Privacy Policy
This site uses cookies for marketing, personalisation, and analysis purposes. You can opt out of this at any time or view our full privacy policy for more information.
Moffat Medical Practice has a legal duty to explain how we use any personal information we collect about you, as a registered patient at the practice. Staff at this practice maintains records about your health and the treatment you receive in electronic and paper format.
What information do we collect about you?
We will collect information such as personal details, including name, address, next of kin, records of appointments, visits, telephone calls, your health records, treatment and medications, test results, X-rays, etc. and any other relevant information to enable us to deliver effective medical care.
How we will use your information
Your data is collected for the purpose of providing direct patient care; however, we can disclose this information if it is required by law, if you give consent or if it is justified in the public interest. The practice may be requested to support research; however, we will always gain your consent before sharing your information with medical research databases such as the Information Services Division Scotland (ISD Scotland) or others when the law allows.
In order to comply with its legal obligations, this practice may send data to ISD Scotland when directed by the Secretary of State for Health under the The Public Health (Scotland) Act 2008. Additionally, this practice contributes to national clinical audits and will send the data that is required by ISD Scotland when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form; for example, the clinical code for diabetes or high blood pressure.
Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the GDPR.
Maintaining confidentiality and accessing your records
We are committed to maintaining confidentiality and protecting the information we hold about you. We adhere to the General Data Protection Regulation (GDPR), the NHS Codes of Confidentiality and Security, as well as guidance issued by the Information Commissioner’s Office (ICO). You have a right to access the information we hold about you, and if you would like to access this information, you will need to complete a Subject Access Request (SAR). Please ask at reception for a SAR form and you will be given further information. Furthermore, should you identify any inaccuracies; you have a right to have the inaccurate data corrected.
Telephone Call Recording Policy
The General Data Protection Regulation (GDPR) protects personal information held by organisations on computer and relevant filing systems. It enforces a set of standards for the processing of such information. In general terms, it provides that all data shall be used for specific purposes only and not used or disclosed in a way that is incompatible with these purposes.
In the course of its activities the Practice will collect, store and process personal data, including the recording of all telephone calls and it recognises that correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
The Practice is registered with the Information Commissioner under the GDPR.
The purpose of recording incoming and outgoing calls:
- Identify practice staff training needs
- Protect practice staff from abusive or nuisance calls
- Protect the interests of both parties
- Establish facts relating to incoming/outgoing calls made (for example for complaints)
- Identify any issues in practice processes with the view to improve them
Telephone consultations are recorded in the medical record in the same way as a face-to-face consultation and retained for the same period as the rest of the medical record. The telephone call is not stored in the medical record.
Purpose of this Policy
To ensure that telephone call recordings are in compliance with the GDPR. We will make every effort to advise callers that their call will be recorded and for what purpose the recording may be used. This will be via a pre-recorded message within the telephone system, in our practice leaflet and on the website.
The voice file will be stored within the telephone system to which the same rules of confidentiality will apply.
The recordings are stored securely on a system provided by FocusGroup for 12 months, after which they are automatically deleted (with the exception of an ongoing complaint that has not yet completed). They are protected through the company’s Data Protection Policy which is compliant with GDPR legislation.
If patients request to listen to a recorded telephone call, this should be allowed within the general provision of Data Subject Access request under the Data Protection Act 2018. This will be authorised by a Partner or the Practice Manager/Data Controller.
Overview
The policy applies to all practice staff. All calls via the telephone system in the practice will be recorded, including:
- External incoming calls
- External outgoing calls made by staff and clinicians
- Call transfers
Recording automatically stops when the call is terminated by a member of our team.
Playback and Monitoring of Recorded Calls
This will be undertaken by the Practice Manager/Data Controller and/or Partners and Senior staff. This would take place in a private setting and, where applicable, individuals would be given the opportunity to listen to the calls and receive feedback and support. Developmental in the case of staff.
Access to all recordings is controlled, managed by senior staff and stored securely.
Requests for copies of telephone conversations can be made under the Data Protection Act as a Subject Access Request. An assessment will be made whether the information can be released and the requester will be invited to the practice to hear the recording.
If an external body makes a request relating to detection or prevention of a crime (for example police), requests for information should be directed to the Practice Manager/Data Controller.
Risk stratification
Risk stratification is a mechanism used to identify and subsequently manage those patients deemed as being at high risk of requiring urgent or emergency care. Usually this includes patients with long-term conditions, e.g. cancer. Your information is collected by a number of sources, including SPIRE (NHS National Services Scotland), NHS Dumfries and Galloway and Local Intelligence Support Team; this information is processed electronically and given a risk score which is relayed to your GP who can then decide on any necessary actions to ensure that you receive the most appropriate care.
eConsult Privacy Policy
Please click on the link below for details of eConsult Health Limited Privacy Policy:
https://econsult.net/privacy-policies
iGDPR Managed Service Privacy Notice
We use a processor, iGPR Technologies Limited (“iGPR”), to assist us with responding to report requests relating to your patient data, such as subject access requests that you submit to us (or that someone acting on your behalf submits to us) and report requests that insurers submit to us under the Access to Medical Records Act 1988 in relation to a life insurance policy that you hold or that you are applying for. iGPR manages the reporting process for us by reviewing and responding to requests in accordance with our instructions and all applicable laws, including UK data protection laws. The instructions we issue to iGPR include general instructions on responding to requests and specific instructions on issues that will require further consultation with the GP responsible for your care.
Medlink Privacy Notice
The Medlink privacy notice can be found at https://medlink.co.uk/privacy/
Invoice validation
Your information may be shared if you have received treatment to determine which NHS Area Health Board is responsible for paying for your treatment. This information may include your name, address and treatment date. All of this information is held securely and confidentially; it will not be used for any other purpose or shared with any third parties.
Opt-outs
You have a right to object to your information being shared. Should you wish to opt out of data collection, please contact a member of staff who will be able to explain how you can opt out and prevent the sharing of your information; this is done by registering a Type 1 opt-out, preventing your information from being shared outside this practice.
Retention periods
In accordance with the NHS Codes of Practice for Records Management, your healthcare records will be retained for 10 years after death, or if a patient emigrates, for 10 years after the date of emigration. *Electronic Patient Records (EPRs) – GP only- must not be destroyed, or deleted, for the foreseeable future. See link for further clarification of retention periods:
http://www.gov.scot/Publications/2010/04/20142935/8
What to do if you have any questions
Should you have any questions about our privacy policy or the information we hold about you, you can:
- Contact the practice’s data controller by phone 01683 220062 or via email at dg.gpadmin-y18659@nhs.scot. (GP practices are data controllers for the data they hold about their patients.)
- Write to the data controller at: Moffat Medical Practice, The Surgery, High Street, Moffat, DG10 9JP
- Ask to speak to the Practice Manager Mr Robert Denston
The Data Protection Officer (DPO) forMoffat Medical Practice is Mr John McGonigle and he is based at NHS Dumfries & Galloway, Data Protection Dept., Second Floor Central Core, Mountainhall Treatment Centre, Bankend Road, Dumfries. DG1 4AP.
Changes to our privacy policy
We regularly review our privacy policy and any updates will be published on our website and on posters to reflect the changes. This policy will be reviewed annually.