Practice Policies & Patient Information
The aim of the practice is to provide good family medicine in conditions conducive to matching the high expectations of our patients.
In addition of our normal service there are facilities for minor surgical operations, ECG’s, full medical examinations, and vaccinations for travel abroad.
Both surgeries have ample facilities and disabled people are well catered for.
The surgery is fully computerised.
Care Data Programme
Information about you and the care you receive is shared, in a secure system, by healthcare staff to support your treatment and care.
It is important that we, the NHS, can use this information to plan and improve services for all patients. We would like to link information from all the different places where you receive care, such as your GP, hospital and community service, to help us provide a full picture. This will allow us to compare the care you received in one area against the care you received in another, so we can see what has worked best.
Information such as your postcode and NHS number, but not your name, will be used to link your records in a secure system, so your identity is protected. Information which does not reveal your identity can then be used by others, such as researchers and those planning health services, to make sure we provide the best care possible for everyone.
How your information is used and shared is controlled by law and strict rules are in place to protect your privacy.
We need to make sure that you know this is happening and the choices you have.
Chaperone Policy
Introduction
This policy is designed to protect both patients and staff from abuse or allegations of abuse and to assist patients to make an informed choice about their examinations and consultations.
Guidelines
A chaperone can be requested by either
- The patient or
- The clinician
Patients who request a chaperone should never be examined without a chaperone being present.
Who Can Act as a Chaperone?
Chaperones should be clinical staff familiar with procedural aspects of personal examination. On the very rare occasion when this is not possible then a member of staff who has received formal training as a Chaperone can be used.
Confidentiality
The chaperone should only be present for the examination itself, and most discussion with the patient should take place while the chaperone is not present.
Patients should be reassured that all practice staff understand their responsibility not to divulge confidential information.
Procedure
- The clinician will contact reception to request a chaperone.
- Where no chaperone is available, a clinician may offer to delay the examination to a date when one will be available, as long as the delay would not have an adverse effect on the patient’s health.
- If a clinician wishes to conduct an examination with a chaperone present but the patient does not agree to this, the clinician must clearly explain why they want a chaperone to be present. The clinician may choose to consider referring the patient to a colleague who would be willing to examine them without a chaperone, as long as the delay would not have an adverse effect on the patient’s health.
- The clinician will record in the notes that the chaperone is present, and identify the chaperone.
- The chaperone will enter the room discreetly and remain in the room until the clinician has finished the examination.
- The chaperone will normally attend inside the curtain at the head of the examination couch and watch the procedure.
- To prevent embarrassment, the chaperone should not enter into conversation with the patient or GP unless requested to do so, or make any mention of the consultation afterwards.
Children Privacy Notice
What is a privacy notice and why does it apply to me?
A Privacy Notice tells people how organisations use information that they hold about them. A new law called the UK General Data Protection Regulation 2016, also known as UKGDPR, says that we need to provide you with this Privacy Notice and let you know:
- What information we hold about you
- How we keep this especially important information safe and secure and where we keep it
- How we use your information
- Who we share your information with
- What your rights are
- When the law gives us permission to use your information
Why does the law give you permission to use my information?
The law gives us permission to use your information in situations where we need it to take care of you. Because information about your health is very personal, sensitive and private to you, the law is very strict about how we use it.
So, before we can use your information in the ways we have set out in this Privacy Notice, we have to have a good reason in law, which is called a ‘lawful basis’. Not only do we have to do that, but we also have to show that your information falls into a special group or category, because it is very sensitive. By doing this the law makes sure we only use your information to look after you and that we do not use it for any other reason.
If you would like more information about this please ask to speak to our Data Protection Officer (DPO) mentioned in this Privacy Notice who will explain this in more detail.
About Us
We, at Dr A Sulakshana and Partners, are responsible for collecting, storing and handling your information when you registered with us as a patient. Because we do this, the law says we are Data Controllers. Sometimes we may use your information for a particular purpose and when we do so, the law says we are Data Processors.
What information do you hold about me?
We hold information about you such as:
- Your name
- Address
- Mobile number
- Information about your parent(s) or person with parental responsibility
- All your health records
- Appointment records
- Visits to see your GP
- Treatments you have had
- Medicines prescribed for you and any other information to help us look after you
How do you keep it safe?
- The law says that we must do all we can to keep your information private, safe and secure.
