Practice Policies & Patient Information
Access to Patient Information
In order to provide care for you we are obliged to keep records. This is increasingly done using computers. We are obliged to comply with the Data Protection Act 1998 and other guidance on privacy and data confidentiality and we take this very seriously.
In order to manage services and improve the quality of care we provide we share some information on Practice activity, but this information is anonymised i.e. names and other identifying details are removed.
Chaperone
All patients are entitled to have a chaperone present for any consultation, examination or procedure where they feel one is required. The chaperone may be a family member or friend. On occasions you may prefer a formal chaperone to be present, i.e. a trained member of staff.
Wherever possible we would ask you to make this request at the time of booking so that arrangements can be made and your appointment is not delayed in any way. Where this is not possible we will endeavour to provide a formal chaperone at the time of request.
Your healthcare professional may also require a chaperone to be present for certain consultations in accordance with our chaperone policy.
Complaints Procedure
We hope that if you have a problem, you will use our Practice Complaints Procedure. Please view our Complaints leaflet. Our Practice Manager will ensure that the complaint is investigated as thoroughly and quickly as possible. We believe this will give us the best chance of putting right whatever has gone wrong and an opportunity to improve our practice.
However you may choose to contact NHS England on 0300 311 2233 between 8am and 6pm Monday to Friday to resolve the issue.
Support and advice to patients making a compliant can be obtained from NHS Complaints Advocacy Service, POhWER Advocacy Services on 0300 456 2370.
Comments, Complaints & Suggestions
Please Help Us To Get It Right
We are always willing to hear if there is any way that you think that we can, constructively, improve the service we provide.
Please let us know when you think we have done something well or if you have any suggestions as to how we can do something better.
Practice Complaints Procedure
If you have a complaint or concern about the service you have received from the practitioners or any of the staff working in this practice, please let us know. As part of an NHS system we operate a practice complaints procedure. Our complaints system meets national criteria.
How To Complain
We hope that most problems can be sorted out easily and quickly, often at the time they arise and with the person concerned. If your problem cannot be sorted out this way and you wish to make a complaint, we would like you to let us know as soon as possible – ideally, within a matter of days – because this will enable us to establish what happened more easily. Complaints can be made verbally, electronically to [email protected], or in writing.
Complaining On Behalf of Someone Else
We keep strictly to the rules of medical confidentiality. If you are complaining on behalf of someone else, we must know that you have their permission. A note signed by the person concerned will be needed unless they are incapable (because of illness) of providing this.
Time Limits For Making Complaints
- within 12 months of the incident that caused the problem; or
- within 12 months of discovering giving as much detail as possible.
The Practice Manager will retain the discretion to investigate complaints brought later than this if there are good reasons for the delay and it is still possible to carry out an investigation.
Complaints should be addressed to the Practice Manager. It will be a great help if you are as specific as possible about your complaint.
What Will Happen
We will acknowledge your complaint within three working days either verbally or in writing. If you are issued an acknowledgement letter or email, it will include:
- The manner in which the complaint will be handled;
- The timescales by which the investigation will be completed;
- The timescales by which our response will be sent.
Our response will include:-
- An explanation of how the complaint has been considered;
- The conclusions reached in relation to the complaint including any remedial actions considered necessary;
- Confirmation of any action needed as a result of the complaint has been/will be taken
What If I’m Still Not Satisfied?
We hope that, if you have a problem, you will use our practice complaints procedure. We believe this will give us the best chance of putting right whatever has gone wrong and an opportunity to improve our practice.
If you remain dissatisfied and feel that your complaint needs further investigation you can contact the NHS England Customer Call Centre where calls will be triaged and followed up by a case manager linking with local staff. The centre is open between 8am and 6pm Monday to Friday. Contact details below:
NHS England
PO Box 16738
Redditch
Worcester
B98 9PT
You also have the right to ask the Parliamentary Health Service Ombudsman to carry out an independent investigation into your complaint. If you feel you have suffered because you have received poor service or treatment or were not treated properly or fairly, the Parliamentary Health Service Ombudsman may be able to help.
