Practice Policies & Patient Information
Accessing your GP – Held Records
Via the NHS app or Patient Access
As a patient at Ashford Medical Partnership you are now able to access your prospective full medical record going forward via the NHS app (and Patient Access).
Your GP medical record contains consultation notes based on conversations between you, your GP and other members of the clinical team: medicines prescribed to you; all test results including hospital investigations; allergies; vaccines; and your medical conditions along with documents that may have been sent from local hospitals, clinics or other agencies, eg the police. There could be sensitive and personal information within your medical record.
We are supportive of providing you with access to your record, but we wish to do this safely and make you aware that this is happening so that you can opt out, if you so wish. You may wish to consider what you will see, and the risks which may be involved in having such confidential data either on your smartphone with the NHS app installed or online if other people might have access to that information through your devices. If you are in a difficult or pressured relationship for example, you may prefer your records to remain accessible only to those treating you, with them not appearing on your smartphone or online. Government has been clear that if a patient does not wish to have access, then we do not have to provide it. This is one reason why we have asked if you wish to opt out, or have it switched off for the time being.
You can have access to different parts of your medical records, for example medication history and allergies which will enable you to order your repeat prescriptions. It’s also possible to request access to what we call your ‘coded record’ where you can see a list of medical problems and results. You can also request access to the ‘full’ record where you will be able to see everything, including the notes which have been written by doctors, nurses and others involved in your care, at the GP surgery, and elsewhere.
It’s important to remember that these documents may, at times, contain information that could be upsetting, especially if they contain news of a serious condition. It can also be a cause for worry seeing results online when it isn’t clear what the results might mean, and no one is available to ask, as can be the case during the evening or at weekends, for example.
Sometimes people with a mental health condition might prefer not to see documents that remind them of difficult times in their life. Letters from mental health teams sometimes go into detail about past events, and great care would be needed in deciding whether you would want to see these letters. It is possible for individual items to be hidden at your request and your GP would be happy to talk about any concerns you may have.
Great care is also needed in case private details might cause harm at home, should people in a difficult or pressured relationship be forced to show their medical record to an abusive partner. Anyone in such a position should make this clear to us at the practice, so we can take steps to keep you safe. This might mean removing access through the NHS app for the time being, or through a careful process where we hide sensitive things. We would talk this through with you.
Requesting access – what do I need to do?
The easiest way to get access is to create an NHS login through the NHS app. Although you can also access your GP records via the internet on a computer, the first bit is easiest if done through a smartphone. If you don’t have one, you may have a family member or friend you trust who can help you.
If you use the NHS app, you’ll have to set up an account using a unique e-mail address and then ‘authenticate’ yourself to the NHS system to prove you are who you say you are. This will involve confirming your name, date of birth and contact details. The NHS login has several levels of authentication and to gain access to your records you’ll need the highest level of authentication. This generally involves you recording a short video of yourself to prove you are a real person as well as uploading a copy of a suitable identification document.
Once you have suitably authenticated yourself to the NHS app and created your login you will have access to your medical records, we would ask you to be mindful of the risks associated with access and the importance of not sharing passwords or having them stored in your smartphone if you think other people might want to see them without your permission. If you have any concerns, you should explain these to your GP practice team who can guide you.
If you would prefer to use Patient Access, the Practice has a form for you to complete. You will be asked for ID and proof of address, together with your email address.You will also be asked what level of access you require. Once you’re ready to proceed with online access, your request will be forwarded to our clinical team for review. If any concerns arise during this process, the practice may reach out to you for a discussion to ensure that granting access aligns with our standards of safety and care.
We are not sure how many people will ask for access all at once, so there may be a wait, but we will do our best to get you online access as soon as we can.
Ashford Medical Partnership for the year ended 31 March 2021
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 Ashford Medical Partnership in the last financial year was £93,044 before Tax and National Insurance. This is for 5 full-time GPs and 8 part-time GPs and 1 locum.
This is the mean GP Net Earnings for the practice in respect of accounting periods ending in the financial year to 31st March 2021, which we are required to publish. A hard copy is available upon request.
The mean GP Net Earnings calculation includes:
- Income from NHS England, ICBs and local authorities for the provision of GP services that relate to the contract or which have been nationally determined
- Earnings are pre-tax, National Insurance and employee pension contributions
- GP Partner earnings are stated net of related practice expenses
The following are excluded from the calculation of mean GP Net Earnings:
- Certain income and costs related to the premises such as Notional Rent and Mortgage Interest
- Local Enhanced Service (LES) payments
- Dispensing income
- NHS Sundry income
- Non-NHS income
- Any employer NHS Pension contributions
Chaperones
The practice is committed to providing a safe, comfortable environment where patients and staff can be confident that the best practice is being followed at all times and the safety of everyone is of paramount importance.
All patients are entitled to have a trained chaperone present for any consultation, examination or procedure where they feel one is required. Patients can have a family member or friend for support if they wish.
Wherever possible we would ask you to make this request at the time of booking the appointment so that arrangements can be made and your appointment is not delayed in any way. Where this is not possible we will endeavour to provide a formal trained chaperone at the time of request. However, occasionally it may be necessary to reschedule the appointment.
Your healthcare professional may also require a chaperone to be present for certain consultations in accordance with our chaperone policy.
Procedure
- The clinician will contact a nurse or other suitable trained person to request a chaperone.