- We use secure computer systems and we make sure that any written information held about you is under lock and key and kept in a safe place. This includes taking great care with any passwords we use which we change on a regular basis. We also train our staff to respect your privacy and deal with your information in a manner that makes sure it is always kept and dealt with in a safe way.
What do you do with my information?
- We only usually use your information to help us care for you. That means we might need to share your information with other people who are concerned and involved with looking after your health.
- We might need to share your information with the police, courts, social services, solicitors and other people who have a right to your information, but we always make sure that they have a legal right to see it (or have a copy of it) before we provide it to them.
Who else will see my information?
- Usually only doctors, nurses and other people who work with us are allowed to see your information.
- Sometimes though, if you need to go to the hospital or be seen by a special doctor, we will share your information with them but this only so that we can take care of you.
- Sometimes we might be asked to take part in medical research that might help you in the future. We will always ask you or your parent(s) or adult with parental responsibility if we can share your information if this happens.
- Possibly the police, social services, the courts and other organisations and people who may have a legal right to see your information.
What are my rights?
- If you want to see what information we hold about you then you have a right to see it and you can ask for it.
- To ask for your information you will usually need to put your request in writing and tell us what information you want us to give you.
- We usually need to answer you within one month. Your parent(s) or adult with parental responsibility can help you with is if you need help.
- Usually we will give this to you free of charge.
- If you think there are any errors in the information we hold about you then you can ask us to correct it but the law says we can’t remove any of the information we hold about you even if you ask us to. This is because we need this information to take care of you.
- You have a right to ask us not to share your information.
- If you would like to talk to us about not sharing your information, even if this means you don’t want us to share your information with your parent(s) or adult with parental responsibility, please let us know. We will be happy to help.
What if I have a question?
- A member of our staff/receptionist will be happy to talk to you about any questions you may have and we will do our best to help you.
- The Surgery has a person called a Data Protection Officer (DPO) who deals with all queries about patient information. Our receptionist may put you in touch with this person who will listen to your concerns and give you the advice you need.
- The Data Protection Officer for the for the GPs for the Bedfordshire Luton and Milton Keynes GP Practices signed to Arden and GEMCSU is:Judith Jordan, Arden & GEM Head of Integrated Governance, but we have a team who carry out the function, the contact details are:
- Email:agem.dpo@nhs.net
- Telephone: 0121 611 0730
What if I have a serious complaint about how you look after my information?
- We will always do our best to look after your information and to answer your questions.
- If you are still not happy with something we have done with your information you can speak to our DPO.
- If our DPO has not been able to help you or if you prefer not to speak to our DPO then you have a right to pass your complaint to an organisation called the Information Commissioner’s Office (ICO) who will look into what has gone wrong. For more information visit ico.org.uk
Updates to this privacy notice
- The law says we must keep all information we provide in this Privacy Notice up to date.
- This Privacy Notice was last updated on 01/07/2025 and will be reviewed on 01/07/2026
Complaints
Our aim is to provide the highest level of care for all our patients. We will always be willing to hear if there is any way that you think we can improve the service we provide.
Making a complaint:
If you have a complaint or concern about the service that you have received from the doctors or staff working for this practice, please speak to our receptionists and they will advise you of the procedure.
We hope that most problems can be sorted out easily and quickly, often at the time they arise and with the person concerned. If your problem cannot be sorted out in this way and you wish to make a complaint, we would like you to let us know as soon as possible in writing, ideally within a matter of days or at most a few weeks because this will enable us to establish the facts in a timely manner. If it is not possible to do this, please let us have details of your complaint:
- Within 12 months of the incident that caused the problem or
- Within 12 months of discovering that you have a problem, provided it is within 12 months of the incident.
Please complete the complaints form below:
Please submit your complaint in writing and give as much information as you can. Send your complaint to the practice for the attention of the Practice Manager as soon as possible. Alternatively, you can email your complaint to barton.letters@nhs.net
Complaining on Behalf of someone else:
Please note that we keep strict rules of medical confidentiality. If you are complaining on behalf of someone else, we must know that you have their permission to do so. A note signed by the person concerned will be required.
Help us to get it right
We constantly try to improve the service we offer.
Please let us know when you think we have done something well or if you have any suggestions as to how we can do something better.
Confidentiality
All staff working within the NHS have a legal duty of confidentiality towards patients which is written into their Contract of Employment.
No information concerning a patient will be given to a third party without the consent of the patient involved.