Contact details below:
The Parliamentary and Health Service Ombudsman
Millbank Tower
Millbank
London
SW1P 4QP
Helpline: 0345 015 4033
Website: www.ombudsman.org.uk
Email: [email protected]
Telephone: 0300 311 22 33
Email: [email protected]
Support and advice to patients making a complaint can be obtained from NHS Complaints Advocacy Service, POhWER Advocacy Services on 0300 456 2370. You may also approach the Patient Experience team for help and advice;
The Patient Experience Team
Kingston House
438 – 450 High Street
West Bromwich
B70 9LD
Contact Number: 0800 389 8391
They provide confidential advice and support, helping you to sort out any concerns you may have about the care we provide, guiding you through the different services available from the NHS.
Confidentiality
Our staff will not reveal, to anybody outside the practice, personal information they learn in the course of their work without the patient’s consent. Nor will they discuss with colleagues any aspect of a patient’s attendance at the surgery in a way that might allow identification of the patient, unless to do so is necessary for the patient’s care.
We are obliged by law to provide certain information e.g. notification of certain infectious diseases.
Data Protection Act – Patients’ Rights
The right of access to personal data is described in the Data Protection Act 1998 (DPA). It states that a Data Subject (i.e. the patient, or the patient’s nominated representative e.g. a solicitor) having submitted a request in writing and paid the appropriate fee (see below), is entitled to be provided within 21 days with a copy of the Personal Data (i.e. the medical records/notes) held about him or her. The Act requires that a copy of the data must be supplied in permanent form unless the supply of such a copy is not possible, would involve disproportionate effort, or the Data Subject (the patient or solicitor) agrees otherwise.
The general rights as set out in the DPA are modified by two orders. The Data Protection (Subject Access Modification)(Health) Order 2000 provides that information need not be disclosed if it would be likely to cause serious harm to the physical or mental health of the Data Subject or any other person and describes the mechanisms for ensuring that decisions as to whether to disclose or withhold information are taken by the appropriate health professional. The Data Protection (Subject Access) Fees and Miscellaneous Regulations 2000 provides that whereas the normal maximum access fee that may be charged is £10, for health records a fee of up to £50 may be charged for paper notes and £10 for computerised records.
GDPR Privacy Statement
Please read our GDPR Privacy Statements and Information:
Modern Slavery Statement
13/5/2019 – Approved by Dr Yasmin Ahmad, Ridgacre Medical Centre
22/5/2019 – Approved by OHP governance committee
Section 54 of the UK Modern Slavery Act (2015) requires commercial organisations operating in the UK with an annual turnover in excess of £36m to produce a ‘slavery and human trafficking statement for each financial year of the organisation’.
Organisational Structure and Business
Our Health Partnership is one of the UK’s biggest GP partnerships. It brings together 52 surgeries in the Midlands and Shropshire. By using our shared expertise to tackle the challenges of GP practice today, we can keep local surgeries thriving and provide the excellent care that our patients need now and into the future.
Our approach to slavery and human trafficking
We are committed to tackling modern slavery within every part of our business and its supply chains. Our Anti-slavery statement, in combination with the establishment of effective policies, demonstrates our commitment to the issue of modern slavery and ensures that appropriate and coordinated action is taken throughout the business.
Due diligence
We have taken action to understand and address the risks of modern slavery within our operations, including:
- The development of robust processes around whistleblowing, grievance, disciplinary and bullying and harassment policies, to provide both staff and patients with assurance that modern slavery concerns will be raised and dealt with appropriately
- Staff training and increasing awareness of modern slavery, on how to spot signs and raise complaints within the organisation, and monitoring the delivery of this training to staff
- Putting in place Strict standards for conduct in the workplace, mirroring the NHS code of conduct, as referenced within our staff handbook and code of conduct policy
- Ensuring inappropriate employment practices are avoided by adhering to our Illegal Working Prevention, DBS, and Recruitment policies, to ensure identity checks, DBS, qualifications and references are in place
- Continued development of policies around safeguarding
OHP Employee Privacy Notice
Data protection officer:
Umar Sabat
As part of any recruitment process, we collect and process personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
What information do we collect?