- The clinician will record in the notes that the chaperone is present, and identify the chaperone who will wear a lanyard identifying them as a chaperone.
- Where no chaperone is available the examination will not take place – the patient should not normally be permitted to dispense with the chaperone once a desire to have one present has been expressed.
- The chaperone will enter the room discreetly and remain in room until the clinician has finished the examination and with time for the patient to redress.
- A ‘formal chaperone’ will attend inside the curtain at the head of the examination couch and watch the procedure. If asked to attend outside the curtain, this will be recorded on the patient’s notes as an ‘informal’ chaperone’ as they are not a direct witness to either the procedure itself or the actions and behaviour of the patient and the practitioner.
- The clinician should explain the procedure and obtain the consent for the procedure from the patient in the presence of the chaperone so that the chaperone knows what the patient has consented to.
- To prevent embarrassment, the chaperone should not enter into conversation with the patient, apart from introducing themselves when entering, or with the GP unless requested to do so. The chaperone should not make any mention of the consultation afterwards.
- The patient can refuse a chaperone, and if so this must be recorded in the patient’s medical record.
- If at any time during the procedure you feel uncomfortable or concerned please ask the doctor or nurse to stop and explain things again. It may not always be possible to stop immediately; this will depend on the procedure being undertaken.
If you would like to see a full copy of our Chaperone Policy or have any questions or comments regarding this, please contact the Practice Manager
Confidentiality
All staff at the practice have a duty to preserve the absolute confidentiality of all patient information and this obligation continues in perpetuity. All staff sign a confidentiality agreement.
Information is only given to a third party upon receipt of a satisfactory written consent. Patient data held on the practice computer system is managed in accordance with the Data Protection Act (1998).
Information Sharing
If you wish to send information to the Practice via email please confirm that you have read our Information Sharing Agreement and confirm that you have done so in your email. This applies whether you are sending in information at the request of one of our staff or not.
Submitting information to the Practice via email
To facilitate timely and effective care for patients our clinicians will occasionally request that patients submit information via email. Whether in the form of text or images any information submitted at the request of the clinician will be sent to a secure nhs.net email account, the address of which the patient will be advised before any submission is made.
In submitting information electronically a patient, or anyone acting on their behalf with the patient’s express written consent, accepts responsibility for the security of the email account from which the information is sent. Ashford Medical Partnership (Dr Naky and Partners) accepts no liability for unsecured email addresses from which data is sent to us. We are responsible for the security of information once it is received into the designated nhs.net email account and undertake to comply with all relevant legislation concerning patient confidentiality on receipt of such information.
Where a patient or their approved representative is offered the option to submit information to us electronically they will be referred to this agreement which is displayed within all our premises and on our website.
When submitting information the sender will be required to include a statement confirming that they have read and consent to the conditions specified above.
Any information provided including photographic images will be saved on the patient’s electornic record unless they specifically request that it is not.
CQC Statement of Purpose
Under the Health and Social Care Act 2008 (The Care Quality Commission (Registration) Regulations 2009 Part 4), the registering body (Ashford Medical Partnership) is required to provide to the Care Quality Commission a statement of purpose.
The name and address of the registered provider is
Ashford Medical Partnership
Willesborough Health Centre
Bentley Road
Ashford
TN24 0HZ
Registered GP manager: Dr Navin Kumta
Ashford Medical Partnership consists of 6 GP partners and 5 salaried doctors:
Dr Navin Kumta, Dr Chun Man James Wong, Dr Iwin Varghese,
Dr Khodbakhsh Borhanzahi , Dr Raj Ramjutton,
and Dr Suhail Jan (Partners)
Dr Sarah Harper, Dr Achamma Thomas, Dr Lalita Gurung, Dr Babita Gurung, Dr James Thompson, Dr Rachel Hodgkiss, Dr Similoluwa Femi-Akinpelu and Dr Seema Zulfikar (Salaried GPs)
The Partnership operates from purpose built sites in Willesborough, Singleton and St Stephens Health Centre in Ashford, Kent. The Willesborough and Singleton Health Centres merged in 2017 and subsequently a merger with South Ashford Medics was completed on 11th March 2019 to create Ashford Medical Partnership under a single G code – G82080.
As of 11th March 2019 in addition to the main site at Willesborough Health Centre we provide services from branch sites located at:
Singleton Health Centre – 10 Singleton Centre, Ashford, TN23 5GR
St Stephens Health Centre – St Stephens Walk, Ashford, TN23 5AQ
The Partnership also employs Advanced Clinical Practitioners, Nurse Practitioners, a Paramedic Practitioner, a Community Practitioner and Clinical Pharmacists to complement and diversify the services offered and to assist in providing the right care at the right time to our patient population. We also have a team of Practice nurses and health care assistants under the supervision of a Nursing Team Lead.
Ashford Medical Partnership provides GMS (General Medical Services) and a range of additional services to our 36,515 patient population. Our patients are able to access services from our three sites all of which sit within a 3 mile radius.
Ashford Medical Partnership also has its own Primary Care Network for the three surgery sites known as ‘Ashford Medical Partnership PCN’ (U50767).
