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Information and public services for the Island of Jersey

L'înformâtion et les sèrvices publyis pouor I'Île dé Jèrri

Primary Care privacy policy

‚ÄčAbout Primary Care

Primary Care provides care and treatment to islanders through GP services across multiple practices.

Practices are registered with the Jersey Office of the Information Commissioner (JOIC) to process personal and special category information under the Data Protection (Jersey) Law 2018.

Why Primary Care collects personal information about you

The clinical and administration team caring for you need to collect and maintain information about your health, treatment and care, so that you can be given the best possible healthcare from us.

This personal information may be held in a variety of formats, including:

  • paper records
  • electronically on computer systems
  • in pictures
  • video
  • audio files

Our legal basis for processing your personal information

Any personal information we hold about you is processed for the purposes of the following articles of the Data Protection (Jersey) Law 2018:

  • Employment and Social Fields (Article 8) 
  • Medical Purposes (Article 15) 
  • Public Health (Article 16) 

What personal information we need to collect about you and how do we obtain it

We collect personal information from a number of sources including:

  • registration forms
  • referral details from our clinical or administration team
  • other third party healthcare providers
  • hospitals
  • directly from you or your authorised representative

We will likely hold the following basic personal information about you:

  • name, former names and preferred names
  • address
  • telephone number
  • email address
  • bank account details (where charges apply)
  • social security number and other unique identifiers
  • date of birth
  • non-binary or gender expression
  • medical history and diagnoses
  • observation charts and test results
  • next of kin information
  • correspondence and communication, via email, telephone calls and letters
  • family, lifestyle and social circumstance or safeguarding status
  • physical or mental health condition
  • racial or ethnic origin
  • religious or other beliefs of a similar nature
  • sexual life

It is important we have a complete picture of you, to help staff deliver appropriate treatment and care plans that meet your needs.

What we do with your personal information

We use your records to: 

  • directly, manage and deliver healthcare to you 
  • ensure that the staff involved in your care have accurate and up to date information
  • assess and advise on the most appropriate care for you
  • improve the quality and type of care you receive
  • ensure appropriate information is available if you see another healthcare professional, or are referred to a specialist or Health and Community Services (HCS), or other health provider in Jersey, UK or elsewhere

What we may do with your personal information

We may also use the personal information we collect about you to:

  • remind you about your appointments 
  • send you relevant correspondence
  • review the care we provide through audit, service improvement, and patient satisfaction surveys
  • refer you to a secondary care provider, such as HCS
  • request tests and receive results from external testing providers, such as HCS Pathology and Radiology
  • support the funding of your care, e.g. with commissioning organisations
  • prepare statistics on Primary Care performance to meet the needs of the population or for HCS and or other regulatory bodies, such as the Jersey Care Commission
  • train and educate healthcare professionals
  • report and investigate complaints, claims and untoward incidents, in collaboration with the Primary Care Governance Team and Responsible Officer
  • report events to the appropriate authorities, such as the GMC, when we are required to do so by code of practice, or by law

Where possible, we anonymise or pseudonymise your personal information to protect patient confidentiality, unless there is a legal basis that permits us to use it, and we will only use or share the minimum information necessary.

The Calidcott Principles

The manner in which Primary Care use and share health and social care data is informed by the Caldicott Principles, a framework for determining ethical and appropriate processing.

When making decisions about how and why we use and share data, we consider whether:

  • the purpose of the processing can be justified; is the requirement clearly defined and documented
  • it is necessary to use the data
  • we need to identify individuals
  • we are using the minimum necessary information to fulfil the purpose
  • the people processing the data 'need to know'
  • everyone involved is aware of their responsibilities and obligations
  • the processing of the data complies with relevant privacy legislation
  • the duty to share for care and treatment is as important as the duty to protect patient confidentiality
  • we are adequately informing you about how your data is used and the reasons why

More information about the Caldicott Principles can be found on the UK Caldicott Guardian Council.