We collect a range of information about you. This includes;
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief
We collect this information in a variety of ways. For example, data might be contained in application forms or CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
We will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why do we process personal data?
We need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.
We are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, we will keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the Practice staff who carry out HR activities, the central People team and interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
In order to meet our duties, we are required to obtain references from your former employers as part of the interview process. We will not share your data with third parties for this purpose without your consent.
The organisation will share data with third parties with employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
We will not transfer your data to countries outside the European Economic Area or any company that is not included in the EU-US Privacy Shield.
How do we protect data?
We take security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. For more information, please refer to the Practice Data Protection Policy.
Where we engage third parties to process personal data on our behalf, we do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
How long we keep your personal information
If your application for employment is unsuccessful, we will hold your data on file for up to 6 months after the end of the relevant recruitment process. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained for the duration of your employment. At the end of your employment your data will not be kept longer that necessary for the purpose for which it is processed. For example, personal information of employees including terms and conditions of employment, disciplinary records, reviews and annual leave records will be kept for 7 years after employment ends. The organisation will keep hold of employees PAYE, Payroll records for 7 years after employment ends given the relevance to any pay disputes and as HMRC may request to see them in this time. Occupational Health records will be kept in a suitable form for a minimum of 40 years after the date of last entry. Further information about retention schedules can be obtained from the Organisation.
Your rights
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Under certain circumstances, by law you have the right to:
- Ask for access to your personal information. This is called a ‘subject access request.’
- Ask for rectification of the information we hold about you
- Ask for the erasure of information about you
- Ask for our processing of your personal information to be restricted
- Data portability
- Object to us processing your information.
If you make a subject access request, and if we do hold information about you, we will:
- Give you a description of it
- Tell you why we are holding and processing it, and how long we will keep it for
- Explain where we got it from, if not from you
- Tell you who it has been, or will be, shared with
- Let you know whether any automated decision-making is being applied to the data, and any consequences of this
- Give you a copy of the information in an intelligible form
You may also have the right for your personal information to be transmitted electronically to another organisation in certain circumstances.
If you want to use your rights, please contact: Practice Manager NAME
If at any time you are not happy with how we are processing your personal information, then you may raise the issue with the Data Protection Officer. If you are not happy with the outcome, you may raise a complaint with the Information Commissioner’s Office: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
Automated decision-making
Employment decisions are not based solely on automated decision-making. We will regularly review this Privacy Notice to ensure it remains accurate and up to date.
Safe Surgeries
The Manor Practice is participating in the NHS England Safe Surgeries initiative aimed at improving access to primary care for vulnerable people, especially migrants. The Manor Practice has declared itself a “safe surgery” for everyone and therefore a lack of ID or proof of address, immigration status or language are not barriers to patient registration.
Statement of Purpose
Zero Tolerance Practice
A Zero Tolerance Policy to violent, threatening and abusive behaviour is now in place throughout the National Health Service. The staff in this practice have the right to do their work in an environment free from such behaviour and everything will be done to protect that right.
The NHS operate a zero tolerance policy with regard to violence and abuse and the Practice has the right to remove violent patients from the list with immediate effect in order to safeguard Practice staff, patients and other persons. Violence in this context includes actual or threatened physical violence or verbal abuse which leads to fear for a person’s safety. In this situation we will notify the patient in writing of their removal from the list and record in the patient’s medical records the fact of the removal and the circumstances leading to it.
At no time will any violent, threatening or abusive behaviour be tolerated in this practice.