medical records. There are some safeguards regarding what patients will have access to and they may find information has been redacted or removed for the following reasons;

  • It may be deemed to risk causing harm to the patient or others
  • The information within the record may relate to third parties who are entitled to their confidentiality, or who have not given their permission for the information to be shared.

Patients do not need to give a reason to see their data. And requests can be made verbally or in writing.  Although we may ask them to complete a form in order that we can ensure that they have the correct information required.

Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the additional copies.

Patients will need to provide proof of identity to receive this information. We will not share information relating to you with other individuals without your explicit instruction or without sight of a legal document.

Patients may also request to have online access to their data, they may do this via the NHS APP, or via the practice’s system. If you would like to access your GP record online click here

COVID Passport access

Patients may access their Covid passport via the link, the practice cannot provide this document as it is not held in the practice record. If you have any issues gaining access to your Covid Passport or letter you should call: 119

Change of Details

It is important that you tell the surgery if any of your contact details such as your name or address have changed, or if any of your other contacts details are incorrect including third party emergency contact details.  It is important that we are made aware of any changes immediately in order that no information is shared in error.

Mobile telephone number

If you provide us with your mobile phone number, we will use this to send you text reminders about your appointments or other health related information.  It is within our legal duty as a public authority to keep our patients updated with important information.

Email address

Where you have provided us with your email address, we will use this to send you information relating to your health and the services we provide.  If you do not wish to receive communications by email please let us know.


Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a Data Controller and our registration can be viewed online in the public register at:

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Data Protection Officer

Should you have any data protection questions or concerns, please contact our Data Protection Officer via the surgery at: [email protected]

What is the right to know?

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector.  You can request any non-personal information that the GP Practice holds, that does not fall under an exemption.  You may not ask for information that is covered by the Data Protection Legislation under FOIA.  However, you can request this under a right of access request – see section above ‘Access to your information’.

Right to Complain

If you have concerns or are unhappy about any of our services, please contact Operations Manager

For independent advice about data protection, privacy and data-sharing issues, you can contact:

The Information Commissioner

Wycliffe House , Water Lane , Wilmslow, Cheshire


Phone: 0303 123 1113     Website:

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to.  These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong.

The NHS Constitution for England – GOV.UK (

Document Control

This document was created by NHS South Central and West Commissioning Support Unit (SCW) and as such the Intellectual Property Rights of this document belong to SCW.

Document Name Version Status Author

Privacy Notice

Primary Care template

3.3 Published NHS SCW Information Governance Services
Document objectives: This document supports Practice staff in compliance with Data Protection legislation, achieving best practice in the area of Information Governance and in meeting the requirements of the Data Security and Protection Toolkit
Target audience: All staff
Monitoring arrangements and indicators: This document will be monitored by NHS SCW Information Governance Services to ensure any legislative changes that occur before the review date are incorporated.
Review frequency SCW reviews customer documents in line with our planned schedule
SCW Planned Review date 01 August 2023
Date uploaded to SCW Website 02 October 2022
Approved & ratified by practice The Park Surgery 16/12/2022
Date issued by practice 16/12/2022
GP Review date: 16/12/2023

Change record

Date Author Version Page Reason for Change
21.07.2020 SCW 2 All Review for Website publication
25.08.2021 SCW 3 All Review for Website publication, minor changes made, to links and addition of covid and online access.
24.12.2021 SCW 3.1 5 & 7 NHS Care Record guarantee link and Document control page updated
31.05.2022 SCW 3.2 All Reviewed
28.09.22 SCW 3.3 5 NHS Care Record Guarantee & NHS Constitution removed as per NHSE guidance
30.11.22 SCW 3.4 6 NHS Constitution – new link provided by NHSE

Appendix A – The Practice will share patient information with these organisations where there is a legal basis to do so.

Activity Rationale

Commissioning and contractual purposes Invoice Validation


Quality and Performance


Purpose – Anonymous data is used by the Integrated Care Board (ICB) for planning, performance, and commissioning purposes, as directed in the practices contract, to provide services as a public authority.


Legal Basis – UK GDPR 6 1(b) Contractual obligation as set out in the

Health and Social Care Act for Quality and Safety 2015


Patients may opt out of having their personal confidential data used for Planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to to apply a National Data Opt Out



Processor – Sussex Integrated Care Board

Summary Care Record

Including additional information

Purpose –The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

Legal Basis – Direct Care under UK GDPR:

  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and

·         Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine

Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that by opting out of having your information shared with the Summary Care Record could result in a delay to care that may be required in an emergency.

Processor – NHS England and NHS Digital


Purpose – We may share anonymous patient information with research companies for the purpose of exploring new ways of providing healthcare and treatment for patients with certain conditions. This data will not be used for any other purpose.


Where personal confidential data is shared your consent will need to be required.