We adhere strictly to the Data Protection Act.
COVID-19 Privacy Notice
Expansion of the OpenSAFELY secure COVID-19 research platform
NHS England has been directed by the government to establish and operate the OpenSAFELY COVID-19 Service and the OpenSAFELY Data Analytics Service. These services provide a secure environment that supports research, clinical audit, service evaluation and health surveillance for COVID-19 and other purposes.
Each GP practice remains the controller of its own GP patient data but is required to let approved users run queries on pseudonymised patient data. This means identifiers are removed and replaced with a pseudonym.
Only approved users are allowed to run these queries, and they will not be able to access information that directly or indirectly identifies individuals.
Patients who do not wish for their data to be used as part of this process can register a type 1 opt out with their GP.
Here you can find additional information about OpenSAFELY
GP Earnings
All GP practices are required to declare the mean earnings (e.g. average pay) for GPs working to deliver NHS services to patients at each practice.
The average pay for GPs who worked for six months or more in The Surgery in the last financial year was £74,177 before Tax and National Insurance. This is for 3 full-time GP’s and 4 part-time GP’s.
Information we hold about you
The main reasons for which your information may be needed are:
- Giving you health care and treatment
- Looking after the health of the general public
- Managing and planning the NHS – for example
- Making sure that our services can meet patients needs in the future
- Preparing anonymous statistics on NHS performance and activity
- Investigating complaints or legal claims
- Helping staff to review the care they provide to make sure it is of the highest standard
- Training and educating staff
- Research approved by the Local Research Ethics Committee.
(If anything to do with the research would involve you personally, you will be contacted to see if you are willing).
If at any time you would like to know more about how we use your information you can speak to Jo Penlington Practice Manager.
National Data Opt-Out Programme
NHS Digital is developing a new system to support the national data opt-out which will give patients more control over how confidential patient information is used. The system will offer patients and the public the opportunity to make an informed choice about whether they wish their confidential patient information to be used just for their individual care and treatment or also used for research and planning purposes.
Patients and the public who decide they do not want their confidential patient information used for planning and research purposes will be able to set their national data opt-out choice online.
For further opt-out information, please visit the NHS Digital site:
And if you would like to opt-out, you can follow the process using the link below;
Our practice policy on this subject is available to review below:
Patient Dignity and Respect Policy
This policy sets out the practice provision to ensure that patients are afforded privacy and dignity, and are treated respectfully, in all appropriate circumstances where there is the potential for embarrassment or for the patient to feel “ill at ease”.
The requirement to respect patients is the responsibility of all staff, not just those in direct clinical contact with the patient.
Vulnerable patients in this respect may include:
- Elderly
- Infirm
- Disabled
- Those with racial or cultural beliefs
- Illiterate
- Homeless / no fixed abode
- Those with specific conditions
- Patients with communication difficulties
- Those patients with gender requirements
- Those known to staff / known by staff
- Family members
- Patients from minority groups
General
- The Practice will not stereotype patients based on perceived characteristics
- Patients will be referred to with respect even in private discussions in the surgery
- Patients will be addressed by their preferred method and titles. Mr, Mrs etc. will be used as a first preference by staff
- Guide dogs will be permitted in all parts of the building.
- A hearing loop will be installed
- Under no circumstances will staff enter through a closed consultation room / treatment room door without first knocking, and waiting for permission to enter (if occupied), or pausing to determine that the room is empty
Consultations
- Patients will be allowed free choice of gender of doctor and nurse, where available, and will be able to wait or delay an appointment to see their choice of clinician. Where clinically urgent, patients will be encouraged to see a clinician appropriate for their “best care”, however undue pressure is not appropriate
- Consultations will not be interrupted unless there is an emergency, in which case the room will be telephoned as a first step, before knocking at the door and awaiting specific permission from the clinician to enter
- A chaperone will be offered where an examination is to take place. See Chaperone Policy [*]
- Clinical staff will be sensitive to the needs of the individual and will ensure that they are comfortable in complying with any requests with the potential to cause embarrassment
- Patients will be afforded as much time and privacy as is required to recover from the delivery of “bad news”, and the clinical staff will, where possible, anticipate this need and arrange their appointments accordingly
- Clinicians and staff will allow “personal space” where possible and respect this
- Patients with difficulty in understanding due to language may have a family member or friend available to interpret or assist
- Communication by staff to patients will be individual according to the needs of the individual patient (e.g. those with speech difficulties, hearing, or learning difficulties may need an individual approach)
- Where an intimate examination is considered necessary to be performed on a patient with difficulty in understanding due to language or other issues (e.g. consent or cultural issues) it is recommended that a Chaperone or family member / carer should always be present
- Patients who may have difficulty in undressing may be offered the services of a second (same gender) clinician or trained Chaperone to assist
- Patients will be requested only to remove a minimum of clothing necessary for the examination
- Consultations in the patient’s home will be sensitive to the location and any other persons who may be present or may overhear
Post – Consultation
- Clinicians and staff will respect the dignity of patients and will not discuss issues arising from the above procedures unless in a confidential clinical setting appropriate to the care of the patient (respectful of the patient even when not present).