Who we share your personal information with and why

We may share relevant personal and special category information with other health and social care organisations and external organisations. We may share your information for healthcare purposes with: 

  • HCS
  • Customer and Local Services (CLS)
  • Children. Young People, Education and Skills (CYPES)
  • NHS UK
  • Out of Hours GP Service (JDOC)
  • other General Practitioners (GPs)
  • ambulance services
  • private consultants
  • external secondary or tertiary care  providers

Health and Community Services

Information is shared regularly with HCS and other Government departments to deliver services and collaboratively care and treat islanders.

We refer you to secondary services where we believe you will benefit from further investigation and care, including mental health services and specialists, such as orthopaedic or the diabetes centre.

We request services and receive results from HCS in relation to pathology and radiology testing and imaging to review your needs and determine further treatment, where necessary.

We receive discharge summaries and responses to referrals so we are aware of interaction between services and can deliver good outcomes to patients. This includes primary care receiving medicine discharge records following admissions so that safe medication regimes can be maintained across service providers.

We are provided with vaccination and test events so that we can maintain a record of illness and your immunisations and to ensure that you are appropriately protected from illness. This includes the sharing of Covid-19 and seasonal flu data with us.

We provide information to HCS Safeguarding Teams to ensure that they can adequately deliver care to vulnerable people in the community.

The Summary Care Record

We provide health data to acute services in HCS, such as the Hospital Pharmacy and the Emergency Department, in the form of the Summary Care Record.

 This provides a limited view of information held within your primary care record including your:

  • primary care interaction
  • medicine administration
  • demographic
  • known allergies 

Sharing this information:

  • ensures healthcare professionals can make decisions based on a holistic view of you
  • improves outcomes
  • reduces delays to care due to manual information sharing processes, such as telephone calls 
  • reduces the risks associated with medicine administration across numerous providers

Screening programmes

We also provide data to HCS to help administer vaccination and screening programmes. Screening is a way of finding out if you are at risk of a health problem, so that early treatment and information can be offered to help you make informed decisions.

HCS contact you directly if you are eligible for screening programmes.

We use automated data processing in the form of data extraction tools and coded searches to identify individuals who are eligible for screening tests and referrals.

We provide information to HCS so that they can accurately identify those that are diagnosed with diabetes. This enables them to contact individuals directly to offer tests to identify diabetic retinopathy, which can cause sight loss if not detected early.

In all cases, you can opt out of programmes when contacted by the HCS Screening Teams. However, screening is considered a vital element of preventative healthcare and HCS reserves the right to contact you again after a period of time to secure your participation. You may also contact the screening programmes directly should you change your mind.  

Immunisation or preventative programmes

Immunisations, such as the Covid-19 vaccination programme, are often delivered in phases, ensuring that those most vulnerable to the effect of diseases are offered the opportunity to protect themselves as a priority. Eligibility is often determined based on diagnoses, conditions, or age and as such, it is vital that the most accurate and up to data is used.

Where required, HCS request demographic data from us based on the eligibility criteria. The data shared is limited to your demographic details and does not state the reason for your eligibility. For example, HCS may ask for data relating to those that have a particular type of cancer, have received radiotherapy in the last 6 months, or have a severe liver condition. We provide the names and contact details but not the specific reason as to why the individual is eligible.

The data is shared securely to those administering the programme, and used only for that purpose. Individuals are under no obligation to opt-in to a vaccination or preventative programme.

Digital Health

The 2017 Digital Health Strategy outlined collaborative strategies that would be implemented to improve the effectiveness of data sharing and improve the outcomes for patients.

Health and Community Services and the Primary Care Body are currently working with other Government departments and care providers to deliver the Jersey Health Demographic Service and the Jersey Care Record.

Both projects are in the discovery phase currently and will see data shared to those that 'need to know' to deliver platforms and databases designed to support your care and treatment. 

We will publish more information about how your data will be processed and shared for these purposes once completed.

Other data sharing

We will not disclose any health information to third parties who are not enabling care and treatment, without your explicit consent, unless there are circumstances, such as when the health or safety of others is at risk or where current legislation permits or requires it.

There are occasions where the Practice may be required by law to share information provided to us with other bodies responsible for auditing or administering public funds, to prevent and detect fraud.

