Data Processors

In this category, these are the organisations we share information about you with:

Data Processors

System/database

Recipients or categories of recipients of the personal or special categories of personal data

Purpose of the processing and data retention periods

 

Lawful basis
General Data Protection Regulation
- Article 6, Article 9 - 
Data Protection Act
- Section 8, Section 10, Part 1 of Schedule 1-

Your Rights

EMIS Health and Egton

 

EMIS Health and Egton are responsible for the provision of a clinical system, software and IT services used by the Practice to securely store and process your medical record.

All information about your personal health records are stored in your GP electronic record. This information is then available to practice staff & external bodies as outlined in this document.

Data Retention Periods:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

GDPR Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services;

DPA Section 10 (1) (c) – processing is necessary for health and social care purposes;

In accordance with DPA  Schedule 1, Part 1 , (1a) - the the processing for employment, social security and social protection is met where it is for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection;

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: In line with the GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

CPMS

 Responsible for the provision of IT clinical systems that enables safe, difitised patient care across the healthcare facilities.

The supplier of CPMS - an Electronic Health Record (EHR) that links system and brings together patient data across the health and care system irrespective of traditional organisational or technological boundaries. This means health and care professionals in Kent and Medway can access subsets of their patients/service users’ medical or social records from a single system in order to provide the best possible care.

The source of the information shared in this way is your electronic GP record for the purposes of direct patient care and population health management.

Data Retention Periods:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

GDPR Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services;

DPA Section 10 (1) (c) – processing is necessary for health and social care purposes;

In accordance with DPA  Schedule 1, Part 1 , (1a) - the the processing for employment, social security and social protection is met where it is for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection;

 

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being in EMIS Web.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

Docman and Docmail

Docman Limited act as a data processor and provides cloud-based storage software for electronic patient document. This includes letters that we receive, scan and upload to the patient record, as well as letters that we receive in an electronic format.

Generally, Docman enables primary health care organisations capture, file, workflow, view and manage primary care documents efficiently.

Docmail enables primary health care organisations send letters, invoices and documents directly from computers and other portable devices.

The source of the information shared in this way is your electronic GP record for the purposes of direct administrative patient care.

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

GDPR Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services;

DPA Section 10 (1) (c) – processing is necessary for health and social care purposes;

In accordance with DPA  Schedule 1, Part 1 , (1a) - the the processing for employment, social security and social protection is met where it is for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection;

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: In line with the GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation to which we are subject.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

 

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

iPlato

iPlato is cloud-based text messaging service used by GPs to communicate with their patients.

The source of the information shared in this way is your electronic GP record for the purposes of direct administrative patient care.

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

Electronic patient records must not be destroyed or deleted for the foreseeable future.”

 

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

GDPR Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services;

DPA Section 10 (1) (c) – processing is necessary for health and social care purposes;

In accordance with DPA  Schedule 1, Part 1 , (1a) - the the processing for employment, social security and social protection is met where it is for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection;

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: In line with the GDPR Article 21, you have a general right to raise an objection to the processing of your personal data in some particular circumstances. This right only applies where we cannot demonstrate compelling legitimate grounds for continued processing of your personal data for the purposes of direct provision of care, and compliance with a legal obligation  to which we are subject. 

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

Quality Medical Solutions UK (QMS-UK):

QMS-UK are commissioned by NHS England to provide secure data processing solutions for two services:

Child Health Information Service – information relating to children’s vaccinations is shared with CHIS who run one of 4 Child Health Information Services across Kent and Medway

National Diabetic Retinal Screening Service – Diabetic eye screening is carried out in Kent and Medway  by Health Intelligence

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

“GP records should be retained until 10 years after the patient's death or after the patient has permanently left the country, unless they remain in the European Union.

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

GDPR Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services;

DPA Section 10 (1) (c) – processing is necessary for health and social care purposes;

In accordance with DPA  Schedule 1, Part 1 , (1a) - the the processing for employment, social security and social protection is met where it is for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection;

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared in QMS.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

Ardens

 

Otford Medical Practice performs computerised searches of some or all of our records to identify individuals who may be at increased risk of certain conditions or diagnoses i.e. Diabetes, heart disease, risk of falling). Your records may be amongst those searched. This is often called “risk stratification” or “case finding”. These searches are sometimes carried out by Data Processors who link our records to other records that they access, such as hospital attendance records. The results of these searches and assessment may then be shared with other healthcare workers, such as specialist, therapists, technicians etc. The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.

Risk stratification can be grouped into two purposes namely:

Direct Care‘Case Finding’ where carried out by a health professional (e.g. GPs and Provider) involved in an individual’s care or by a data processor acting under contract with such a provider, it is treated as direct care.

Indirect Care - understand the local population needs and plan for future requirement.