Practice Privacy Policy
Appendix A – Privacy Notice
Dr Sulakshana & Partners
Appendix A – The Practice will share patient information with these organisations where there is a legal basis to do so.
| Activity | Rationale |
| Commissioning and contractual purposes
Invoice Validation Planning Quality and Performance
|
Purpose – Anonymous data is used by the Integrated Care Board (ICB) for planning, performance, and commissioning purposes, as directed in the practices contract, to provide services as a public authority.
Legal Basis – UK GDPR 6 1(b) Contractual obligation as set out in the Health and Social Care Act for Quality and Safety 2015
Patients may opt out of having their personal confidential data used for Planning or research. Please contact your surgery to apply a Type 1 Opt out or logon to https://www.nhs.uk/your–nhs–datamatters/manage–your–choice/ to apply a National Data Opt Out
Processor – BLMK ICB |
| Summary Care Record
Including additional information |
Purpose –The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.
Legal Basis – Direct Care under UK GDPR : • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and • Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that by opting out of having your information shared with the Summary Care Record could result in a delay to care that may be required in an emergency. |
| Processor – NHS England and NHS Digital | |
| Research | Purpose – We may share anonymous patient information with research companies for the purpose of exploring new ways of providing healthcare and treatment for patients with certain conditions. This data will not be used for any other purpose.
Where personal confidential data is shared your consent will need to be required.
Where you have opted out of having your identifiable information shared for this Planning or Research your information will not be shared.
Legal Basis – Where sharing of personal identifiable data is required the legal basis of Article 6 1 (a) and 9 2 (h) Consent will be required.
Where identifiable data is required for research, patient consent will be needed, unless there is a legitimate reason under law to do so or there is support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales
Sharing of aggregated non identifiable data is permitted.
Processor – Available on Request |
| Individual Funding Requests | Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our standard NHS contract.
The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time but this may affect the decision to provide individual funding.
Legal Basis – Under UK GDPR Article 6 1(a) consent is required 6 1 (e) Public Task Article 9 2 (h) health data
Data processor –BLMK ICB |
| Safeguarding Adults | Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of individuals.
Consent may not be required to share information for this purpose.
Legal Basis – in some case consent will be required otherwise |
| • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
• Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
Data Processor – BLMK Safeguarding Adults Team |
|
| Safeguarding Children | Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns and to protect the safety of children.
Legal Basis – • Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and • Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine
Consent may not be required to share this information.
Data Processor – BLMK Children’s Services |
| Risk Stratification – Preventative Care | Purpose – ‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.
Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health.
If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data Legal Basis UK GDPR Art. 6(1) (e) Public task and Art.9 (2) (h) Health data. The use of identifiable data by ICBs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2022 NHS England Risk Stratification which gives us a |
| statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.
Processors – Available upon request |
|
| Public Health
Screening programmes (identifiable) Notifiable disease information (identifiable) Smoking cessation (anonymous) Sexual health (anonymous) Vaccination Programmes
|
Purpose – Personal identifiable and anonymous data is shared. The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service to name a few. The law allows us to share your contact information, and certain aspects of information relating to the screening with Public Health England so that you can be appropriately invited to the relevant screening programme.
More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes [Or insert relevant link] or speak to the practice
Patients may not opt out of having their personal information shared for Public Health reasons.
Patients may opt out of being screened at the time of receiving an invitation.
Legal Basis: Sharing personal data for this purpose is governed by the COPI Reg 2. Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ 6 1 (f) Legitimate interests And Article 9(2)(h) Health data as stated below 9 2 (i) Public health
Data Processors – Public Health BLMK Council |
| Direct Care
NHS Trusts Community Providers Pharmacies Enhanced care providers Nursing Homes Other Care Providers |
Purpose – Personal information is shared with other secondary care trusts and providers in order to provide you with individual direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.
