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Privacy

Privacy notice

As data controllers, GPs have fair processing responsibilities under the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). This means ensuring that your personal confidential data (PCD) is handled in ways that are safe, transparent and what you would reasonably expect. Please find documents and links below.

Your information, what you need to know

This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form

Our commitment to data privacy and confidentiality issues

As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation.

This includes the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.

Data we collect about you

Records which this GP practice will hold or share about you will include the following:

  • Personal Data – This means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Special Categories of Personal Data – This term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
  • Confidential Patient Information – This term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.
  • Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
  • Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place
  • Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care.

For example it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in Appendix A.

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service.

Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

  • Improving the quality and standards of care provided
  • Research into the development of new treatments
  • Preventing illness and diseases
  • Monitoring safety
  • Planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.

How long do we hold information for?

All records held by the practice will be kept for the duration specified by national guidance from NHS England.

Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is.

Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for Health and Social Care 2016.

Your right to opt out of data sharing and processing

The NHS Constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’. For further information please visit The NHS Constitution.

Type 1 Opt Out

This is an objection that prevents an individual’s personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you wish to apply a Type 1 Opt Out to their record they should make their wishes know to the practice manager.

National Data Opt-Out

The national data opt-out was introduced to enable patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.

By 2020 all health and care organisations are required to apply national data opt-outs where confidential patient information is used for research and planning purposes. NHS Digital has been applying national data opt-outs since 25 May 2018. Public Health England has been applying national data opt-outs since September 2018.

The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to the National Data Opt Out Programme.

To find out more or to register your choice to opt out, please visit the NHS Your Data Matters website.

On this web page you will:

  • See what is meant by confidential patient information
  • Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
  • Find out more about the benefits of sharing data
  • Understand more about who uses the data
  • Find out how your data is protected
  • Be able to access the system to view, set or change your opt-out setting
  • Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
  • See the situations where the opt-out will not apply

Right of access to your information (Subject Access Request)

Under Data Protection Legislation everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access and you may find information has been redacted or removed for the following reasons;

  • Does not cause harm to the patient
  • That legal confidentiality obligations for the non-disclosure of third-party information are adhered to

You do not need to give a reason to see your data. And requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require.

Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the extra copies.

You will need to provide proof of identity to receive this information.

If you would like to access your GP record online please visit our website.

Change of details

It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.

Mobile telephone number

If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile.

Email address

Where you have provided us with your email address, with your consent we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email please let us know.

Notification

Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a Data Controller and our registration can be viewed online in the public register via the ICO website.

Any changes to this notice will be published on our website and in a prominent area at the practice.

Data Protection Officer

Should you have any data protection questions or concerns, please contact our Data Protection Officer via the Contact the Practice form.

What is the right to know?

The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector.

You can request any non-personal information that the GP practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However you can request this under a right of access request – see section above ‘Access to your information’.

Right to Complaint

If you have concerns or are unhappy about any of our services, please contact the Practice Manager.

For independent advice about data protection, privacy and data-sharing issues, you can contact:

The Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone: 0303 123 1113
Website: www.ico.org.uk/global/contact-us

The NHS Care Record Guarantee

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under Data Protection Legislation.

The NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong.

https://www.gov.uk/government/publications/the-nhs-constitution-for-england

Appendix A – The practice will share your information with these organisations where there is a legal basis to do so.

ICB ‘Integrated Care Board’

ICB Purpose

Anonymous data is used by the ICB for planning and performance as directed in the practices contract.

Legal Basis

Contractual

Processor

NHS Surrey Heartlands ICB

  • Name: Dan Clement
  • Role: Associate Director ICS Information Governance / Data Protection Officer (NHS Kent & Medway Integrated Care Board)
  • Email address: [email protected]
  • Telephone: 01634 335095
  • Postal Adress: NHS Kent and Medway, 2nd floor, Gail House, Lower Stone Street, Maidstone, ME15 6NB

Summary Care Record

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 – Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, phone. If you wish to opt-out of having an SCR please return a completed opt-out form to the practice.

Processor

NHS England and NHS Digital

Research

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 -Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, phone. If you wish to opt-out of having an SCR please return a completed opt-out form to the practice.

Processor

NHS England and NHS Digital

OpenSAFELY

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 type 1 opt out with their GP.
Find additional information about OpenSAFELY.

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 contracts.

Legal basis

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

Data Processor

Consultant at an NHS Trust

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.

Legal basis

Because of public Interest issues, e.g. to protect the safety and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.