Where you have opted out of having your identifiable information shared for this Planning or Research your information will not be shared.


Legal Basis – Where sharing of personal identifiable data is required the legal basis of Article 6 1 (a) and 9 2 (h) Consent will be required.


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.


Processor – To be advised if in use

Individual Funding Requests

Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our standard NHS contract.


The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time, but this may affect the decision to provide individual funding.


Legal Basis – Under UK GDPR Article 6 1(a) consent is required

6 1 (e) Public Task

Article 9 2 (h) health data


Data processor –Sussex Integrated Care Board

Safeguarding Adults

Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of individuals.


Consent may not be required to share information for this purpose.


Legal Basis – in some case consent will be required otherwise

·         Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and

·         Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine


Data Processor – West Sussex Safeguarding Adults Team

Safeguarding Children

Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children.


Legal Basis –

·         Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and

·         Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine


Consent may not be required to share this information.


Data Processor – West Sussex Safeguarding Children Team

Risk Stratification – Preventative Care

Purpose – ‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.


Information about you is collected from a number of sources including NHS Trusts, GP Federations, and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information.  This can help us identify and offer you additional services to improve your health.


If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.


Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data

Legal Basis

UK GDPR Art. 6(1) (e) Public task and Art.9 (2) (h) Health data.

The use of identifiable data by ICBs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2022 NHS England Risk Stratification  which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.


Processors – SCW CSU

Public Health

Screening programmes (identifiable)

Notifiable disease information (identifiable)

Smoking cessation (anonymous)

Sexual health (anonymous)

Vaccination Programmes



Purpose – Personal identifiable and anonymous data is shared.

The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms, and diabetic retinal screening service to name a few. The law allows us to share your contact information, and certain aspects of information relating to the screening with Public Health England so that you can be appropriately invited to the relevant screening programme.

More information can be found at: [Or insert relevant link] or speak to the practice

Patients may not opt out of having their personal information shared for Public Health reasons.


Patients may opt out of being screened at the time of receiving an invitation.


Legal Basis:

Sharing personal data for this purpose is governed by the COPI Reg 2.

Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’

6 1 (f) Legitimate interests

And Article 9(2)(h) Health data as stated below

9 2 (i) Public health


Data Processors – PHE Surrey & Sussex, County Hall, Chart Way, Horsham, West Sussex, RH12 1XA

Direct Care

NHS Trusts

Community Providers


Enhanced care providers

Nursing Homes

Other Care Providers

Purpose – Personal information is shared with other secondary care trusts and providers in order to provide you with individual direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.


Legal Basis – 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 1 (e) direct care and 9 2 (h) to provide health or social care:


In some cases, patients may be required to consent to having their record opened by the third-party provider before patients’ information is accessed. Where there is an overriding need to access the GP record in order to provide patients with lifesaving care, their consent will not be required.


Processors – Sussex Community Foundation Trust

Western Sussex Hospital Trust

Sussex Partnership Foundation Trust

South East Ambulance Service NHS Foundation Trust

Care Quality Commission

Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.


More detail on how they ensure compliance with data protection law (including UK GDPR) and their privacy statement is available on our website:


Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below


Processors – Care Quality Commission

Population Health Management

Purpose – Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data in order to:

•             Understand the health and care needs of the care system’s

population, including health inequalities

•             Provide support to where it will have the most impact

•             Identify early actions to keep people well, not only focusing

on people in direct contact with services, but looking to join

up care across different partners.

(NB this links to the Risk Stratification activity identified above)


Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data.  NB only organisations that provide your care will see your identifiable data.


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below


Data Processors – Optum, Cerner

Payments, Invoice validation

Purpose – Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amounts paid per patient per quarter varies according to the age, sex, and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non-patient related elements such as premises. Finally, there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors, and GPs themselves as well as research. In order to make patient-based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.


Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below


Data Processors – NHS England, ICB, Public Health

Patient Record data base

Purpose – Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date.  Your record will follow you as you change surgeries throughout your life.

Closed records will be archived by NHS England


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below


Processor – TPP SystmOne And PCSE

Medical reports

Subject Access Requests


Purpose – Your medical record may be shared in order that:


Solicitors/persons acting on your behalf can conduct certain actions as instructed by you.


Insurance companies seeking a medical report where you have applied for services offered by then can have a copy to your medical history for a specific purpose.


Legal Basis – under GDPR Article 6 1 (a) and 9 2 (a) explicit consent will be required before a GP can share your record for these purposes.


Processor – Solicitors, Insurance organisations

Medicines Management Team

Medicines Optimisation

Purpose – your medical record is shared with the medicines management team pharmacists, in order that your medication can be kept up to date and any necessary changes to medication can be implemented.


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor – Sussex Integrated Care Board Medicines Management Team

GP Federation

GP Enhanced Access

Video consultations

Minor surgery services

Covid Vaccination Programme


Purpose – Your medical record will be shared with the IPC in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics. The Federation will be acting on behalf of the GP practice.