Legal Basis – The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 1 (e) direct care and 9 2 (h) to provide health or social care:
In some cases patients may be required to consent to having their record opened by the third party provider before patients information is accessed. Where there is an overriding need to access the GP record in order to provide patients with life saving care, their consent will not be required.
|
| Processors – BLMK Hospitals Trusts | |
| Care Quality Commission | Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.
More detail on how they ensure compliance with data protection law (including UK GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about–us/our–policies/privacystatement
Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below
Processors – Care Quality Commission |
| Population Health
Management |
Purpose – Health and care services work together as ‘Integrated Care Systems’ (ICS) and are sharing data in order to:
• Understand the health and care needs of the care system’s population, including health inequalities • Provide support to where it will have the most impact • Identify early actions to keep people well, not only focusing on people in direct contact with services, but looking to join up care across different partners. (NB this links to the Risk Stratification activity identified above)
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data. NB only organisations that provide your care will see your identifiable data.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Data Processors – Optum, Cerner |
| Payments, Invoice validation | Purpose – Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amounts paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non-patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs |
| may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.
Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below
Data Processors – NHS England, ICB, Public Health |
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| Patient Record data base | Purpose – Your medical record will be processed in order that a data base can be maintained, this is managed in a secure way and there are robust processes in place to ensure your medical record is kept accurate, and up to date. Your record will follow you as you change surgeries throughout your life.
A warning marker may be applied to your record if necessary for staff protection in accordance with practice policy. This will be reviewed on a regular basis and removed if no longer required.
Closed records will be archived by NHS England
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – TPP System One, and PCSE
|
| Medical reports
Subject Access Requests
|
Purpose – Your medical record may be shared in order that:
Solicitors/persons acting on your behalf can conduct certain actions as instructed by you.
Insurance companies seeking a medical reports where you have applied for services offered by then can have a copy to your medical history for a specific purpose.
Legal Basis – under GDPR Article 6 1 (a) and 9 2 (a) explicit consentwill be required before a GP can share your record for either for these purposes.
Processor – Solicitors, Insurance organisations |
| Medicines Management
Team Medicines Optimisation |
Purpose – your medical record is shared with the medicines management team pharmacists, in order that your medication can be kept up to date and any necessary changes to medication can be implemented.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor – BLMK ICB Medicines Optimisation |
| GP Federation
|
Purpose – Your medical record will be shared with BLMK ICS/ICB/Federation in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics. The Federation will be acting on behalf of the GP practice.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor – BLMK ICS/ICB/Federation |
| Primary Care Network (PCN) | Purpose – Your medical record will be shared within Hillton PCN in order that they can provide direct care services to the patient population.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor – Hillton PCN |
| Smoking cessation | Purpose – personal information is shared for the smoking cessation service to be provided.
Only those patients who wish to be party to this service will have their data shared
Legal Basis – Article 6 1 (a) and 9 2 (h) consent
Processor – Choose You |
| Social Prescribers | Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their health social care needs.
Only those patients who wish to be party to this service will have their data shared
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor – Hillton PCN |
| Police | Purpose – Personal confidential information may be shared with the Police authority for certain purposes. The level of sharing and purpose for sharing may vary. Where there is a legal basis for this information to be shared consent will not always be required.
The Police will require the correct documentation in order to make a request. This could be but not limited to, DS 2, Court order, s137, the prevention and detection of a crime. Or where the information is necessary to protect a person or community.
|
| Legal Basis – UK GDPR –6 1 (c) Legal Obligation. Article 6 1 (f) legitimate interest
Article 9 2 (f) requests for legal reasons
Processor – Police Constabulary |
|
| Coroner
Medical Examiner |
Purpose – Personal health records or information relating to a deceased patient may be shared with the coroneror medical examinerupon request.
Legal Basis – UK GDPR Article 6 1 (c) Legal Obligation 9 2 (h) Health data
Processor – The Coroner, Medical Examiner |
| Private healthcare providers | Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patient’s request. Consent from the patient will be required to share data with Private Providers.
Legal Basis – Article 6 1 (a) and 9 2 (h) Consented and under contract between the patient and the provider
Provider – LIVI |
| Messaging Service
|
Purpose – Personal identifiable information shared with the messaging service in order that messages including; appointment reminders; results; campaign messages related to specific patients health needs; and direct messages to patients, can be transferred to the patient in a safe way.