Data Processor

Dr Tara Jones and Dr Sharon Kefford, Surrey Heartlands ICB

Adults Safeguarding Generic email for SE Hampshire and F&G CCG: [email protected]

Safeguarding Children

Purpose

We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns.

Legal basis

Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.

Data Processor

As above.

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

GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs 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 2020 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

Surrey Heartlands ICB

Public Health Screening programmes (identifiable), Notifiable disease information (identifiable), Smoking cessation (anonymous), Sexual health (anonymous)

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. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.

More information can be found on the Gov.uk website.

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

Public Health England South East Civic Centre, Level 2,Tannery Lane, Ashford, TN23 1PL
Telephone: 0344 225 3861

NHS Trusts

Purpose

Personal information is shared with other secondary care trusts in order to provide you with 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 and 9 conditions as stated below:

Processors

Epsom and St Helier University Hospitals Trust, East Surrey Hospital, Royal Surrey County Hospital, Ashford & St Peters Hospital, Frimley Park Hospital, other private hospitals within the UK.

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 GDPR) and their privacy statement is available on our website: www.cqc.org.uk/about-us/our-policies/privacy-statement

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

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 amount 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

Patient Record Data Base

Purpose

Your medical record will be shared, in order that a data base can be maintained and managed in a secure way.

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

EMIS

Abtrace

Why are we telling you this?

 Ashlea Medical Practice uses a system called Abtrace to help us provide safer and more proactive care to our patients.

What is Abtrace?

 Abtrace is a secure clinical decision support system that works alongside your medical record. It helps us:

  • Identify when you may need a review, blood test or follow-up care
  • Remind you about routine monitoring (e.g. diabetes checks, medication reviews)
  • Support our doctors and nurses in delivering guideline-based care

What information is used?

 To do this, Abtrace uses information already in your record, including:

  • Your name, date of birth, NHS number and contact details (if messaging is used)
  • Medical conditions and diagnoses
  • Medications and repeat prescriptions
  • Blood test results and vital signs (e.g. blood pressure)
  • Dates of past or upcoming reviews

This information is only used for your direct care.

How is your data kept safe?

 Your data stays within the UK, stored securely in NHS-approved cloud servers

  • Data is encrypted in transit and at rest
  • Only authorised staff at Woodchurch surgery can access your record
  • Abtrace does not sell or share your data
  • Abtrace is NHS Data Security and Protection Toolkit compliant, ISO 27001 certified, and Cyber Essentials Plus certified

Will I get messages from Abtrace?

 Yes, you may receive an SMS or NHS App message to help you manage your health – for example reminding you about routine monitoring.

If you do not wish to receive these messages, please contact reception to update your communication preferences.

What are my rights?

 You have rights under data protection law, including:

  • To be informed about how your data is used (this notice)
  • To access your information
  • To request corrections if something is wrong
  • To object to your data being used (in certain circumstances)
  • To request restrictions on how your data is processed

To exercise any of these rights, please speak to reception or contact us by email.

 Questions or concerns?

 If you have any questions about how your data is used with Abtrace, contact:

Data Protection Officers:

Dr Mark Jones

Phone: 01372 375666

Accurx

As part of the Digital First National programme of work, GP Practices are required to provide a tool for patients to access primary care services.

The aim of the Accurx platform is to improve communications between healthcare staff and patients, resulting in improved outcomes and productivity. The platform facilitates digital communications between the practice and our patients.
Using the Accurx platform will require the processing of special category data by Accurx, their sub-processors and by default the GP Practice as a Controller. This will include; exchanging and storing messages in relation to patients and medical staff, performing video consultations (these will not be recorded or stored) between healthcare staff and their patients This will allow you to respond to the Practice in multiple ways such as; free text, questionnaires and submitting images/documents.

If you have a non-urgent healthcare concern or need to contact the Practice for any medical or admin reason, click on the online link via our website or via NHS app or via NHS website. Fill out the online form, which will then be reviewed and processed by our healthcare professionals to decide the right care for you. We will respond to online medical requests once triaged on the day, and 3 working days for admin queries.

Accurx is approved by NHS England to be used by GP practices and the other systems involved in patient care. NHS England has a lengthy assurance process to make sure they meet the highest standards of safety and security. Your data is safe and is shared only with your GP Practice for the purposes of your direct care. Your data is stored and sent securely using industry best practices, and Accurx only collect the data that is necessary to allow your GP Practice to provide you with care.