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor – Innovations in primary Care

Primary Care Network (PCN)

Purpose – Your medical record will be shared with Arun Integrated Care in order that they can provide direct care services to the patient population.


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor – Names of the member practices in AiC

Westcourt Medical Centre

Willow Green Surgery

The Park Surgery

Smoking cessation

Purpose – personal information is shared in order for the smoking cessation service to be provided.


Only those patients who wish to be party to this service will have their data shared


Legal Basis – Article 6 1 (a) and 9 2 (h) consent


Processor – West Sussex County Council

Social Prescribers

Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their health social care needs.


Only those patients who wish to be party to this service will have their data shared


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor – Age UK


Purpose – Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared consent will not always be required.


The Police will require the correct documentation in order to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime. Or where the information is necessary to protect a person or community.


Legal Basis – UK GDPR –6 1 (c) Legal Obligation. Article 6 1 (f) legitimate interest

Article 9 2 (f) requests for legal reasons


Processor – Police Constabulary


Medical Examiner

Purpose – Personal health records or information relating to a deceased patient may be shared with the coroner or medical examiner upon request.


Legal Basis – UK GDPR Article 6 1 (c) Legal Obligation 9 2 (h) Health data


Processor – The Coroner, Medical Examiner

Private healthcare providers

Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with Private Providers.


Legal Basis – Article 6 1 (a) and 9 2 (h) Consented and under contract between the patient and the provider


Provider – BMI Goring Hall Hospital, or, any such private healthcare facility the data subject chooses

Messaging Service


Purpose – Personal identifiable information shared with the messaging service in order that messages including appointment reminders; results; campaign messages related to specific patients health needs; and direct messages to patients, can be transferred to the patient in a safe way.


Legal Basis – UK GDPR Article 6 1 (b) Contract, Article 6 1 (e) Public task, Article 9 2 (h) Health data


Provider – AccuRX, econsult, SystmOne SMS

Remote consultation

Including – Video Consultation

Clinical photography

Purpose – Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice.


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Patients may be videoed or asked to provide photographs with consent.  There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children.


Processor AccRx

MDT meetings

Purpose – For some long-term conditions, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions. Personal data will be shared with other agencies in order that mutual care packages can be decided.


Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor – MS Teams


Research and Planning

PurposeAs we move away from the initial response to COVID-19 the health and social care system will need to continue to take action to manage and mitigate the spread and impact of the outbreak. This includes ensuring that approved researchers can continue to securely access pseudonymised data held by GP IT systems to assist the health and care service’s response to COVID-19. By recognising trends in COVID-19 diseases and identifying risks it poses; controlling and preventing the spread of COVID-19; monitoring and managing outbreaks

You can find further information here:

COVID-19: notification to GPs and NHS England to share information – GOV.UK (


NHS England » OpenSAFELY – the Coronavirus (COVID-19) Research Platform


Legal Basis – In order to share personal confidential data with other agencies for research or planning.

Either the Article 6 1 (a) and 9 2 (a) Explicit consent will be required. And 6 1 (c) compliance with a legal obligation


The Processor would need to meet Section 251 CAG approval.


It would need to be approved under direct care to patients Article 6 1 (e) Public Task and 9 2 (h) Health data


Provider – COVID vaccination Hubs, BIOBANK, Oxford University,

General Practice Extraction Service (GPES)

  1. Covid-19 At risk patients data collection Version 5
  2. Covid-19 Planning and Research data
  4. Physical Health Checks for people with Severe Mental Illness

Purpose – GP practices are required to provide data extraction of their patients’ personal confidential information for various purposes to NHS Digital. The objective of this data collection is on an ongoing basis to identify patients registered at General Practices who fit within a certain criterion, in order to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction, by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work:


  1. At risk patients including severely clinically vulnerable


2.       COVID-19 At Risk Patients – NHS Digital


3.       NHS England has directed NHS Digital to collect and analyse data in connection with Cardiovascular Disease Prevention Audit


  1. GPES Physical Health Checks for people with Severe Mental Illness (PHSMI) data collection.


Legal Basis – All GP Practices in England are legally required to share data with NHS Digital for this purpose under section 259(1)(a) and (5) of the 2012 Act


Further detailed legal basis can be found in each link.


Any objections to this data collection should be made directly to NHS Digital.  [email protected]


Processor – NHS Digital or NHS X


Purpose: Prescriptions containing personal identifiable and health data will be shared with organisations who provide medicines management including chemists/pharmacies, in order to provide patients with essential medication regime management, medicines and or treatment as their health needs dictate. This process is achieved either by face-to-face contact with the patient or electronically. Pharmacists may be employed to review medication, Patients may be referred to pharmacists to assist with diagnosis and care for minor treatment, patients may have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver care and medication


Legal Basis: Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor – Pharmacy of choice

Enhanced Access Service                Purpose: The enhanced access service will improve access for patients to primary care appointments between the hours of 6.30pm and 8pm Mondays to Fridays and between 9am and 5pm on Saturdays.


