Policies

Introduction and background

The Accessible Information Standard (AIS) is a new mandatory information standard for implementation by all GP practices by 31^st July 2016

The AIS aims to ensure that people who have a disability or sensory loss receive information that they can access and understand (for example in large print, braille or via email and professional communication support if they need it such as an interpreter or sign language interpreter.

The standard directs and defines a specific, consistent approach to identifying, recording, flagging, sharing and meeting the information and communication support needs of patients, service users, carers and parents, where those needs relate to a disability, impairment or sensory loss.

It is particularly relevant to individuals who are blind, deaf, deafblind and/or have a learning disability, although it will support anyone with information or communication needs relating to a disability, impairment or sensory loss, for example those who have a mental health condition which affects their ability to communicate.

Scope

This policy applies to all staff working in the practice so they are aware of their responsibilities to all our patients. All staff within the Practice will endeavour to ascertain whether patients have specific needs they require in order for them to be fully involved in their care.

This will be done via the New Patient Registration Form and opportunistically during patient contact.

The New Patient Registration Form has a section where patients can alert the practice to any specific needs they may have.

Specific needs include:

• Sensory impairment, i.e. speech, hearing, sight
• Physical disability
• Mental disability
• Religious or cultural needs
• Translation/interpretation
• Allergies and sensitivities
• Has or is a carer
• Access to premises

1. The information will be transferred to the Patient Record to ensure that their specific needs are identified
2. The patient’s record will be highlighted so it is clear there are information or communication needs and clearly explain what those needs are
3. This information will be shared with other NHS organisations, when required, if the practice has the consent to do so.
4. The practice will make sure patients get information in an accessible way and communication support if they need it

Patients should be aware that this may not be instant and may take some time to organise depending what the request is

Meeting the needs of our patients

Hilltop Medical Practice will endeavour to provide one or more communications or contact methods which are accessible to and useable by the patient, service user, carer or parent.  The method must enable the individual to contact the service and staff MUST use this method to contact the individual.

Procedures

1. Web-site to be updated to advise of Introduction of AIS
2. Notices to be displayed on patient noticeboard
3. All receptionists to be briefed
4. Report to be run to identify all patients that may have accessibility issues. Individuals most likely to be affected by the Standard include people who are blind or deaf, who have some, hearing or visual loss, people who are deafblind and people with a learning disability. However, this list is not exhaustive.  The report will be run every 6 months.
5. Ensure that we have a method of obtaining leaflets in Braille.
6. Ensure all leaflets for any campaigns eg Flu are also available in an easy-read version with large font
7. Ensure that we always have the hearing aid loop on at the main reception desk and that is visible and available at all times
8. Any appointments for patients with these needs, should always be a double appointment
9. Guide dogs should be welcomed into the surgery and accommodated within the consulting rooms

Your Information, Your Rights

Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR).

The following notice reminds you of your rights in respect of the above legislation and how your GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.

This notice reflects how we use information for:

• The management of patient records;
• Communication concerning your clinical, social and supported care;
• Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
• Participation in health and social care research; and
• The management and clinical planning of services to ensure that appropriate care is in place for our patients today and in the future.

 Data Controller

As your registered GP practice, we are the data controller for any personal data that we hold about you.

 What information do we collect and use?

All personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to your care.

We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:

• ‘Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data. This includes, but is not limited to name, date of birth, full postcode, address, next of kin and [NHS number, Hospital number];

And

• ‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.

Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services). These records may be electronic, a paper record or a mixture of both. We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.

 Why do we collect this information?

 The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training. To do this we will need to process your information in accordance with current data protection legislation to:

• Protect your vital interests;
• Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
• Perform tasks in the public’s interest;
• Deliver preventative medicine, medical diagnosis, medical research; and
• Manage the health and social care system and services.

How is the information collected?

 Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection. In addition physical information will be sent to your practice. This information will be retained within your GP’s electronic patient record or within your physical medical records.

Who will we share your information with?

 In order to deliver and coordinate your health and social care, we may share information with the following organisations:

• Local GP Practices in order to deliver extended primary care services
• NHS [Local hospital Trusts/Brent CCG/NHS England/Public Health England]
• 111 and Out of Hours Service
• Local Social Services and Community Care services
• Voluntary Support Organisations commissioned to provide services by Brent CCG

Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.

Your information will not be transferred outside of the European Union.

 Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.

 How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information that has been collected lawfully. Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.

Information is not held for longer than is necessary.   We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.

