Privacy Policy & Data Protection

How we handle your information

Local Health Services such as hospitals, like ourselves, and GP Practices will record and keep your information to ensure you receive the best possible care.

These records include:

  • Your name, date of birth, NHS Number and contact details
  • Information about your appointments and clinical visits
  • Reports and notes about your health, treatment and care
  • Relevant information about people who care for you, such as next of kin and other Health Professionals.

This information provides essential reference for Health Professionals who you see, in all parts of the NHS. It also enables us to investigate any issues, complaints or legal claims.

All NHS Staff have a legal duty to keep your information confidential and secure and records are held securely and in the strictest confidence.

What information do we collect online?

You may choose to submit personal information about yourself (e.g. name, email, address) through the webforms we provide. By entering and submitting your details in the fields requested, you are consenting to North Bristol NHS Trust and our service providers to process your data and provide you with the services you select. Any information you provide to the North Bristol NHS Trust will only be used by us, our agents and service providers and will not be disclosed unless we are obliged or permitted to by law to do so.

Processing your Information

We process personal information to enable us to:

  • provide healthcare services for patients
  • provide feedback on services
  • data match under the national fraud initiative
  • research
  • support and manage our employees
  • maintain our accounts and records
  • use CCTV systems for crime prevention
  • use Body Worn Video Camera (BWV). There are a number of proven uses and benefits such as evidence/record of events, deterring violence and aggression, training and staff development.
  • Use Automatic Number Plate Recognition (ANPR)

Type/classes of information processed

We process relevant information including (but not limited to):

  • Personal details
  • Family details
  • Education, training and employment histories
  • Financial details
  • Goods and services
  • Lifestyle and social circumstances
  • Visual images, personal appearance and behaviour
  • Details held in the patients’ record
  • Responses to surveys

We also process ‘special category’ classes of information that may include:

  • Racial and ethnic origin
  • Offences and alleged offenses
  • Criminal proceedings, outcomes and sentences
  • Trade union membership
  • Physical and mental health details
  • Religion and beliefs
  • Sexual life
  • Genetic data
  • IP addresses

We process personal information about:

  • Our patients
  • Suppliers
  • Employees
  • Complainants, enquirers
  • Survey respondents
  • Professional experts and consultants
  • Individuals captured by CCTV or BWV images

Sharing information

We sometimes need to share the personal information we process with the individual themselves and also with other organisations. Where this is necessary we are required to comply with all aspects of general data protection regulation, both UK and globally. Only information that is relevant will be shared following the seven principles of information sharing (Caldicott2 Principles):

  • Formal justification of purpose
  • Information transferred when absolutely necessary
  • Only the minimum required
  • Need to know access controls
  • All to understand their responsibilities
  • Comply with and understand the law
  • The duty to share information can be as important as the duty to protect patient confidentiality.

Where necessary or required we share information with:

  • Our patients
  • Family, associates and representatives of the person whose personal data we are processing
  • Staff
  • Current, past or potential employers
  • Healthcare, social and welfare organisations
  • Suppliers, service providers, legal representatives
  • Auditors and audit bodies
  • Survey and research organisations
  • People making an enquiry or complaint
  • Financial organisations
  • Professional advisers and consultants
  • Business associates
  • Police forces
  • Security organisations
  • Central and local government
  • Voluntary and charitable organisations
  • Community Pharmacists – regarding discharge information (for patient follow up and for patients requiring compliance devices)
  • Regulatory bodies; e.g. Care Quality Commission (CQC).

Legal Basis for Processing - What are the lawful bases for processing?

The lawful bases for processing are set out in Article 6 of the General Data Protection Regulations.

At least one of these must apply whenever we process personal data:

(a) Consent: you have given clear consent for us to process your personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract we have with you or because you have asked us to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. (This cannot apply if we are a public authority processing data to perform our official tasks.)