This includes, but is not limited to, disclosure under a court order, sharing with the HCS Primary Care Governance Team for inspection purposes i.e. to support the role of the Responsible Officer, the police for the prevention or detection of crime or where there is an overriding public interest to prevent abuse or serious harm to others and other public bodies (e.g. CLS for the misuse of public funds to prevent and detect fraud).

Transferring information to countries within the European Economic Area (EEA) is seen as relatively safe because these countries have strong data protection laws in place. There is a list of countries outside of the EEA that are also deemed safe. If we need to transfer your information outside of the EEA or to a country which is not on the list of safe countries, we will take extra steps to keep your information safe.

The Practice is required to protect your personal information, inform you of how your personal information will be used.

How we maintain your records

Your personal information is held in both paper and electronic forms for specified periods of time as set out in the Information Government Alliance Records Management Code of Practice for Health and Social Care. Whilst this is UK legislation for NHS Providers, it is used in Jersey as a 'best practice solution' in the void of our own similar procedures.

We hold and process your information in accordance with the Data Protection (Jersey) Law 2018 and where appropriate the General Data Protection Regulation. In addition, everyone working for our Practice must comply with the Contractual Duty of Confidentiality and various national and professional standards and requirements.

We have a duty to:

  • maintain full and accurate records of the care we provide to you
  • keep records about you confidential and secure
  • provide information in a format that is accessible to you

Electronic Communications

Some services in the Practice provide the option to communicate with patients via:

  • email
  • SMS text 
  • other electronic communications

The Practice cannot guarantee the security of this information whilst in transit, and by requesting this service you are accepting this risk.

Your rights

If we need to use your personal information for any reasons beyond those stated above, we will discuss this with you and ask for your explicit consent. The Data Protection (Jersey) Law 2018 gives you certain rights, including the right to:

Right to Access

Request access to the personal data we hold about you, e.g. in health records. If you wish to access your GP records,  contact your GP directly.

Right to accuracy

Request the correction of inaccurate or incomplete information recorded in our health records, subject to certain safeguards.

Right to restrict

You have the right to request that we restrict the processing of your personal information. You can exercise this right in instances where you believe the information being processed is inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request but we may be required to continue processing your information to comply with a legal requirement, to deliver medical care, and fulfil the function of social services and social care.

Right to withdraw consent

Where you have been asked to give your consent to process your information, you have the right to withdraw your consent to the further processing of your personal data. However, this may cause delays or prevent us delivering a service to you. 

We will always seek to comply with your request but we may be required to hold or process your information in order to comply with a legal requirement, to deliver medical care and treatment, and fulfil the function of social services and social care.

Under the Data Protection (Jersey) Law 2018, we are authorised to process data for the purposes of:

  • Employment and Social Fields (Article 8) 
  • Medical Purposes (Article 15) 
  • Public Health (Article 16)

Your consent is only required if we intend to share your health records beyond these purposes, as explained above (e.g. research). 

Any consent form you will be asked to sign will give you the option to 'refuse' consent and will explain how you can 'withdraw' any given consent at a later time. The consent form will also warn you about the possible consequences of such refusal/withdrawal.

Right to portability

You can request your personal information to be transferred to other providers.

Right to object

You have the right to object to us processing your data, preventing us from using it. However, this right applies only when we are processing your data for: 

  • a task carried out in the public interest
  • an exercise of official authority
  • our legitimate interests
  • scientific research
  • statistical purposes 
  • direct marketing purposes

Right to complain

If you wish to raise a complaint on how we have handled your personal data, you can contact your Primary Care GP Practices' Data Protection Officer who will investigate the matter and respond to you accordingly and where appropriate.

The Jersey Office of the Information Commissioner

The Jersey Office of the Information Commissioner (JOIC) is the body that regulates the Practice under Data Protection legislation. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the JOIC at:

Jersey Office of the Information Commissioner
2nd Floor
5 Castle Street
St Helier
JE2 3BT

Email enquiries@jerseyoic.org or call +44 (0) 1534 716530.

Transferring to another practice

If you decide at any time and for whatever reason to transfer to another practice, your GP will transfer your medical records to your new doctor on receipt of your signed consent from your new doctor.

If you have any questions speak to your GP, any member of the administration team at your Primary Care GP Practice or ask to speak to the Practice Manager.

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