Ashford Medical Partnership (AMP) is a member of Ashford Clinical Providers Ltd (ACP). ACP is a GP owned organisation in Ashford, Kent and is formed of 12 Practices whose aims are to provide integrated, inter-professional, transformative, effective, sustainable Health and Social Care, in the best interest of the patients registered within Ashford, working towards the right care for the right person at the right time. The organisation offers a range of services including general practice (treatment of disease, disorder and injury), diagnostic and screening, surgical procedures, outpatient clinics and management of long-term conditions. Services are primarily delivered from GP practices who all hold current CQC registration. All ACP medical services are delivered by a combination of local GPs, local consultants, specialist nurses and practitioners to name a few.
Our doctors also provide clinics in the East Kent Urgent Treatment Centre (UTC) – The aim is to provide a primary care led UTC service to patients experiencing urgent needs. The UTC will diagnose and treat many of the most common ailments people would otherwise have to attend A&E for, thereby reducing demand and easing pressure on hospitals whilst freeing up capacity in other parts of the system to treat more serious cases.
Adults and children with minor Illness or injury are treated within the UTC.
UTC clinics are held at the following locations:-
William Harvey Hospital
Queen Elizabeth the Queen Mother Hospital
Kent and Canterbury Hospital
Buckland Hospital
Faversham Health Centre
Our Aims and Objectives
- We aim to ensure a high quality, safe and effective general/personal medical services and environment
- To provide monitored, audited and continually improving healthcare services
- To provide healthcare which is available to a whole population and create a partnership between patient and health profession which ensures mutual respect, holistic care and continuous learning and training.
- The provision of accessible healthcare which is proactive to healthcare changes, efficiency and innovation and development.
- To improve clinical governance and evidence-based practice
- To improve Clinical and Non-clinical risk management
- To reduce risk in specific clinical risk areas and facilities
- To improve capacity
- To optimise performance against key targets and core standards
- To meet key targets set by the Ashford Clinical Commissioning Group
- To participate effectively in the local Cluster Group of GP Practices
- To become a patient centred organisation
- To improve services offered to patients
- To improve the facilities available for patients at the surgery
- To improve communication between the surgery and the patients
- To encourage the development of an active and effective patient participation group
- To recruit, retain and develop a highly motivated and appropriately skilled workforce
- To enhance performance of the workforce
- To develop management capability
- To guide the employees in accordance with the Equalities Scheme
- To continue the development of the AMP facilities
- To ensure effective management and governance systems
- To ensure robust corporate processes
- To effectively engage with our Integrated Commissioning Board
- To ensure a robust Information Technology strategy to support the Partnership
The registered activities and service types have been agreed by the Partners in accordance with CQC guidance. Services are described under registered activity and Service Type.
The regulated services provided by Ashford Medical Partnership
- Routine medical checks and general/personal medical services
- NHS relevant prescriptions and medications or a private prescription can be issued.
- Immunisations, e.g. COVID, Childhood Immunisations, Influenza, Pneumonia, and Shingles, Foreign travel advice and immunisation
- Executive & employee medicals – Our GP’s are able to carry out medical report and review.
- Smoking Cessation – Any patient who is a smoker and ready to stop smoking can self-refer to “One You Kent” for advice and an assessment. Our GPs can also offer support and refer the patient into this service for a range of support by the trained advisers.
- Asthma/Respiratory clinic – The Surgery has facilities for spirometry / lung function testing.
- Diabetic clinic – The Surgery operates a diabetes clinic each week to provide ongoing care for our diabetic patients and run by trained nurses and supervised by GP Partners.
- Family Planning Clinic – Our family planning clinic is run by our Nurse Practitioner.
- Pneumonia/Flu vaccination – At Willesborough Health Centre we offer ‘at risk’ groups the flu vaccine at a certain time each year to protect you against the flu virus. The Practice also offers pneumonia to patients aged 65 and over.
- Health Checks – We offer health checks to patients aged 40 to 74 who do not have a pre-existing health condition. If a patient is eligible, they will be invited to an NHS Health Check by the GP every 5 years.
- Phlebotomy.
- Midwifery – The community midwives hold their own clinics at Willesborough Health Centre for patients the Practice. They supervise antenatal care, undertake deliveries in hospital and at home where appropriate.
- Minor Surgery/Joint Injections – We offer a number of minor operations/surgeries for dermatology related concerns. The minor operation clinics are carried out by Dr Naky. Joint injections are performed by Dr Ramjutton and Sumin Moses (First contact Physiotherapist).
- Cervical Screening – Some of our nurses are qualified to carry out cervical screening and tests in the form of cervical smears
- Multi-disciplinary Team meeting – We have clinical representation at the “AMP PCN MDT” meetings engaging with colleagues from community health providers.
Improved Access
As a member of Ashford Clinical Providers Ltd (Federation), we participate in the delivery of Improved Access services within Ashford as part of a rota system, holding additional pre bookable appointments, seeing patients from our own as well as neighbouring practices. These appointments are offered at Willesborough Health Centre on Monday and Wednesday evenings from 1830-2000 and on Saturdays between 0900-1300 and at St Stephen’s Health Centre on Thursday evening from 1830-2000.
Our ethos is to strive towards a partnership between patients and health professionals based on the following key facets:
Mutual Respect
We endeavour to treat all our patients with dignity, respect and honesty. Everyone within the business is committed to deliver an excellent service. We ask all patients to highlight any discrepancies and to offer the same commitment in return.
‘Holistic’ Care
We treat ‘patients’ and illnesses. This means that we are equally interested in the physical, psychological and social aspects of your individual care.