The Practice uses the following Accurx features:

Online consultations

Video consultations

Accurx Navigator

AccuMail

SMS

Friends and Family test

Record Views

The Accurx privacy notice can be found on their website here: Accurx | Privacy Policy.

1) Controller

 

 

Ashlea Medical Practice

Gilbert House, 39 Woodfield Lane

Ashtead, KT21 2BQ

2) Data Protection Officer contact detailsDr Mark Jones

01372 375666

 
4) Lawful basis for processingUnder UK GDPR and DPA 2018 –

6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.

9(2)(h) ‘…medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems…’

5) Recipient or categories of recipients of the shared dataData may be shared with Accurx, and their sub-processors such as cloud services used for Accurx’ own storage, communications, security, engineering, and similar purposes.
6) Rights to objectYou have the right under Article 21 of the UK GDPR to object to your personal information being processed. Please contact the Practice if you wish to object to the processing of your data. You should be aware that this is a right to raise an objection which is not the same as having an absolute right to have your wishes granted in every circumstance.
7) Right to access and correctYou have the right to access copies of the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.
8) Retention periodThe data will be retained for active use during the processing and thereafter according to NHS Policies and the law.
9)  Right to Complain.You have the right to complain to us about the way your data is handled or processed. To so, please contact the Practice using the following details:

 

Ashlea Medical Practice

Gilbert House, 39 Woodfield Lane

Ashtead, KT21 2BQ

 

If you remain unsatisfied with our response, you have a right to complain to the Information Commissioner’s Office. To do so, you can use this link https://ico.org.uk/make-a-complaint/data-protection-complaints/ or call their helpline

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website).

Accurx Scribe

Use of Accurx Scribe in NHS GP Consultations

This privacy notice explains how our GP practice uses patient data when incorporating Accurx Scribe, an AI-powered medical scribe, into consultations. Accurx Scribe assists clinicians by transcribing medical consultations to improve documentation and reduce administrative workload while maintaining patient care quality and confidentiality.

Purpose of Processing The use of Accurx Scribe aims to

  • Enhance accuracy and efficiency in medical record-keeping.
  • Reduce administrative workload for clinicians.
  • Improve patient-clinician interaction by allowing clinicians to focus on care rather than note-taking.

How Data is Collected and Processed

  • During a consultation, Accurx Scribe transcribes real-time discussions between patients and clinicians.
  • The transcribed information is reviewed and validated by the clinician before being added to the patient’s medical record.
  • Data is processed within a secure environment, ensuring compliance with NHS Digital and UK GDPR requirements.

Data Sharing and Security Measures

  • Accurx Scribe does not share patient data with third parties without explicit consent, except where legally required (e.g., safeguarding, legal obligations).
  • Data is encrypted and stored securely in the UK, in compliance with NHS data governance policies.
  • Access to patient data is restricted to authorised healthcare professionals within the practice.

Patient Rights Under data protection laws, patients have the following rights

  • Right to Access: You can request a copy of your consultation records by contacting the practice.
  • Right to Rectification: If you believe your records contain inaccuracies, you can request corrections.
  • Right to Object: You can object to the use of Accurx Scribe in your consultation by informing your clinician.
  • Right to Restrict Processing: In certain circumstances, you may request limitations on how your data is processed.

Legal Basis

Legal Basis for Processing The legal bases for processing personal data under UK GDPR and the Data Protection Act 2018 include:

  • Article 6(1)(e) – Performance of a task carried out in the public interest or in the exercise of official authority.
  • Article 9(2)(h) – Processing necessary for the provision of health or social care.

Recipient Or Categories of Recipients of The Shared Data

Categories of Data Processed The following types of personal data may be processed when using Accurx Scribe:

  • Patient identifiers (name, date of birth, NHS number)
  • Consultation transcripts (including symptoms, diagnoses, and treatment plans)
  • Voice recordings (if applicable)

Retention Period Retention Period

  • Transcribed consultation records are stored as part of the patient’s electronic medical record and retained in accordance with NHS retention guidelines.
  • Any temporary data processed by Accurx Scribe is securely deleted once incorporated into the medical record. This is set to be deleted within 90 days by Ashlea Medical Practice. No data is held by Accurx Scribe.

Opt-Out Option

If you prefer not to have your consultation transcribed by Accurx Scribe, you can opt out at any time by informing your clinician before or during your appointment.