Consent and Objections

Do I need to give my consent?

The GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation. However consent is only one potential lawful basis for processing information. Therefore your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice. Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice. Your consent will be documented within your electronic patient record.

What will happen if I withhold my consent or raise an objection?

You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing. Please contact your GP Practice for further information and to raise your objection.

Health Risk Screening / Risk Stratification

Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health. By using selected information such as age, gender, NHS number, diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.

To summarise Risk Stratification is used in the NHS to:

• Help decide if a patient is at a greater risk of suffering from a particular condition;
• Prevent an emergency admission;
• Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
• Review and amend provision of current health and social care services.

Your GP will use computer based algorithms or calculations to identify their registered patients who are at most risk, with support from the local Commissioning Support Unit and/or a third party accredited Risk Stratification provider. The risk stratification contracts are arranged by Brent CCG in accordance with the current Section 251 Agreement. Neither the CSU nor your local CCG will at any time have access to your personal or confidential data. They will only act on behalf of your GP to organise the risk stratification service with appropriate contractual technical and security measures in place.

Your GP will routinely conduct the risk stratification process outside of your GP appointment. This process is conducted electronically and without human intervention. The resulting report is then reviewed by a multidisciplinary team of staff within the Practice. This may result in contact being made with you if alterations to the provision of your care are identified.

A Section 251 Agreement is where the Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers.

As mentioned above, you have the right to object to your information being used in this way. However you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.

Sharing of Electronic Patient Records within the NHS

Electronic patient records are kept in most places where you receive healthcare. Our local electronic systems (such as SystmOne, EMIS and Eclipse) enables your record to be shared with organisations involved in your direct care, such as:

• GP practices
• Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
• Child health services that undertake routine treatment or health screening
• Urgent care organisations, minor injury units or out of hours services
• Community hospitals
• Palliative care hospitals
• Care Homes
• Mental Health Trusts
• Hospitals
• Social Care organisations
• Pharmacies

In addition, NHS England have implemented the Summary Care Record which contains information including medication you are taking and any bad reactions to medication that you have had in the past.

In most cases, particularly for patients with complex conditions and care arrangements, the shared electronic health record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health. Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so. The shared record means patients do not have to repeat their medical history at every care setting.

Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to disable this function or restrict access to specific elements of your record. This will mean that the information recorded by your GP will not be visible at any other care setting.

You can also reinstate your consent at any time by giving your permission to override your previous dissent.

 Your Right of Access to Your Records

The Data Protection Act and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format. This is known as the “right of subject access”. If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information. This can be your GP, or a provider that is or has delivered your treatment and care. You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party. If you would like access to your GP record please submit your request in writing to:

Dr Neeta Ghosh-Chowdhury

 Eye Screening for Diabetics

The Practice shares your diabetes related data with the Diabetic Eye Screening Programme operated by Health Intelligence (commissioned by NHS England). This supports your invitation for eye screening (where you are eligible and referred by the Practice) and ongoing care by the screening programme. This data may be shared with any Hospital Eye Services you are under the care of to support further treatment and with other healthcare professionals involved in your care, for example your Diabetologist.

For further information, take a look at Health Intelligence’s Privacy Notice on the diabetic eye screening website: www.nwldesp.co.uk

Data Sharing Measure in relation to the COVID pandemic

1)      The secretary of state has served notice under the Health Service COPI (Control of Patient Information) Regulations 2002 to require organisations to process confidential patient information during the COVID Pandemic and these measures will remain in place until September 2020. In addition, aggregate data which supports the planning and delivery of health care during the COVID pandemic will be processed securely through the Whole Systems Integrated Care database. Any such data will be formally identified as COVID related and used only for this purpose until Sep 2020.

2)      Primary care staff across each CCG will be able to access your full medical record without consent during the COVID-19 pandemic but will only do so when this is necessary to provide you with care. They will be required to use a smartcard which confirms their identity, and which limits their access and actions to those appropriate for their role. They will all have been trained to understand their professional and legal responsibilities in providing you with care. Access to records by trained clinicians will be made available for example when patients:

are asked to present to the Respiratory Hubs offering care for COVID related illness

are directed to other hubs based services for routine face to face, or telephone or video consultation

require community visiting services

3)      The extension to smart card permissions is currently limited to CCG wide sharing, but in the event of the pandemic escalating we have taken measures to implement NWL wide sharing and will notify patients through this Fair Processing Notice, should that need arise.