Legal Basis – UK GDPR Article 6 1 (b) Contract, Article 6 1 (e) Public task, Article 9 2 (h) Health data
Provider – Accurx, TPP SystmOne |
| Utilising self-booking links for patients to book appointments | Purpose –
Processing of data to send appointment booking links to patients – via the direct booking links or the Practice website.
Legal Basis of Processing – Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’ Article 9(2)(h) ‘… the provision of health or social care or treatment of management of health or social care systems…’
Provider – Accurx – Accubook
For further information of Hero Health Privacy Policy please see this link: Accurx | Privacy policy
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| Remote consultation
Including – Video Consultation Clinical photography |
Purpose – Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice.
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| Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Patients may be videod or asked to provide photographs with consent. There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children.
Processor – AccuRX, |
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| MDT meetings | Purpose – For some long-term conditions, the practice participates in meetings with staff from other agencies involved in providing care, to help plan the best way to provide care to patients with these conditions. Personal data will be shared with other agencies in order that mutual care packages can be decided.
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor – Microsoft Teams |
| COVID-19
Research and Planning |
Purpose – To understand the risks to public health, trends and prevent the spread of infections such as Covid-19 the government has enabled a number of initiatives which include research and planning during the Covid-19 pandemic which may include the collection of personal confidential data has been necessary. This is to assist with the diagnosis, testing, self-isolating, fitness to work, treatment medical, social interventions and recovery from Covid-19. COPI Reg 3 has been extended and you can find further information here:
Coronavirus (COVID–19): notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 – GOV.UK (www.gov.uk)
NHS England » OpenSAFELY – the Coronavirus (COVID–19) Research Platform
Legal Basis – In order to share personal confidential data with other agencies for research or planning. Either the Article 6 1 (a) and 9 2 (a) Explicit consent will be required. or The Processor would need to meet Section 251 CAG approval. Or It would need to be approved under direct care to patients Article 6 1 (e) Public Task and 9 2 (h) Health data
Provider – COVID vaccination Hubs, BIOBANK, Oxford University, |
| General Practice
Extraction Service (GPES) |
Purpose – GP practices are required to provide data extraction of their patients personal confidential information for various purposes to NHS Digital. The objective of this data collection is on an ongoing |
| 1. At risk patients data collection Version 3
2. Covid-19 Planning and Research data 3. CVDPREVENT Audit 4. Physical Health Checks for people with Severe Mental Illness |
basis to identify patients registered at General Practices who fit within a certain criteria, in order to monitor and either provide direct care, or prevent serious harm to those patients. Below is a list of the purposes for the data extraction, by using the link you can find out the detail behind each data extraction and how your information will be used to inform this essential work:
1. At risk patients including severely clinically vulnerable
2. Covid-19 Planning and Research data, to control and prevent the risk of Covid-19
3. NHS England has directed NHS Digital to collect and analyse data in connection with Cardiovascular Disease Prevention Audit
4. GPES Physical Health Checks for people with Severe Mental Illness (PHSMI) data collection.
Legal Basis – All GP Practices in England are legally required to share data with NHS Digital for this purpose under section 259(1)(a) and (5) of the 2012 Act
Further detailed legal basis can be found in each link.
Any objections to this data collection should be made directly to NHS Digital. enquiries@nhsdigital.nhs.uk
Processor – NHS Digital or NHS X |
| Medication/Prescribing | Purpose: Prescriptions containing personal identifiable and health data will be shared with organisations who provide medicines management including chemists/pharmacies, in order to provide patients with essential medication regime management, medicines and or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Pharmacists may be employed to review medication, Patients may be referred to pharmacists to assist with diagnosis and care for minor treatment, patients may have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver care and medication
Legal Basis : Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor – Pharmacy of choice |
| Professional Training | Purpose – We are a training surgery. Our clinical team are required to be exposed to on the job, clinical experience, as well as continual professional development. On occasion you may be asked if you are |
| happy to be seen by one of our GP registrars, pharmacists or other clinical team to assist with their training as a clinical professional. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE.
Legal Basis – 6 1 (a) consent, patients will be asked if they wish to take part in training sessions. 9 2 (a) – explicit consent will be required when making recordings of consultations
Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.