Continuity of Care and the ‘Therapeutic relationship’
Building and maintaining a strong relationship between doctors, health professionals, and patients is essential to the way we work. This is especially so in the management of ongoing problems or long-term illness. In these circumstances we would encourage our patients to continue seeing the same health professional and, wherever possible, we will facilitate this through our appointments system.
Learning and Training
We believe in “life-long learning” and all health professionals and administrative staff, undergo an annual appraisal where learning and development needs are identified. We also recognise the benefit of supported learning for our patients and families in enhancing their ability to manage and deal with both ‘self-limiting’ and long-term illnesses
Open List
We have an open list policy and accept patients who are resident and newly resident in the defined Practice area.
Email address – [email protected]
General Data Protection Regulation (GDPR)
Annex A – Practice privacy notice
Dr Naky and Partners at Ashford Medical Partnership has a legal duty to explain how we use any personal information we collect about you, as a registered patient, at the practice. Staff at this practice maintain records about your health and the treatment you receive in electronic and paper format.
What information do we collect about you?
We will collect information such as personal details, including name, address, next of kin, records of appointments, visits, telephone calls, your health records, treatment and medications, test results, X-rays, etc. and any other relevant information to enable us to deliver effective medical care.
How we will use your information
Your data is collected for the purpose of providing direct patient care; however, we can disclose this information if it is required by law, if you give consent or if it is justified in the public interest. The practice may be requested to support research; however, we will always gain your consent before sharing your information with medical research databases such as the Clinical Practice Research Datalink and QResearch or others when the law allows.
In order to comply with its legal obligations, this practice may send data to NHS Digital when directed by the Secretary of State for Health under the Health and Social Care Act 2012. Additionally, this practice contributes to national clinical audits and will send the data that is required by NHS Digital when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form; for example, the clinical code for diabetes or high blood pressure.
Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the GDPR.
Maintaining confidentiality and accessing your records
We are committed to maintaining confidentiality and protecting the information we hold about you. We adhere to the General Data Protection Regulation (GDPR), the NHS Codes of Confidentiality and Security, as well as guidance issued by the Information Commissioner’s Office (ICO). You have a right to access the information we hold about you, and if you would like to access this information, you will need to complete a Subject Access Request (SAR). Please ask at reception for a SAR form and you will be given further information. Furthermore, should you identify any inaccuracies, you have a right to have the inaccurate data corrected.
Risk stratification
Risk stratification is a mechanism used to identify and subsequently manage those patients deemed as being at high risk of requiring urgent or emergency care. Usually this includes patients with long-term conditions, e.g. cancer. Your information is collected by a number of sources, including Dr Naky and Partners; this information is processed electronically and given a risk score which is relayed to your GP who can then decide on any necessary actions to ensure that you receive the most appropriate care.
Invoice validation
Your information may be shared if you have received treatment to determine which Clinical Commissioning Group (CCG) is responsible for paying for your treatment. This information may include your name, address and treatment date. All of this information is held securely and confidentially; it will not be used for any other purpose or shared with any third parties.
Opt-outs
You have a right to object to your information being shared. Should you wish to opt out of data collection, please contact a member of staff who will be able to explain how you can opt out and prevent the sharing of your information; this is done by registering a Type 1 opt-out, preventing your information from being shared outside this practice.
Retention periods
In accordance with the NHS Codes of Practice for Records Management, your healthcare records will be retained for 10 years after death, or if a patient emigrates, for 10 years after the date of emigration.
What to do if you have any questions
Should you have any questions about our privacy policy or the information we hold about you, you can:
- Contact the practice’s data controller via email at [email protected]. GP practices are data controllers for the data they hold about their patients.
- Write to the data controller at Willesborough Health Centre, Bentley Road, Ashford, TN24 0HZ
- Ask to speak to the Business Manager Philip Blake, or their deputy Prue Plester
The Data Protection Officer (DPO) for Dr Naky and Partners is Philip Blake and he/she is based at Willesborough Health Centre
Complaints
In the unlikely event that you are unhappy with any element of our data-processing methods, you have the right to lodge a complaint with the ICO. For further details, visit the ICO website.
Changes to our privacy policy
We regularly review our privacy policy and any updates will be published on our website, in our newsletter and on posters to reflect the changes. This policy is to be reviewed 1 October 2018.
GPDPR (GP Data for Planning and Research Programme)
GP Data for Planning and Research Programme: GP data has a crucial role to play in research and planning which can improve public health, but it is important for patients and the public that this data is made available for appropriate purposes in a secure and trusted manner. This programme is a planned replacement for the GP Extraction Service (GPES) currently used to collect data for planning and research from general practices in England.
It is a legal obligation for the practice to comply with the Data Provision Notice ‘DPN’ for this programme as a result of a new direction from the secretary of state for health and social care as part of the Health and Care Act 2012. Once fully established, this new collection will replace multiple other data collections from general practices including the GPES in due course.
Infection Prevention Control Statement
Introduction
Policy statement
In accordance with The Health and Social Care Act 2008, Ashford Medical Partnership is committed to the prevention of healthcare associated infection and patient safety is of the utmost priority. Good management and organisational processes are crucial to ensure that high standards of infection prevention (including cleanliness) are maintained.
Status
This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment.
Training and support
The practice will provide guidance and support to help those to whom it applies to understand their rights and responsibilities under this policy. Additional support will be provided to managers and supervisors to enable them to deal more effectively with matters arising from this policy.