Legal Basis:


•             Article 6(1)(e) Necessary for the performance of a task carried out in the public interest


•             Article 9(2)(h) Necessary for provision of health and/or social care, including preventative or occupational medicine


Processor: Innovations to Primary Care Ltd (IPC)Professional Training

Purpose – We are a training surgery. Our clinical team are required to be exposed to on the job, clinical experience, as well as continual professional development. On occasion you may be asked if you are happy to be seen by one of our GP registrars, pharmacists, or other clinical team to assist with their training as a clinical professional. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE.


Legal Basis – 6 1 (a) consent, patients will be asked if they wish to take part in training sessions.

9 2 (a) – explicit consent will be required when making recordings of consultations


Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.


Processor – RCGP, HEE, iConnect, Fourteen Fish


Purpose – The practice uses an internet based telephony system that records telephone calls, for their own purpose and to assist with patient consultations. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients.


Legal Basis – While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way.

Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Provider – Focus Communications

Learning Disability Mortality Programme


Purpose: The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with this criterion will be shared with NHS England.


Legal Basis:  It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information who fit within a certain criterion.


Processor: ICB, NHS England

Technical Solution


Purpose: Personal confidential and special category data in the form of medical record, is extracted under contract for the purpose of pseudonymisation. This will allow no patient to be identified within the data set that is created. SCWCSU has been commissioned to provide a data processing service for the GPs, no other processing will be undertaken under this contract.


Legal Basis: Under UK GDPR the legitimate purpose for this activity is under contract to provide assistance.

Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor: SCW CSU

Shared Care Record

Purpose: In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP connect, which is managed by NHS Digital, to enable a shared care record, which will assist in patient information to be used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population.


Where data is used for secondary uses no personal identifiable data will be used.


Where personal confidential data is used for Research explicit consent will be required.


Legal Basis: Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor: NHS Digital

Local shared care record

Purpose: Health and Social care services are developing shared systems to share data efficiently and quickly.  It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment.  It is also quicker for staff to access a shared record than to try to contact other staff by phone or email.


Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job.  Systems do not share all your data, just data which services have agreed is necessary to include.


Legal Basis: Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below


Processor: Plexus, NHS Digital, ESHT, ICS member providers

Anticoagulation Monitoring

Purpose: Personal Confidential data is shared with LumiraDX in order to provide an anticoagulation clinic to patients who are on anticoagulation medication. This will only affect patients who are within this criteria.


Legal Basis: The legal basis for this activity under UK GDPR is

Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below

Processor: LumiraDX INRStar

Off Site Storage of medical records

Purpose: The practice has commissioned the services of an offsite storage facility to provide secure offsite storage for all Lloyd George medical records. The facility has met the NHS standard as a supplier of this service. The practice can assure patients that their medical records will remain in control of the practice and robust mechanisms are in place to protect the security of the patients personal confidential data.

Legal Basis: The movement and storage of patient records will be undertaken by contractual obligation between the practice and the companies undertaking the work.

Under UK GDPR Article 6 1(b) contractual obligation

Article 9 2 (h) Health data.

Processor: CAS Ltd

Insurance reports, Reports requested by patients and SAR requests

We use a processor, iGPR Technologies Limited (iGPR), to assist us with responding to report requests relating to patient data, such as subject access requests that you submit to us (or that someone acting on your behalf submits to us) and report requests that insurers submit to us under the Access to Medical Records Act 1988 in relation to a life insurance policy that you hold or that you are applying for.

iGPR manages the reporting process for us by reviewing and responding to requests in accordance with our instructions and all applicable laws, including UK data protection laws.

The instructions we issu to iGPR include general instructions on responding to requests and specific instructions on issues that will require further consultation with the GP responsible for you care.

Processor: iGPR Technologies Ltd

Medical Examiner, University Hospital West Sussex Foundation Trust

Purpose: Purpose: Medical records associated with deceased patients are outside scope of the UK GDPR. However, next of kin details are within the scope of the UK GDPR. We will share specified deceased patient records and next of kin details with the Medical Examiners within University Hospital West Sussex NHS Foundation Trust


Legal Basis:

Article 6(1)c

“It is necessary under a legal obligation to which the controller is subject”

Article 9(2)h

“processing is necessary for the purposes of preventive 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”


Processor:  Medical Examiners Office, University Hospitals West Sussex NHS Foundation Trust



We keep our Privacy Notice under regular review. This notice was last reviewed on 22nd August 2023.

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 UK GDPR:


  • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
  • 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…”


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