Privacy Notice

What is a Privacy Notice?

A Privacy Notice is a statement to patients, service users, visitors, carers, the public, and staff on how we collect, use, store, share, and delete the personal information that we use. Privacy Notices are also known as a Privacy Statement, Fair Processing Statement, or Privacy Policy.

This Privacy Notice is part of our commitment to ensure that we process personal information/data fairly and lawfully.

Who we are

Tameside and Glossop Integrated Care NHS Foundation Trust serves a community of 250,000 people across Tameside and Glossop. We provide a range of high quality elective, emergency and specialist services for adults and children.

Data Controller

Tameside and Glossop Integrated Care NHS Foundation Trust is named as the controller of the personal information.

We are registered with the Information Commissioner with the registration number Z2236125

The Trust’s Data Protection Officer

The Data Protection Officer’s role is to ensure that the personal data used within the Organisation is used responsibly, safely, and within the data protection laws.

Dan Greenwood

Data Protection Officer

Tameside and Glossop Integrated Care NHS Foundation Trust

07585 960950

dan.greenwood@tgh.nhs.uk

What is personal data and how is it collected?

Personal data is information that relates to a living individual who can be identified from that data.

These may include

  • Demographical information such as names, address, date of birth, telephone numbers, and next of kin.
  • Appointments, here at the hospital, in the community, or home visits.
  • Details and records of treatment and care, including medical notes, letters between different care providers, letters to your GP, letters to the patient, and reports on the patient's health
  • Results from x-rays and blood tests etc.
  • Information from people who care for you and know you well, such as health professionals and relatives.

We may also have information that is personal sensitive, such as sexuality, race, your religion or beliefs, and whether you have a disabilities, allergies, or health conditions.

This information is collected in a number of different ways, via your healthcare professional, referral information provided by for GP, or directly given by you. 

We also collect surveillance images/video for the prevention and detection of crime.

How we use your information

  • To help inform decisions that we make about your care.
  • To ensure that your treatment is safe and effective.
  • To work effectively with other organisations who may be involved in your care.
  • To support the health of the general public.
  • To ensure our services can meet future needs.
  • To review care provided to ensure it is of the highest standard possible.
  • To train healthcare professionals.
  • For research and audit.
  • To prepare statistics on NHS performance.
  • To monitor how we spend public money.

Additionally we use the information to

  • Improve individual care.
  • Understand more about disease risks and causes.
  • Improve diagnosis.
  • Develop new treatments and prevent disease.
  • Plan services.
  • Improve patient safety.
  • Evaluate Government, NHS and Social Care policy

It helps you because: 

  • Accurate and up-to-date information assists us in providing you with the best possible care.
  • If you see another healthcare professional, specialist or another part of the NHS, they may readily access the information they need to provide you with the best possible care.

Where possible, when using information to inform future services and provision, non-identifiable information will be used.

Who do we share your information with?

Direct Care Purposes

Unless you object, we will normally share information about you with other health and social care professionals directly involved in your care so that you may receive the best quality care. For example every time you attend the hospital as a patient, we will send your GP a summary of any diagnoses, test results or treatment given. 

You may be receiving care from other people as well as the NHS, for example Social Care Services. We may need to share some information about you with them so we can all work together for your benefit. We will only do this when they have a genuine need for it or we have your permission.

When we share your information it is subject to strict agreements on how it is protected and used, the organisations that we may share information with are:

  • Social Care Services
  • Education Services
  • Local Authorities
  • Voluntary and private sector providers working with and for the NHS

We will not disclose your information to any other third parties without your permission unless there are exceptional circumstances, such as when either your or somebody else’s health and safety is at risk; or the law requires us to pass on information.

We use the following lawful basis for direct care when processing your information:

  • Common Law Duty of Confidence
  • Health & Social Care Act, section 251 [b]
  • General Data Protection Regulation, article 6 [1] [e]
  • General Data Protection Regulation, article 9 [2] [h]

Indirect Care Purposes

We also use information we hold about you to:

  • Review the care we provide to ensure it is of the highest standard and quality
  • Ensure our services can meet patient needs in the future
  • Investigate patient queries, complaints and legal claims
  • Ensure the hospital receives payment for the care you receive
  • Prepare statistics on NHS performance
  • Audit NHS accounts and services
  • Undertake heath research and development (with your consent – you may choose whether or not to be involved)
  • Help train and educate healthcare professionals

Nationally there are strict controls on how your information is used for these purposes. These control whether your information has to be de-identified first and with whom we may share identifiable information. You can find out more about these purposes, which are also known as secondary uses, on the NHS England and NHS Digital websites:

https://www.england.nhs.uk

https://digital.nhs.uk/services

We use the following lawful basis for indirect care when processing your information:

For Research, Health & Social Care Providers, Commercial Research Partners, Arms' Length Bodies, Universities

  • Common Law Duty of Confidence
  • Health & Social Care Act, section 251 [b]
  • General Data Protection Regulation, article 6 [1] [f]
  • General Data Protection Regulation, article 9 [2] [j]

Clinical Commissioning Group/commissioning and planning purposes 

  • Common Law Duty of Confidence
  • Control of Patient Information Regulations 2002
  • General Data Protection Regulation, article 6 [1] [c]
  • General Data Protection Regulation, article 9 [2] [h]

Patient satisfaction 

We may use your details to contact you with patient satisfaction surveys relating to the services you have used. This is to improve the quality of healthcare we deliver to you.