4)   The government have requested reinstatement of the “break glass” facility” previously available in TPP clinical systems so as to allow a declared access to patient records in the event of an emergency.

Complaints

In the event that your feel your GP Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager at:

Hilltop Medical Practice

150 Hilltop Avenue, London NW10 8RY

If you have any questions or concerns regarding the information Brent CCG holds on you or the use of your information, please contact them at:

Information Governance
BEHH Federation
The Heights
59 – 65 Lowlands Road
Harrow-on-the-Hill
Middlesex
HA1 3AW

If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wimslow, Cheshire SK9 5AF – Enquiry Line: 01625 545700 or online at www.ico.gov.uk

NHS England require that the net earnings of GPs engaged in the practice is publicised and the required disclosure is shown below.  However, it should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time GPs spend working in the practice and it should not be used to form any judgement about GP earnings nor to make any comparison with any other practice.

All GP practices are required to declare the mean earnings (i.e. average pay) for GPs working to deliver NHS services to patients at each practice.

The average pay for GPs working in Hill Top Medical Practice in the last financial year (ending 2022)was £47,866 before tax and national insurance.  This is for 1 full time GPs and 4 locum GP who worked in the practice for more than six months.

From April 2014, all patients aged 75 and had a named GP who had overall responsibility for the care and support that our surgery provided to them.

From now on, ALL patients regardless of age will have a named GP ( Dr Neeta Ghosh-Chowdhury) who is responsible for their overall care. She will also work with other relevant health and care professionals, who are involved in your care, to ensure that your care package meets your individual needs. This does not mean that you will have to only see her and you can still request to see a Doctor of your choice at the Practice. Please contact reception if you have any questions.

What is non-NHS work and why is there a fee?

Our Primary Care Team is committed to safeguarding children. The safety and welfare of children who come into contact with our services either directly or indirectly is paramount, and all staff have a responsibility to ensure that Best Practice is followed, including compliance with statutory requirements.

We are committed to a Best Practice which safeguards children and young people irrespective of their background, and which recognises that a child may be abused regardless of their age, gender, religious beliefs, racial origin or ethnic identity, culture, class, disability or sexual orientation.

The Primary Care Team are committed to working within agreed policies and procedures and in partnership with other agencies, to ensure that the risks of harm to a child or young person are minimised. This work may include direct and indirect contact with children, access to patient’s details and communication via email or text message/telephone.

Our Surgery is supported by the CCG who have designated Nurses and Doctors in post who offer professional expertise and advice regarding safeguarding children.

There is a new Central NHS Computer System called the Summary Care Record (SCR). It is an electronic record which contains information about the medicines you take, allergies you suffer from and any bad reactions to medicines you have had.

Why do I need a Summary Care Record?

Storing information in one place makes it easier for healthcare staff to treat you in an emergency, or when your GP practice is closed.

This information could make a difference to how a doctor decides to care for you, for example which medicines they choose to prescribe for you.

Who can see it?

Only healthcare staff involved in your care can see your Summary Care Record.

How do I know if I have one?

Over half of the population of England now have a Summary Care Record. You can find out whether Summary Care Records have come to your area by looking at our interactive map or by asking your GP

Do I have to have one?

No, it is not compulsory. If you choose to opt out of the scheme, then you will need to complete a form and bring it along to the surgery. You can use the form at the foot of this page.

More Information

For further information visit the NHS Care records website

Download the opt out form >>>>

What is Integrated Care?

Today, health and social care is delivered by different organisations that work separately. Organisational boundaries can prevent professionals from working together to provide the kind of high quality, joined up support that people expect and want. We want to change this so people and their goals are at the centre of a team of health and care professionals who work together smoothly. This will mean unlocking the social capital in our communities, viewing the energy, compassion, skills and learning of local people as valuable assets. We want to enable individuals, community groups, charities, local organisations and services to work effectively together.

Integrated care means integrated care teams that are focussed on individual people and their needs. Bringing together all the different parts of the health and social care system will provide better communication and sharing of relevant information to reduce duplication and confusion for individuals, carers and staff. This will mean one set of goals agreed by the individual, supported by one team, one approach.

Hilltop Medical Practice is working with Health and Social Care in order to provide the most flexible, patient centre Care. We are participating in the Whole Systems Integrated Care Scheme. Please see below for more details.

Patient INformation Sheet

Frequently Asked Questions

Opt Out Form