Who we are
Our website address is: http://www.imc-alderney.com.
This leaflet explains who we are, why information is collected about you, the ways in which this information may be used, who it is shared with and how we keep it safe. It also explains how the practice uses the information we hold about you, how you go about accessing this information if you wish to see it and to have any inaccuracies corrected or erased.
WHO WE ARE
The Island Medical Centre (IMC) is the sole GP surgery based on Alderney in the Channel Islands. Our small staff of clinicians provides primary medical care services to our practice population of around 1800 patients and our reception team, led by Practice Manager Tracy Jean, support the team in providing care for patients.
WHAT INFORMATION DO WE COLLECT FROM YOU?
GP Records are stored electronically and on paper and include personal details about you such as your address, carers, legal representatives, emergency contact details, as well as:
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments and telephone calls
- Notes and reports about your health
- Details about your treatment and care
- Details about any medication you are taking
- Results of investigations such as laboratory tests, x-rays
- Relevant information from other health professionals, relatives or those who care for you
WHY DO WE COLLECT THIS INFORMATION?
Your records are used to ensure you receive the best possible care from our nurses and doctors. It enables the staff to see previous treatments, medications and enables them to make informed decisions about future decisions about your care. It helps the doctors to see lists of previous treatments and any special considerations which need to be taken into account when care is provided.
Important information is also collected to help us to remind you about specific treatment which you might need, such as health checks, or reminders for screening appointments such as cytology reminders.
Information held about you may be used to help protect the health of the public and to help us to improve services provided by Health and Social Care in Guernsey, as well as other health providers. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.
Staff at the practice use your information to help deliver more effective treatment to you and to help us to provide you with proactive advice and guidance.
Who MIGHT WE share your information with?
There are a number of ways information collected about you is shared, which includes:
- Patient referrals
With your agreement, your GP or Nurse may refer you to other services and healthcare providers not provided by the practice, or they may work with other services to provide your care in the practice. Once you have been seen for your referral, the other health care provider will normally tell us about the treatment they have provided for you and any follow up which the GPs need to provide. This information is then included in your GP record.
- Local Hospital, Community or Social Care Services
Sometimes the clinicians caring for you need to share some of your information with others who are also supporting you. This could include hospital or community based specialists, nurses, health visitors, therapists or social care services.
- Summary Care Record (SCR)
The Committee for Health & Social Care (HSC) in the Bailiwick of Guernsey, which includes Alderney, Herm and Jethou, have not yet embarked on a programme to create a Summary Care Record for each patient. However, this is something that is being considered and so we feel it is important to let you know that this may occur in the future. It has already been rolled out in many UK practices.
A Summary Care Record (SCR) is an electronic record of important patient information, created from the GP medical records. It contains information about medication you are taking, any allergies you suffer from and any bad reactions to medications you have previously had. It can be seen and used by authorised staff in other areas of the health and care system involved in your direct care. Giving healthcare staff access to this information can prevent mistakes being made when caring for you in an emergency or when your GP practice is closed. Your Summary Care Record also includes your name, address, date of birth and your unique GY Number to help identify you correctly. If you and your GP decide to include more information it can be added to the Summary Care Record, but only with your express permission.
- National Services
There are some UK national services like the National Cancer Screening Programme that collect and keep information from across the NHS and the Channel Islands. This is how these organisations know when to contact you about services like cervical, breast or bowel cancer screening. Often you have the right to not allow these organisations to have your information.
You can find out more about how the NHS holds and shares your information for national programmes on the NHS Choices website.
- Local Data Sharing Agreements
The practice currently has two data sharing agreements. The agreements cover:
- Alderney Information Sharing Group (community day care co-ordinators, Police, Fire & Rescue, Alderney Ambulance, Mignot Hospital staff and IMC GP as well as HSC Social Worker). This group meets quarterly to share information about the vulnerable adults in our community and other people on our mutual caseload who have recently been discharged from hospital, or who are housebound, or who require longer term rehabilitation from the GP record. There is no access to your health record at these meetings.
- TrakCare is an electronic health record for people living in the Bailiwick of Guernsey, used by the hospitals both on Alderney and in Guernsey. When admitted to either hospital, health, social care and community care teams can collect information about you and store it electronically on separate computer systems. TrakCare stores summary information from these organisations in one place so that – with your consent – professionals can view it to deliver better care to you. For example: if you are seen in the Treatment Room at the Mignot Hospital, the Princess Elizabeth Hospital will know that you are being seen or admitted. We do not have a direct link to Trakcare at the IMC at present but this may happen in the future. This will enable timely transfer of information which, in an emergency, may be very useful.
