Brentfield Medical Centre gathers and processes your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and law. This notice provides you with the necessary information regarding your rights and our obligations and explain how why and when we process your personal data.
Our practice address is: 10 Kingfisher Way London NW10 8TF
Our email address is: breccg.Brentfieldmc@nhs.net
INFORMATION WE COLLECT
The practice processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our services. We will never collect unnecessary personal data from you and do not process your information in anyway, other than as specified in this notice.
The personal data that we collect you is:
- Date of birth
- Next of kin / emergency contact
- Email address
- Mobile phone number
- Landline number
- Financial information to facilitate payroll payments
- Financial information to facilitate payment
- Employment eligibility
- Blood born virus status
- Relevant employment related information
- Occupational health information
We collect information by use of on line forms, electronically completed forms, scanned and paper forms, email, and electronic records using third party software such as payroll/accounting/personnel.
All patient electronic medical record data is processed within the clinical system.
HOW WE USE YOUR PERSONAL DATA
The practice takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose (s) specified in this notice. Where you have provided consent you are free to withdraw this consent at any time.
The purpose and reasons for processing your personal data are detailed below:
- Provision of healthcare
- Employment and payroll
- Membership communication and support
- Payment for sub contract work undertaken
We will from time to time send you communications materials that we have assess to be beneficial to you such information is non-intrusive and is processed on the grounds of legitimate interest.
You have the right to assess any personal information that the practice processes about you and to request information about:
- What personal data we hold about you
- The purpose of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
If you believe we hold any incomplete or inaccurate data about you, you have the right to ask us for it to be corrected or completed and we will ensure that this done as quickly as possible; unless there is a valid reason for not doing so , at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection law.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identify before acting on the request; this is to ensure that your data is protected and kept secure.
To exercise any of these rights please contact us via breccg.Brentfieldmc@nhs.net or by writing to 10 Kingfisher Way London NW10 8TF.
SHARING AND DISCLOSING YOUR PERSONAL INFORMATION
We do not share or disclose any of your personal information without your consent, other than for purposes specified in this notice or where there is a legal requirement.
The practice takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place.
We maintain internal policies and procedures, or procure that our sub processors do so, which are designed to:
- Secure any User Personal Data Processed by us against accidental or unlawful loss, access or disclosure
- Identify reasonably foreseeable and internal risks to security and unauthorised access to the User Personal Data Processed by us
- Minimise security risks including through risk assessment and regular testing.
We conduct regular reviews of the security of our network and the adequacy of our information security programme as measured against industry and NHS security standards and our policies and procedures, and will use reasonable effort to procure that our sub processors do so as well.
We periodically evaluate security of our network and associated services to determine whether additional or different security measures are required to respond to new security risks or findings generated by the periodic reviews, and will use reasonable efforts to procure that our sub processors do so as well.
We limit access to personal data by implementing appropriate access controls.
Availability and back-up of User Personal Data
We regularly back-up User Personal Data and store such back-up in accordance with NHS security policy.
Disposal of IT Equipment
All NHS supplied IT assets/equipment are disposed of by NHS IT support and a Certificate of Destruction obtained and the asset register is update to reflect such destruction. Where the IT equipment is the property of The practice we have in place processes to securely remove all personal data before disposing of IT systems.
The practice operates within NHS N3 connection or equivalent. Where necessary and appropriate we use encryption technology to protect User Personal Data that is held electronically.
Transmission or transport of User Personal Data
All User Personal Data will be transmitted or transport within the NHS N3 network and utilising appropriate controls to secure such data.
No default or generic passwords will be used to process User Personal Data and an audit trail will identify all activity in IT systems used to process data.
We implement and audit appropriate physical security measures to safeguard User Personal Data.
Staff training and awareness
All staff regularly undertakes information governance training and updates in compliance with the NHS Information Governance Toolkit. Staff compliance with information governance policy and procedures and remedial action taken if any area of non-compliance is identified. Employees and contractors are subject to disciplinary measures for breaches or our policies and procedures relating to data privacy and security.
TRANSFERS OUTSIDE ENGLAND AND WALES
Personal data in the European Union is protected by the General Data Protection Regulations (GDPR) 2018. The practice processes all User Personal Data within the NHS firewalls and within England and Wales. Should a specific need arise to utilise a product or service all practical steps will be taken to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by Data Privacy Shield Certification to protect your data and comply with the relevant data protection laws.
HOW LONG WE KEEP YOUR DATA
The practice only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.
We are required under UK tax law to keep you basic personal data (name, address, contact details and invoicing /payment details) for a minimum of 6 years.
We are required under UK law to keep payroll records for 3 years.
We are required under UK lay to keep personnel records for 5 years.
LEGITIMATE INTEREST EXAMPLE
The practice will occasionally send you information about up and coming events or updates by email that have been identified as being of interest to you and is in our interests. Such information will be relevant to you and will be non-intrusive and you will have the right to opt out by emailing breccg.Brentfieldmc@nhs.net to unsubscribe.
The practice only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to raise a complaint with the organisational Caldicott Guardian by emailing breccg.Brentfieldmc@nhs.net
Caroline Kerby – Caldicott Guardian / SIRO
Dr Sarah Basham – Information Governance Lead