Central London Community Healthcare NHS Trust (“CLCH” or “we” or “us”) recognises the importance of respecting the privacy rights of all individuals. This Privacy Notice has been written to tell you what to expect when the Trust collects personal and confidential information. It mainly applies to:
all patient/service users of CLCH services
all employees, including but not limited to permanent staff, agency and temporary staff, volunteers, students
visitors to any of our geographical sites and internet website
individuals taking part in any surveys conducted by CLCH
job applicants and former employees
individuals exercising the right of subject access or freedom of information.
Downloadable materials for keeping your information safe:
posters and other materials are available on the NHS Digital website
Keeping Your Information Safe Leaflet
In order to provide a healthcare service, we need to collect and use personal information for a range of purposes. Primarily, we collect data for healthcare and administration purposes. For example, a health professional will record treatment details as this is essential information in order to provide a healthcare service. Patient consent is sought wherever appropriate.
There are some cases where it is necessary and a legal requirement to process personal information even without the consent of the individual whom the information relates to. If we do not have accurate, up to date information, this may impact on the services (such as effective treatment) that we provide.
Where we have not collected your information directly ourselves (such as GP or social workers), this will be clearly documented and/or stated to the individual, in line with the requirements under the General Data Protection Regulations.
CLCH respects patient choice and will respect an individual’s request to withhold information from someone or an agency unless there is a legal requirement to disclose the information.
Other purposes for data collection and usage may include:
As noted above, there are a number of reasons why we collect and use data. In all cases, the processing of personal and confidential information will comply with provisions and exemptions of the General Data Protection Regulations.
We may also provide information to other organisations, for example another NHS Trust for healthcare purposes. CLCH makes every effort to establish a written form of agreement / contract in such cases where we share with other organisations to ensure that all personal information is kept secure and is not disclosed to any unauthorised individuals. Any processing of personal information for purposes other than those specified or legally justified will require the consent of the data subjects (individual who the data refers to); a principle which CLCH strictly adheres to. Examples of when we may process information without consent would be for legal reasons, when instructed to do so by HM Courts.
CLCH has entered into a strategic partnership with Capita PLC to provide a number of administrative functions. In this contractual agreement Capita PLC processes data for which CLCH is the Data Controller for either patients or staff, CLCH determines for what purposes the information is used. Any information that CLCH holds on patients is as a consequence of direct care. The contract with Capita PLC includes confidentiality, information security, staff responsibilities and training requirements to ensure data is kept secure and confidential.
All personal data held by CLCH is held for a time period in accordance to the Records Management Code of Practice for Health and Social Care 2016.
We appreciate that not everyone wants their information to be used in the ways that have been identified. You may choose to restrict the collection or use of your personal information in the following ways:
We will not sell, distribute or lease your personal information to third parties without your consent.
CLCH may also share your electronic medical record with other Health & Social care organisations, if you give your consent to this. This is done when the other organisation uses the same Electronic Patient Administration System and has a relationship with you such as your GP. If consent is given then that specific organisation is able to view the relevant information we hold on you. This will not be done if consent is not given.
If you believe that any information we are holding on you is incorrect or incomplete, please write to the Information Governance team using the contact details below. This information may then be amended.
You may request details of personal information we hold about you under the General Data Protection Regulations, this is known as a subject access request. All subject access requests should be made to the Information governance team.
Under the General Data Protection Regulations you also have the right to erasure of your personal data held by us. If you wish to express this right, please write to the Information Governance team clearly stating which information you refer to.
If you are unhappy with the way that we are handling your information, we ask that you contact the Information Governance team in writing at first instance. You also have the right to lodge a complaint with the Information Commissioners Office.
You have a choice about how you want your confidential patient information to be used. If you're happy for us to use your information, you do not need to do anything.
If you choose to opt out, your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, visit nhs.uk/your-nhs-data-matters. Here you can:
You can find out more about how patient information is used at:
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies, or used for marketing purposes. Data would only be used in this way with your specific agreement.
Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out, and apply your choice to any confidential patient information they use or share, for purposes beyond your individual care. Our Trust is currently compliant with the national data opt-out policy.