Scope
Who it applies to
This document applies to all employees of the practice, other individuals performing functions in relation to the practice, such as agency workers, locums, and contractors.
Why and how it applies to them
Infection prevention control is the responsibility of all staff at Ashford Medical Partnership. All personnel are to be fully au fait with the guidance given in the policies associated with this statement.
The practice aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have in respect to the individual protected characteristics of those to whom it applies.
Infection Prevention Control Statement
Infection Prevention Control (IPC) lead
At Ashford Medical Partnership the IPC lead is Dr James Wong and Lead practice nurse Áine Quigley.
Responsibilities
The IPC lead is responsible for promoting good infection control practice within Ashford Medical Partnership. They are to ensure that:
- They provide timely advice to colleagues, service users and relatives (where applicable)
- Training is provided regarding the standard principles of infection prevention control, specifically training in hand decontamination, the use of PPE and the safe use of and disposal of sharps (this list is not exhaustive)
- Appropriate supplies of sharps containers, PPE and materials for hand decontamination are available
Risk Assessments
Risk assessments are undertaken to control risks in the workplace
Recommendation
Following the above risk assessments, the following recommendations were made/actions taken:
Significant events
Significant event analysis (SEA) should act as a learning process for the whole practice, as significant events can reflect good as well as poor practice.
Audit
Audit is an essential component of any infection prevention and control strategy weekly, monthly and quarterly audits are undertaken at Ashford Medical Partnership.
The IPC lead can provide further detailed information regarding the audits and subsequent action plans.
Guidance documentation and policies
Ashford Medical Partnership refers to the following guidance documentation and policies which are related to infection prevent and control:
- AMP Red Zone policy
- Infection Control Policy
- Infection Control Inspection Checklist
- Infection Control Protocol
Summary
All staff undertake infection prevention and control training and are committed to maintaining high standards of infection prevention and cleanliness within Ashford Medical Partnership.
Regular training, audits and reviews are key to the prevention of healthcare associated infection.
Annex A – Example Infection Control Annual Statement
Ashford Medical Partnership 17/12/2020
Purpose
This annual statement will be generated each year in December in accordance with the requirements of the Health and Social Care Act 2008 Code of Practice on the prevention and control of infections and related guidance. The report will be published on the practice website and will include the following summary:
- Any infection transmission incidents and any action taken (these will have been reported in accordance with our significant event procedure)
- Details of any infection control audits undertaken and actions undertaken
- Details of any risk assessments undertaken for the prevention and control of infection
- Details of staff training
- Any review and update of policies, procedures and guidelines
Infection Prevention and Control (IPC) Lead
The lead for infection prevention and control at Ashford Medical Partnership is Dr James Wong.
The IPC Lead is supported by Lead practice nurse Áine Quigley.
a. Infection transmission incidents (significant events)
Significant events involve examples of good practice as well as challenging events.
Positive events are discussed at meetings to allow all staff to be appraised of areas of best practice.
Negative events are managed by the staff member who either identified or was advised of any potential shortcoming. This person will complete a Significant Event Analysis (SEA) form that commences an investigation process to establish what can be learnt and to indicate changes that might lead to future improvements.
All significant events are reviewed and discussed in several meetings each month. Any learning points are cascaded to all relevant staff where an action plan, including audits or policy review, may follow.
b. Infection prevention audit and actions
Ashford Medical Partnership carry out weekly infection control audits of each site.
Annually Ashford Medical Partnership have an external IPC audit.
c. Risk Assessments
Risk assessments are carried out so that any risk is minimised to be as low as reasonably practicable. Additionally, a risk assessment which can identify best practice can be established and then followed.
This list of risk assessments is not exhaustive;
- General IPC risks
- Staffing, new joiners and ongoing training
- COSHH
- Cleaning standards
- Curtain cleaning or changes
- Staff vaccinations
- Sharps
- Water safety
d. Training
In addition to staff being involved in risk assessments and significant events, at Ashford Medical Partnership all staff and contractors receive IPC induction training on commencing their post. Thereafter, all staff receive refresher training annually.
e. Policies and procedures
The infection prevention and control related policies and procedures which have been written, updated or reviewed in the last year include, but are not limited, to:
- Red Zone
- Red Zone home visiting
- Infection control policy
Policies relating to infection prevention and control are available to all staff and are reviewed and updated annually. Additionally, all policies are amended on an ongoing basis as per current advice, guidance and legislation changes.
Responsibility
It is the responsibility of all staff members at Ashford Medical Partnership to be familiar with this statement and their roles and responsibilities under it.
Review
The IPC Lead Dr Wong and Áine Quigley Lead practice nurse are responsible for reviewing and producing the annual statement.
This annual statement will be updated on or before 13/07/2024
Signed by
Áine Quigley
For and on behalf of Ashford Medical Partnership
Make a complaint
If you have a complaint or concern about the service you have received from the doctors, or any of the staff attached to the Practice, please let us know. We operate a Practice Complaints Procedure, which meets national criteria of the NHS for dealing with complaints.
How to complain
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. Ideally this will be within days because this will enable us to establish what happened more easily. However, if this is not possible please let us have your complaint in writing to the Practice Manager, within six months of the incident, or within six months of discovering that you have a problem, provided this is within twelve months of the incident.