Processor – RCGP, HEE, iConnect, Fourteen Fish |
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| Telephony | Purpose – The practice use an internet based telephony system that records telephone calls, for their own purpose and to assist with patient consultations. The telephone system has been commissioned to assist with the high volume and management of calls into the surgery, which in turn will enable a better service to patients.
Legal Basis – While there is a robust contract in place with the processor, the surgery has undertaken this service to assist with the direct care of patients in a more efficient way. Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Provider – X-on Surgery Connect, Xon Surgery Assist |
| Learning Disability
Mortality Programme LeDer |
Purpose : The Learning Disability Mortality Review (LeDeR) programme was commissioned by NHS England to investigate the death of patients with learning difficulties and Autism to assist with processes to improve the standard and quality of care for people living with a learning disability and Autism. Records of deceased patients who meet with this criteria will be shared with NHS England.
Legal Basis: It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information who fit within a certain criteria.
Processor : ICB, NHS England |
| Technical Solution Pseudonymisation | Purpose: Personal confidential and special category data in the form of medical record, is extracted under contract for the purpose of pseudonymisation. This will allow no patient to be identified within the data set that is created. SCWCSU has been commissioned to provide a data processing service for the GPs, no other processing will be undertaken under this contract.
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| Legal Basis: Under UK GDPR the legitimate purpose for this activity is under contract to provide assistance.
Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor: SCW CSU or NHS M & L CSU, NHS Arden and GEM CSU |
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| Shared Care Record | Purpose: In order for the practice to have access to a shared record, the Integrated Care Service has commissioned a number of systems including GP connect, which is managed by NHS Digital, to enable a shared care record, which will assist in patient information to be used for a number of care related services. These may include Population Health Management, Direct Care, and analytics to assist with planning services for the use of the local health population.
Where data is used for secondary uses no personal identifiable data will be used.
Where personal confidential data is used for Research explicit consent will be required.
Legal Basis: Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor: NHS Digital |
| Local shared care record BOB ICB | Purpose: Health and Social care services are developing shared systems to share data efficiently and quickly. It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out of hours appointment. It is also quicker for staff to access a shared record than to try to contact other staff by phone or email.
Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job. Systems do not share all your data, just data which services have agreed is necessary to include.
Legal Basis: Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor: BLMK ICB |
| Anticoagulation Monitoring | Purpose: Personal Confidential data is shared with LumiraDX in order to provide an anticoagulation clinic to patients who are on anticoagulation medication. This will only affect patients who are within this criteria.
Legal Basis: The legal basis for this activity under UK GDPR is |
| Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) Health data as stated below
Processor : INRStar |
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| Weight and Wellbeing
programme
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Purpose – personal information is shared in order for the Weight and Wellbeing lifestyle intervention programme to be provided.
Only those patients who wish to be party to this service will have their data shared. Legal Basis – Article 6 1 (a) and 9 2 (h) consent Processor – Xpert Health Training & Education Ltd, CX Services Ltd |
| Accurx Patient Triage – Online
Consultation Platform |
Purpose: Online consultation allows the patients to contact the Practice without having to wait on the phone or take time to come into the practice in person especially if a patient is not sure whether they need a face-to-face consultation. Online consultations enable patients to use a secure online system to ask questions, report symptoms and the practice can then respond by signposting patients to the right person e.g. a doctor or to appropriate service or support.
Legal Basis: Article 6 1 (b) Contract where the data subject is party Article 6 (1) (e) of the GDPR, which permits us to process your personal information that is necessary to provide a service which is in the public interest Article 9(2) (h) of the GDPR which permits us to process your health information which is necessary for the provision of health treatment.
Processor: Accurx Limited
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| Heidi A.I. – Transcribing conversations to the electronic health record EHR. | Heidi A.I.