We collect and process your Personal Data for a variety of purposes as outlined in this Privacy Policy. 
In many cases, separate consent is not required and therefore we will rely on another ‘legal basis for processing’; these purposes could include:

  • For the purpose of a contract
  • To meet legal obligations
  • For legitimate interests
    • Communication
    • Respond to your requests
    • Promotional messages
    • Surveys
    • Compliance with Law and Public  Safety
    • Improvement & Development
    • Enforcing Terms and Notice

We would obtain consent for the following reasons:      

Consent as a Basis for Processing:

  • Marketing & Communication
  • Sharing with 3rd Party Services

We would also process Personal Identifiable Data potentially for:

  • Research
  • Advertising & communication
  • Transfer of Data
  • Automated processing
  • To enable social sharing and connect with us on social media

Managing preferences and withdrawing consent

Consent means offering individuals genuine choice and control. Under the General Data Protection Regulation, consent requires a positive opt-in. 

We will not use pre-ticked boxes or any other method of consent by default.

As explicit consent requires a very clear and specific statement of consent, we will ensure that this is done.

  • We will keep consents separate from other terms and conditions
  • Be specific and granular, clear and concise
  • We will name any third party controllers who will rely on consent as required
  • Make it easy for people to withdraw consent.

We will:

  • keep evidence of consent - who, when, how and what individuals were told
  • keep consent under review and refresh if and when anything changes
  • avoid making consent a precondition of a service.

Using personal information in the wider Health Service

In recent years the NHS has changed the way we share patient information among Health Professionals indifferent settings e.g. Hospitals, GP practices, Urgent Care Centres.

To prevent delay and ensure safe treatment, especially in urgent situations, doctors and other specialists may access essential parts of your record electronically, rather than writing to or phoning your GP or other Healthcare Professionals involved in you treatment and care.

The NHS nationally and locally currently uses three systems to share information electronically. These are all currently ‘opt out schemes’, meaning that your records are automatically included unless you opt out of each Individual scheme.

Summary Care Record

The Summary Care Record (SCR) is a secure national electronic record, enabling doctors and health specialists to access information about you that could be vital in an emergency or out-of-hours situation.
The records went live in the local area during 2014/215.
Records for each individual will be created automatically.
This will enable NHS staff caring for you anywhere in England to access the following information to support your care in an emergency:

  • Any medicines you are taking
  • Any allergies you have
  • Any bad reactions you had to medicines

Healthcare staff will ask your permission before they look at your record except in certain circumstances (e.g. if you are unconscious).

How to Opt-Out of the Summary Care Record

You can download the ‘opt-out form’ at NHS Care Records and give this to your GP. For more information, speak with the Patient Advice & Liaison Service (PALS) on 0800 0730907 or 0117 9474477 or visit NHS Care Records for information about Summary Care Records in other languages or formats.

Connecting Care Records

Connecting Care is a local electronic patient record that allows health and social care professionals directly involved in your care, to share a summary of your medical record.

Your Connecting Care record will help those caring for you to manage your care better, and allow information to be shared quickly and safely. Only authorised staff providing health services across Bristol,

South Gloucestershire and North Somerset can access your record.

For more information about Connecting Care, visit the Connecting Care website at www.connectingcarebnssg.co.uk which includes information on:

  • What Connecting Care is
  • Why share information
  • How information is protected
  • How to Opt Out/In

NHS Care.Data

NHS Care.Data is a national information sharing project managed by the Health & Social Care Information Centre (HSCIC).
It enables sharing of anonymous patient data to support Health research and planning. Your identity is not shared.

While the data is not used directly for your care, it helps researchers to see how well services are performing and how patient care can be improved for everyone. Your record is automatically included, unless you ‘opt out’.

The NHS has been using information from hospitals health records this way for decades, but it is planning to extend this to include some information from GP’s.
Find out more at NHS England

The HSCIC follows strict rules about how information is collected and shared, in line with the law, national guidance and best practice.
To find out more about how your identity and records are protected, stored and shared, visit www.gov.uk/government/speeches/review-of-health-and-care-data-security-and-consent

How to Opt Out of NHS Care.Data

Speak with your GP. They may ask you to complete a form to indicate what information you are not happy to share. Even if you have already opted out of SCR and Connecting Care, you will still need to opt out of NHS.Care.

Changes to our policy

If our privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing the page ensures you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

Last updated: 23 May 2018