What happens next
We will normally acknowledge your complaint within two working days, and aim to look into your complaint within ten working days. We shall then be in a position to offer you an explanation, or invite you to a meeting with the people involved. You may bring someone with you to the meeting.
The purpose of the meeting will be to:
- find out what happened and what went wrong
- make it possible for you to discuss the problem with those concerned
- make sure you receive an apology, if this is appropriate
- identify what we can do to make sure the problem will not recur
Complaining on behalf of someone else
Please note that we keep strictly to the rules of confidentiality. If you are complaining on behalf of someone else, we will need their written permission to discuss the matter with you.
Exceptions to this are if you are complaining on behalf of your child, or on behalf of someone who is mentally incapacitated.
Complaining to NHS England
Our Practice Complaints Procedure is designed to help us put right anything that has gone wrong and to improve our service to patients. However this does not affect your right to approach the local Area Team for NHS England if you feel you cannot raise the complaint directly with us, or if you are dissatisfied with the result of our investigation.
Complaints regarding the provision of local NHS Services can also be raised with Ashford Clinical Commissioning Group, Inca House, Trinity Road, Ashford, TN25 4AB,
Phone: 03000 424815
If writing to the Practice regarding a complaint please address it to:
Tim Pethick, General Manager
Willesborough Health Centre, Bentley Road, Ashford, TN24 0HZ
Complaints or Allegations Procedure
Introduction
The purpose of the policy is to ensure that all patients (or their representatives) who have the cause to complain about their care or treatment can have freely available access to the process and can expect a truthful, full and complete response and an apology where appropriate. Complainants have the right not to be discriminated against as the result of making a complaint and to have the outcome fully explained to them.
The process adopted in the practice is fully compliant with the relevant NHS Regulations (2009) and guidance available from defence organisations, doctors` representative bodies and the Care Quality Commission. Everyone in the practice is expected to be aware of the process and to remember that everything they do and say may present a poor impression of the practice and may prompt a complaint or even legal action.
The general principle of the practice in respect of all complaints will be to regard it first and foremost as a learning process, however in appropriate cases and after full and proper investigation the issue may form the basis of a separate disciplinary action. In the case of any complaint with implications for professional negligence or legal action, the appropriate defence organisation must be informed immediately.
Availability of information
The practice will ensure that there are notices advising on the complaints process conspicuously displayed in all reception/waiting areas and that leaflets containing sufficient details for anyone to make a complaint are available without the need to ask. The ractice website and any other public material (Practice Leaflet etc.) will similarly provide this information and also signpost the complainant to the help available through the NHS Complaints Advisory Service.
Who can a formal complaint be made to?
ONLY TO – either the practice – OR – NHS England
In the event of anyone not wishing to complain to the practice they should be directed to make their complaint to NHSE:
- By telephone: 03003 11 22 33
- By email: [email protected]
- By post: NHS England, PO Box 16738, Redditch, B97 9PT
In those cases where the complaint is made to NHS England, the practice will comply with all appropriate requests for information and co-operate fully in assisting them to investigate and respond to the complaint.
Who can make a complaint?
A complaint can be made by or, with consent, on behalf of a patient (i.e. as a representative); a former patient, who is receiving or has received treatment at the Practice; or someone who may be affected by any decision, act or omission of the practice.
A Representative may also be
- by either parent or, in the absence of both parents, the guardian or other adult who has care of the child; by a person duly authorised by a local authority to whose care the child has been committed under the provisions of the Children Act 1989; or by a person duly authorised by a voluntary organisation by which the child is being accommodated.
- someone acting on behalf of a patient/ former patient who lacks capacity under the Mental Capacity Act 2005 (i.e. who has Power of Attorney etc.) or physical capacity to make a complaint and they are acting in the interests of their welfare.
- someone acting for the relatives of a deceased patient/former patient.
In all cases where a representative makes a complaint in the absence of patient consent, the practice will consider whether they are acting in the best interests of the patient and, in the case of a child, whether there are reasonable grounds for the child not taking the complaint on their own behalf. In the event a complaint from a representative is not accepted, the grounds upon which this decision was based must be advised to them in writing.
In the event the patient is deceased, we may agree to respond to a family member or anyone acting on their behalf or who has a legal authority to deal with an interest and welfare of the patient.
Who is responsible at the practice for dealing with complaints?
The practice “Responsible Person” is Dr A Naky, Senior Partner. They are charged with ensuring complaints are handled in accordance with the regulations, that lessons learned are fully implemented, and that no Complainant is discriminated against for making a complaint. This person should be a practice Partner (BMA Guidance and Primary Care contracts).
The practice “Complaints Manager” is Tim Pethick, General Manager, and they have been delegated responsibility for managing complaints and ensuring adequate investigations are carried out.
Time limits for making complaints
The period for making a complaint is normally:
(a) 12 months from the date on which the event which is the subject of the complaint occurred; or
(b) 12 months from the date on which the event which is the subject of the complaint comes to the complainant’s notice.
The practice has discretion to extend these limits if there is good reason to do so and it is still possible to carry out a proper investigation. The collection or recollection of evidence, clinical guidelines or other resources relating to the time when the complaint event arose may also be difficult to establish or obtain. These factors may be considered as suitable reasons for declining a time limit extension, however that decision should be able to stand up to scrutiny.