As part of the Digital First National programme of work, GP Practices are required to record accurate data about patient interaction, especially within consultations. To assist with this administrative task, the practice is using a new technology known as Heidi AI. The primary purposes include improving clinical documentation, aiding healthcare professionals in notetaking, and generating consult summaries. Heidi technology enables clinicians to focus on patients during the consultation, contributing to improved patient care. It also acts as a valuable tool for medical practitioners, saving them hours of administrative time per week. Heidi works by transcribing speech into text from a healthcare encounter such as conversations between clinicians and patients or by clinicians dictating their clinical findings, impression and/or management plans before, during and after the healthcare encounter. The clinician can also add additional contextual notes about the healthcare encounter. This system is designed to alleviate the administrative burden on healthcare professionals, allowing them to focus more on patient care rather than paperwork. The Heidi Scribe will leverage natural language processing (NLP), speech recognition technology, and machine learning algorithms to understand and interpret complex medical dialogue, identify key health information, and categorise data into the appropriate sections of an Electronic Health Record (EHR). Your consent will be sought for consultations that are transcribed using the Heidi AI tool. Heidi also uses aggregated de-identified information from these consults to improve its models and outputs, ultimately improving both patient care and clinician experience. All Data that identifies you stays within the practice and its servers which are UK based, no identifiable data is used by the Heidi tool for machine learning. Heidi AI will not make decisions about your care, it only transcribes verbal interactions with the practice, with your consent. More information about the model can be found on the Heidi website here: – https://www.heidihealth.com/uk Privacy Policy UK | Heidi Health
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We keep our Privacy Notice under regular review. This notice was last reviewed on 02 July 2025.
Lawful basis for processing:
The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the UK GDPR:
- Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
- Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”
Objections/Complaints
Should you have any concerns about how your information is managed at the GP, please contact the GP Practice Manager or the Data Protection Officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority:
You have a right to complain to the UK supervisory Authority as below:
- Information Commissioner:
Wycliffe house,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF - Tel: 01625 545745
- https://ico.org.uk/
If you are happy for your data to be used for the purposes described in this privacy notice, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact Greensand Surgery Data Protection Officer.
If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.
Data Protection Officer
The Data Protection Officer for the for the GPs for the Bedfordshire Luton and Milton Keynes GP Practices signed to Arden and GEMCSU is:
Judith Jordan, Arden & GEM Head of Integrated Governance, but we have a team who carry out the function, the contact details are:
- Email:agem.dpo@nhs.net
- Telephone: 0121 611 0730
Changes:
It is important to point out that we may amend this Privacy Notice from time to time. If you are dissatisfied with any aspect of our Privacy Notice, please contact the Dr Sulakshana & Partners Data Protection Officer.
Privacy Notice – Use of Heidi AI Scribe in Patient Consultations
Dr Sulakashana and Partners have currently paused the use of Heidi A.I. and will let patients know should they resume it’s usage.
Dr Sulakashana and Partners are committed to delivering the best possible care to our patients. To enhance the quality and efficiency of our consultations, clinicians (your GP or a member of the multidisciplinary team within practice) may use Heidi Health AI Scribe during your appointment. This section provides information about what Heidi Health AI Scribe is and how your consent is managed.
What is Heidi Health AI Scribe?
Heidi Health AI Scribe is an advanced, secure digital assistant designed to support clinicians during consultations. It uses artificial intelligence to document medical notes, ensuring your clinician can focus on actively listening to your concerns and delivering personalised care, rather than spending time manually recording the notes. Clinicians review and approve the notes that have been captured prior to adding to the patient record.
- Improved Interaction: Allows clinicians to focus solely on the patient during the consultation.
- Accurate Documentation: Helps create precise, clear, and detailed medical notes for the patient record.
- Time Efficiency: Streamlines administrative tasks, giving clinicians more time to spend with their patients.
Patient Consent
Your privacy and comfort are our top priorities. Heidi Health AI Scribe only processes information discussed during your appointment and operates within strict privacy and data protection regulations. Before using Heidi Health AI Scribe, your clinician will explain its role and seek your verbal consent. You have the right to decline its use at any time.
- Data Security: Heidi Health AI Scribe complies with UK data protection laws, including GDPR, ensuring that your information is handled securely and confidentially.
- Data Protection Officer: The Heidi Health Data Protection Impact Assessment has been reviewed and approved by the Data Protection Officer for Hillton Primary Care Network, on behalf of your GP Practice.
- Your Control: If you prefer not to have Heidi Health AI Scribe involved, please do let your clinician know. This will not affect the quality of care you receive.
Policy written on 3rd March 2025
– Dr Avanti Sulakshana
Zero Tolerance
NHS Staff must be able to come to work without fear of violence, abuse or harassment from patients or their relatives. The NHS has a zero tolerance attitude towards violence.
Violent, threatening or abusive behaviour including shouting and swearing will not be tolerated at this practice.
Patients who act in such a manner will be asked to leave the premises; the Police may be called and you could be removed from our patient list.
Our staff are here to help you, please treat them with respect.