The source of the information shared in this way is your electronic GP record.

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

GDPR Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services;

DPA Section 10 (1) (c) – processing is necessary for health and social care purposes;

In accordance with DPA  Schedule 1, Part 1 , (1a) - the the processing for employment, social security and social protection is met where it is for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection;

Related Legislation:

Section 251 NHS Act 2006

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

National Institute for Health Research

 

RCGP Research and Surveillance Centre

To enable healthcare professionals working for the Otford Medical Practice to provide information, derived from GP records, about individuals to accredited research organisations.

This covers research situations where the data controller (Otford Medical Practice) is approached by research organisations, directly, to recruit patients for studies.

Any research proposal will only be agreed with a clearly defined protocol, consent mechanisms, and relevant research ethics committee approval, and in line with the principles of
Article 89(1) of the EU GDPR.

Research organisations do not approach patients directly, rather
Otford Medical Practice will invite appropriate patients directly seeking their wish to take part.

This
Privacy Notice does not cover situations where Otford Medical Practice has been approached by an organisation seeking personal data concerning health to be disclosed in the absence of consent, i.e. via Related Legislation: Section 251 NHS Act 2006 / Health Research Authority (HRA) approval.

The source of the information shared in this way is your electronic GP record.

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

 

 

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

GDPR Article 9 (2) (h) - processing is necessary for medical or social care treatment or, the management of health or social care systems and services;

DPA Section 10 (1) (c) – processing is necessary for health and social care purposes;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

Article 9 (2) (i) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law

In accordance with DPA Schedule 1, Part 1, (4) - The condition for the processing is met where it is necessary for archiving purposes, scientific or historical research purposes or statistical purposes; carried out in accordance with Article 89(1) of the GDPR and DPA Section 19, and the processing is in the public interest.

Related Legislation:

Section 251 NHS Act 2006

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

Shred-It

To provides solutions for records management, data backup and recovery, document management, secure storage, and accredited data destruction.

The source of the information shared in this way is your electronic GP record.

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

Article 9 (2) (i) - for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law

In accordance with DPA Schedule 1, Part 1, (4) - The condition for the processing is met where it is necessary for archiving purposes, scientific or historical research purposes or statistical purposes; carried out in accordance with Article 89(1) of the GDPR and DPA Section 19, and the processing is in the public interest.

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way Otford Medical Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

[insert the name of the organisation responsible financial and governance audit]

 

The supplier [insert name] offer a wide range of business assurance services, from internal audit, counter fraud and forensic investigations, risk management and governance.

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

 

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

You have the right to:

  • To access, view or request copies of your personal information;
  • request rectification of any inaccuracy in your personal information;
  • restrict the processing of your personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: You have a general right to raise an objection to your personal data being shared for the purpose of risk stratification.

If you wish to exercise any of your rights please contact the Practice (data controller) or the DPO and your request will be carefully considered.

Right to complain: If you are dissatisfied with the way the Practice process your data, you have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/ 

Fairway Training

The Fairway Training  provides practices with a software solution to enable the recording of Human Resources related information of its  employees’ personal data, in particular for the purposes of the recruitment, obligations performance contract of employment, rights and benefits management planning, health and safety, equality and diversity in the workplace, health and safety at work.

The Practice ensures that personal data it collects from employees are used only for employment related purposes or where there is a statutory obligation to share the personal information with to regulatory bodies (e.g. courts, police or NHS England).

Data Retention Period:

All records held in the Practice EMIS  system are kept for the duration specified in the Records Management Codes of Practice for Health and Social Care

 

The processing of personal data is permitted under the following GDPR and DPA conditions:

GDPR Article 6(1) (e) - public interest or in the exercise of official authority;

DPA Section 8 (d) - processing is necessary for the exercise of statutory functions;

The processing of special categories of personal data concerning health is permitted under the following GDPR and DPA conditions:

Article 9(2) (b) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law;

In accordance with DPA  Schedule 1, Part 1 , (1a) - the processing for employment, social security and social protection is met where it is for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection;

Employees have the  right to:

  • To access, view or request copies of their personal information held by the Practice;
  • request rectification of any inaccuracy to their personal information;
  • restrict the processing of their personal information where:
  • accuracy of the data is contested,
  • the processing is unlawful or,
  • where we no longer need the data for the purposes of the processing.

Right to object: Employees have a general right to raise an objection to the sharing personal data.

If an employee wishes to exercise his/her rights they can contact the Practice (data controller) or the DPO and their request will be carefully considered.

Right to complain: If an employee is dissatisfied with the way Otford Medical Practice process his/her personal data, they have the right to appeal/complain to the Information Commissioner (IC). The IC can be contacted at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Tel: 0303 123 1113 or 01625 545 745
Email:
https://ico.org.uk/global/contact-us/