What do we do with your information?
The healthcare professionals who provide your care maintain records about your health. This is a record of your care history and allows health care professionals to review your care to help inform future decisions about your treatment. Sharing this information helps to improve the treatment you receive, such as a hospital consultant writing to your GP. We follow strict data sharing guidelines to keep your information safe and secure.
HOW LONG DO WE KEEP YOUR INFORMATION?
Health and social care records are subject to a nationally agreed code of practice which regulates the minimum period for which records must be kept. This specifies that GP record should be retained until 10 years after the patient’s death or after the patient has permanently left the country, unless they remain in the European Union. Electronic patient records must not be destroyed or deleted for the foreseeable future. For more information, see the records management code of practice: https://digital.nhs.uk/article/1202/Records-Management-Code-of-Practice-for-Health-and-Social-Care-2016
How do we keep your information safe?
Every member of staff who works for the IMC has a legal obligation to keep information about you confidential. We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection (Bailiwick of Guernsey) Law 2017
- General Data Protection Regulation 2017
- Data Protection Act 1998
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality, Information Security and Records Management
- IMC Practice Policy on Confidentiality
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances such as a life or death situation, or where the law requires information to be passed, or where it is in the best interest of the patient to share the information.
In May 2018, a new national regulation called the General Data Protection Regulation will come into force and the practice has a legal responsibility to ensure that we will also comply with these regulations. Locally, we are legally obliged to adhere to the Data Protection (Bailiwick of Guernsey) Law 2017 when it is enacted.
YOUR INDIVIDUAL RIGHTS
- Have inaccuracies corrected
- Have information erased
- Data portability
The practice does not engage in any direct marketing, profiling or use any automated decision making tools.
HOW CAN I ACCESS THE INFORMATION YOU HOLD ABOUT ME?
You have a right under the Data Protection legislation to request access to obtain copies of all the information the surgery holds about you. You are also allowed to have information amended should it be inaccurate.
In order to access your medical record, you need to let the practice know by making a Subject Access Request (SAR).
The practice will respond to your request within one month of receipt of your request. You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located.
It will be very helpful to the practice if you could specify any particular information you need so we can provide the information to you as soon as possible.
Usually there is no charge to see the information that the practice holds about you unless the request is excessive or complicated.
For information about your hospital or Medical Specialist Group medical records, you should write direct to them.
HOW CAN I HAVE INACCURACIES CORRECTED OR ERASED
If you feel that the personal data that the practice holds about you is inaccurate or incomplete then please let us know and we will update your records within one month of notification. If this incorrect information has been sent onwards, we will also inform any other organisations of this. If it is not possible to correct the information then we will write to you to let you know the reason behind the decision and inform you how you can complain about this.
If you feel information in your health record should not be there, you can ask the practice to erasure that information. We will look at each request specifically. Please bear in mind there may well be legal reasons why we will need to keep data even if you request it to be erased. We will explain this to you in detail in our response.
You have the right to access your data in a format which allows you to re-use and share it with other organisations should you wish. As such, we will provide your data in a structured, commonly used and machine readable form.
RIGHT TO OBJECT
As a patient, you have the right to object to personal data about you being used or shared.
You also have the right to restrict the use of data the practice holds about you. If you do wish to object, please contact the practice. This will prevent your confidential information being used other than where necessary by law.
If you are a carer and have a Lasting Power of Attorney for health and welfare then you can also object to personal data being used or shared on behalf of the patient who lacks capacity.
If you do not hold a Lasting Power of Attorney then you can raise your specific concerns with the patient’s GP. If you have parental responsibility and your child is not able to make an informed decision for themselves, then you can make a decision about information sharing on behalf of your child. If your child is competent then this must be their decision.
Should you have any concerns about how your information is managed at the practice, please contact Tracy Jean, Practice Manager. The practice will listen to your concerns and try and act upon the concerns raised as best we are able. If you are still unhappy following a review by the GP practice, you can then complain to the Responsible Officer, Dr Peter Rabey, Medical Director, HSC, Guernsey.