Action upon receipt of a complaint
A) Verbal Complaints: It is always better to try and deal with the complaint at the earliest opportunity and often it can be concluded at that point. A simple explanation and apology by staff at the time may be all that is required.
A verbal complaint need not be responded to in writing for the purposes of the Regulations if it is dealt with to the satisfaction of the complainant by the end of the next working day, neither does it need to be included in the annual Complaints Return. The practice will however record them for the purposes of monitoring trends or for Clinical Governance and that record will be kept and monitored by Tim Pethick, General Manager. Verbal complaints not formally recorded will be discussed when trends or issues need to be addressed and at least annually, with minutes of those discussions kept.
If resolution is not possible, the Complaints Manager will set down the details of the verbal complaint in writing and provide a copy to the complainant within five working days. This ensures that each side is well aware of the issues for resolution. The process followed will be the same as for written complaints.
B) Written Complaints: On receipt, an acknowledgement will be sent within five working days which offers the opportunity for a discussion (face-to-face or by telephone) on the matter. This is the opportunity to gain an indication of the outcome the complainant expects and also for the details of the complaint to be clarified. In the event that this is not practical or appropriate, the initial response should give some indication of the anticipated timescale for investigations to be concluded and an indication of when the outcome can be expected.
It may be that other bodies (e.g. secondary care/ Community Services) will need to be contacted to provide evidence. If that is the case, then a patient consent form will need to be obtained at the start of the process and a pro-forma consent form included with the initial acknowledgement for return.
If it is not possible to conclude any investigations within the advised timescale, then the complainant must be updated with progress and revised time scales on a regular basis. In most cases these should be completed within six months unless all parties agree to an extension.
The Investigation
The practice will ensure that the complaint is investigated in a manner that is appropriate to resolve it speedily and effectively and proportionate to the degree of seriousness that is involved.
The investigations will be recorded in a complaints file created specifically for each incident and where appropriate should include evidence collected as individual explanations or accounts taken in writing.
Final Response
This will be provided to the complainant in writing (or email by mutual consent) and the letter will be signed by the Responsible Person or Complaints manager under delegated authority. The letter will be on headed notepaper and include:
- An apology if appropriate (The Compensation Act 2006, Section 2 expressly allows an apology to be made without any admission of negligence or breach of a statutory duty).
- A clear statement of the issues, details of the investigations and the findings, and clear evidence-based reasons for decisions if appropriate.
- Where errors have occurred, explain these fully and state what has been or will be done to put these rights or prevent repetition. Clinical matters must be explained in accessible language.
- A clear statement that the response is the final one and the practice is satisfied it has done all it can to resolve the matter at local level.
- A statement of the right, if they are not satisfied with the response, to refer the complaint to the Parliamentary and Health Service Ombudsman, Millbank Tower, Millbank, London, SW1P 4QP or visit the Making a complaint page to complain online or download a paper form. Alternatively the complainant may call the PHSO Customer Helpline on 0345 015 4033 from 8:30am to 5:30pm, Monday to Friday or send a text to their ‘call back’ service: 07624 813 005
The final letter should not include:
- Any discussion or offer of compensation without the express involvement and agreement of the relevant defence organisation(s).
- Detailed or complex discussions of medical issues with the patient’s representative unless the patient has given informed consent for this to be done where appropriate.
Annual Review of Complaints
The practice will produce an annual complaints report to be sent to the local Commissioning Body (NHSE) and will form part of the Freedom of Information Act Publication Scheme.
The report will include:
- Statistics on the number of complaints received
- The number considered to have been upheld
- Known referrals to the Ombudsman
- A summary of the issues giving rise to the complaints
- Learning points that came out of the complaints and the changes to procedure, policies or care which have resulted
Care must be taken to ensure that the report does not inadvertently disclose any confidential data or lead to the identity of any person becoming known.
Confidentiality
All complaints must be treated in the strictest confidence and the practice must ensure that the patient etc. is made aware of any confidential information to be disclosed to a third party (e.g. NHSE).
The practice must keep a record of all complaints and copies of all correspondence relating to complaints, but such records must be kept separate from patients’ medical records and no reference which might disclose the fact a complaint has been made should be included on the computerised clinical record system.
Unreasonable or Vexatious Complaints
Where a complainant becomes unreasonable or excessively rude or aggressive in their promotion of the complaint, some or all of the following formal provisions will apply and must be communicated to the patient by the Responsible Person in writing:
- The complaint will be managed by one named individual at senior level who will be the only contact for the patient.
- Contact will be limited to one method only (e.g. in writing).
- Place a time limit on each contact.
- The number of contacts in a time period will be restricted.
- A witness will be present for all contacts.
- Repeated complaints about the same issue will be refused unless additional material is being brought forward.
- Only acknowledge correspondence regarding a closed matter, not respond to it.
- Set behaviour standards.
- Return irrelevant documentation.
- Detailed records will be kept of each encounter.
Complaints involving Locums
It is important that all complaints made to the practice regarding or involving a locum (Doctor, Nurse or any other temporary staff) are dealt with by the practice and not passed off to a Locum Agency or the individual locum to investigate and respond. The responsibility for handling and investigating all complaints rests with the Practice.
Locum staff should however be involved at an early stage and be advised of the complaint in order that they can provide any explanations, preferably in writing. It would not be usually appropriate for any opinions to be expressed by the Practice on Locum staff. Providing their factual account along with any factual account from the practice is the best way to proceed.