Data Controller Contact Details

Ashlea Medical Practice. 30 Upper Fairfield Road, Leatherhead KT227HH

Data Protection Officer

Should you have any data protection questions or concerns, please contact our Data Protection Officer, Dr Mark Jones, Ashlea Medical Practice. 30 Upper Fairfield Road, Leatherhead KT22 7HH. 013723 75666

Ardens / Ardens Manager

As part of our commitment to improving patient care and population health management, this GP practice uses Ardens / Ardens Manager, a secure clinical analytics platform.

Ardens Manager allows us to securely analyse pseudonymised patient data from our clinical system (EMIS) to:

  • Identify areas for improving quality of care and outcomes
  • Monitor performance against national and local indicators (e.g Quality and Outcomes Framework (QOF))
  • Support proactive care for at-risk patients
  • Fulfil our contractual and clinical governance responsibilities

What data is shared?

  • The data processed by Ardens Manager is pseudonymised. This means personal identifiers like your name or NHS number are removed and replaced with codes. The data no longer identifies you, but it can be re-identified by authorised staff within the practice if needed to support your care.
  • Pseudonymised data may be shared securely with other NHS organisations only for direct care, planning, quality improvement, and assurance purposes, and never for marketing or  commercial use.

Who can access the data?

  • Access is limited to authorised staff within the practice and approved roles within our Primary Care Network (PCN) and Integrated Care Board (ICB) who are involved in planning and managing services.
  • We remain the data controller. Ardens (the data processor) acts on our behalf under a strict Data Processing Agreement and complies with UK GDPR and NHS Digital standards.

Legal basis for processing

We process this data under UK General Data Protection Regulation (GDPR) Article 6(1)(e), the performance of task carried out in public interest. For health data, the condition is Article 9(2)(h), the provision of health and social care.

Your rights

Under the UK GDPR, you have the right to object to your data being processed in this way, that is, used in a pseudonymised form for service planning, performance monitoring, and care improvement via Ardens Manager platform.

If you wish to object, please contact the Practice Manager. We will carefully consider your request and assess whether we can reasonably stop processing your data without affecting our ability to deliver safe, effective care or meet our legal obligations.

Please note that:

  • The data used by Ardens Manager is pseudonymised and does not directly identify you.
  • The processing supports important functions such as identifying gaps in care, reviewing service quality and managing local health needs.
  • In some cases, we may need to continue using your data where we have a compelling legal or clinical grounds to do so in the public interest.

This is different from the NHS National Data Opt-Out which allows you to stop your identifiable information being used for research and planning outside of your direct care. To manage your national preferences, visit www.nhs.uk/your-nhs-data-matters

 Find out more

  • For more information on how Ardens Manager processes data, visit: https://www.ardens.org.uk/privacy

 

iGPR

Purpose

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.

Legal basis

Your consent will be required to share your record for this purpose

Processor

iGPR

Surgery Connect Telephony System – X-on

Purpose

To enable a safe two way communication between the patient and the Practice.

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 and 9 conditions of the 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…’
Article 9(2)(b) ‘Carrying out of obligations under employment, social security or social protection law, or a collective agreement’
Article 9(2)(c) ‘Vital interests of a data subject who is physically or legally incapable of giving consent.’
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…”

Processor

Surgery Connect

Medicines Management Team

Purpose

Your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes 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) as stated below

Processor

Lead Medicines Optimisation Pharmacist- Guildford & Waverley ICP – NHS Surrey Heartlands ICB

GP Federation, GP Extended Access

Purpose

Your medical record will be shared with the Dorking Healthcare (DHC) and GP Health Partners (GPHP) 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

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

Leatherhead PCN

PCN

Purpose

Your medical record will be shared with Leatherhead 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) as stated below

Processor

Ashlea Medical Practice

Smoking Cessation

Purpose

Personal information is shared in order for the smoking cessation service to be provided.

Legal basis

Consented

Processor

OneYouSurrey

Social Prescribers

Social Prescribing Link Worker

Mental Health Provider

CAMHS

Medical Reports

Insurance Providers

Police

Surrey and Sussex Police

Private Providers

Private hospitals across the UK

Technical Solutions for Analytics

SCWCSU

Reviews of and Changes to our Privacy Notice

We will keep our privacy notice under regular review. This notice was last reviewed in January 2026.

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 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…”

Rights to Object

You have the right to object to some or all the information being processed under Article 21. Please contact the Data Controller or the practice. You should be aware that this is a right to raise an objection, that is not the same as having an absolute right to have your wishes granted in every circumstance.

Date published: 20th September, 2023
Date last updated: 12th May, 2026