Staff information

We process information on staff members in order to fulfil a contract of employment, the information is protected the same as patient information.

The lawful basis for processing the information related to staff is:

  • General Data Protection Regulation, article 6 [1] [e]
  • General Data Protection Regulation, article 9 [2] [b]
  • Data Protection Act 2018, article 10
  • Safeguarding Vulnerable Groups Act 2006 (DBS)

Transferring information

We only transfer information with companies whose purposes for processing match ours. It is rare that personal information is processed outside of the NHS.

No personal information is sent outside of the European Union.

How we protect your information?

It is important that we keep your information safe, secure, and available only to those who are involved in your care. To do this we restrict access using technology.

Everyone working for the Organisation is subject to the Common Law Duty of Confidentiality and the General Data Protection Regulation (2016). Information provided in confidence will only be used for your treatment unless there are other circumstances when we will ask for your consent.

Under the NHS Confidentiality Code of Conduct, all staff are required to protect your information. All staff are required to undertake annual training in data protection, information governance, and confidentiality.  In addition to this staff that access and process information on your health do so using a number of security measures including chip and PIN access to computerised medical information. Paper records are held in a secure room protected with door access controls.

We store your records and use the NHS Retention Schedule to determine how long we keep these records. The length of time is determined on the type and format of the record.

 

The retention schedule is accessible at the following address https://www.nhsbsa.nhs.uk

Your rights under the General Data Protection Regulation (2016) and Data Protection Act 2018

The Data Protection Act (1998) has been replaced by new data protection laws called the General Data Protection Regulation (GDPR) 2016 and Data Protection Act 2018. 

These laws are very similar to the old Data Protection Act (1998), with additional rights for the data subject.

These rights are:

 

Right of access by the data subject (GDPR Art 15), often called a Subject Access Request – SAR).

You have the right to receive the personal data concerning them in a commonly used electronic format for no charge. We are required to complete this request within calendar month. Additional copies of notes may incur a fee.

 

The right to rectification (GDPR Art 16), people have the right for their personal information to be changed if it is found to be incorrect.

This for instance, could be because of inaccurate personal data, how a name is spelt, to change your next of kin details, or a new address.

 

The right to restriction of processing (GDPR Art 18), people have the right to restrict how data is collected, used, and stored relating to them.

 

The right to data portability (GDPR Art 20), this is closely linked with Art 15, the Right of Access to the Data Subject. You have the right to receive the personal data concerning them in a commonly used electronic format for no charge.

 

The right to object (GDPR Art 21), under the General Data Protection Regulation you have the right to object to us processing your information.

 

If we change any of the information due to a request from you, we will contact you and tell you what we have changed.   In some cases upholding the rights to object, rectification, and the restriction data may affect the treatment you receive, and may make the provision of treatment or care more difficult or even unavailable. We may refuse to uphold the request. If this is the case we will inform you without undue delay, and within one month of the request.

We will tell you 

  • The reason why we are not taking action
  • Your right to complain to the Information Commissioners Office
  • Your right to enforce the right via legal means

 

If you require access to your health records you will need to make a written request to:

OPD/Health Records Administration Manager

Tameside & Glossop Integrated Care NHS Foundation Trust

Fountain Street

Ashton-under-Lyne

OL6 9RW

Tel 0161 922 6519

Email accesstohealthrecords@tgh.nhs.uk

The Organisation can only provide access to the information it holds. For instance, to see the records held by your GP you will have to contact your GP surgery.

If something goes wrong

We take confidentiality very seriously, should something go wrong and your data has been compromised we will contact you, and the Information Commissioner’s Office to inform of the breach.

If the incident is part of a wider breach and it is impossible to inform all those affected personally, we will contact the media news outlets to inform people of the data breach.

Contacting us/Raising a concern

If you would like to contact us or have any concerns about your care of treatment, or that of your relative we need to know about them as soon as possible, so we can take action to improve the situation.

 

Please contact:

Quality and Governance Unit

PALS and Complaints Department

Silver Springs House

Tameside and Glossop Integrated Care NHS Foundation Trust

Fountain Street

Ashton-under-Lyne

OL6 9RW

 

Tel 0161 922 4466

Email: palsandcomplaints@tgh.nhs.uk

Information Commissioner’s Office

The General Data Protection Regulation 2016 requires the Trust to lodge a notification with the Information Commissioner to describe the purposes for which we process information.

 

The details are publicly available from the Information Commissioner’s Office:

The Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Telephone: 01624 545 745

Website www.ico.gov.uk

Twitter @ICOnews

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