The practice will ensure that on engaging any Locum, the Locum Agreement will include an assurance that they will participate in any complaint investigation where they are involved or can provide any material evidence. The practice will ensure that there is no discrepancy in the way it investigates or handles complaints between any Locum staff and either practice Partners, salaried staff, students or trainees or any other employees.
“Informal complaints”
The collection of data about informal complaints – often referred to as “grumbles” – is a good tool for identifying trends for low-level dissatisfaction with services or the way they are offered to patients. Staff are encouraged to raise these issues at practice meetings and in addition a book will be kept in Reception for everyone to note when a negative comment or feedback is made to them by a patient. The book will be checked periodically (at least monthly) by the Complaints Manager to identify trends for discussion and possible amendment of procedures or targeted training needs.
References
Local Authority Social Services & National Health Service Complaints (England) Regulations 2009 – S.I. 209, No.309
NHS Complaints Procedure (England only): Guidance for Primary Care, BMA August 2015
Named GP
Under Department of Health rules from 1 April 2016 patients are assigned a named GP. Patients are not registered to this GP, they are registered to the Practice but this named GP is responsible for the coordination of your overall care.
It has always been the case that a patient can choose which GP they want to see, excepting that they will need to see someone else if their preferred GP is not available or if their need is urgent. Having a named GP does not alter this but your named GP can have queries forwarded to them along with test results and the management of any referrals you require.
Your named GP does not need to be available to you on demand and it is worth noting that most GPs in general Practice do not work 5 days a week.
We have assigned a named GP on a random basis. To find out who has been assigned to you please ask at reception.
Patients’ Rights and Responsibilities
Rights
Patients have a right to the following:
- To be treated with respect.
- To have confidentiality maintained at all times.
- To have complaints and minor grievances dealt with effectively.
- To request a chaperone.
- To make informed choices about treatment.
- To change surgery without giving a reason as quickly as possible.
- To have all personal documents returned as quickly as possible.
- To express a preference to receive services from a particular doctor or health care professional either generally or in relation to a particular condition.
Responsibilities
For the benefit of patients waiting to see the doctor:
- Please do not allow children to be disruptive in the surgery.
- If for any reason you are unable to keep your appointment please telephone the surgery as soon as possible so that the appointment can be released.
- We would request that patients do not smoke whilst in the building.
- For the comfort of others, please ensure that your mobile is switched off while you are in the surgery.
Privacy Policy
Introductory Privacy Notice
This practice keeps data on you relating to who you are, where you live, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care.
When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect Information.
GPs have always delegated tasks and responsibilities to others that work with them in their surgeries, on average an NHS GP has between 1,500 to 2,500 patients for whom he or she is accountable. It is not possible for the GP to provide hands on personal care for each and every one of those patients in those circumstances, for this reason GPs share your care with others, predominantly within the surgery but occasionally with outside organisations.
If your health needs require care from others elsewhere outside this practice, we will exchange with them whatever information about you that is necessary for them to provide that care. When you contact healthcare providers outside the practice but within the NHS it is usual for them to send us information relating to that encounter. We will retain part or all those reports. Normally we will receive equivalent reports of contacts you have with non-NHS services, but this is not always the case.
Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law.People who have access to your information will only normally have access to that which they need to fulfil their roles, for instance admin staff will normally only see your name, address, contact details, appointment history and registration details in order to book appointments, the practice nurses will normally have access to your immunisation, treatment, significant active and important past histories, your allergies and relevant recent contacts whilst the GP you see or speak to will normally have access to everything in your record.
You have the right to object to our sharing your data in these circumstances, but we have an overriding responsibility to do what is in your best interests. Please see below. We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.
1) Data Controller contact details | Dr Amir Naky – Senior GP Partner Willesborough Health Centre Bentley Road Ashford, Kent TN24 0HZ |
2) Data Protection Officer contact details | Dr James Wong – GP Partner Willesborough Health Centre Bentley Road Ashford, Kent TN24 0HZ |
3) Purpose of the processing | Direct Care is care delivered to the individual alone, most of which is provided in the surgery. After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the 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. |
4) 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:
We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality” * |
5) Recipient or categories of recipients of the processed data |
The data will be shared with Health and care professionals and support staff in this surgery and at hospitals, diagnostic and treatment centres who contribute to your personal care. For example:
The William Harvey Hospital |
6) 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 |
7) Right to access and correct |
You have the right to access 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 period | The data will be retained in line with the law and national guidance. |
9) Right to Complain | You have the right to complain to the Information Commissioner’s Office.
There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website). |
* “Common Law Duty of Confidentiality”, common law is not written out in one document like an Act of Parliament. It is a form of law based on previous court cases decided by judges; hence, it is also referred to as ‘judge-made’ or case law. The law is applied by reference to those previous cases, so common law is also said to be based on precedent.
The general position is that if information is given in circumstances where it is expected that a duty of confidence applies, that information cannot normally be disclosed without the information provider’s consent.
In practice, this means that all patient information, whether held on paper, computer, visually or audio recorded, or held in the memory of the professional, must not normally be disclosed without the consent of the patient. It is irrelevant how old the patient is or what the state of their mental health is; the duty still applies.
Three circumstances making disclosure of confidential information lawful are:
- where the individual to whom the information relates has consented;
- where disclosure is in the public interest; and
- where there is a legal duty to do so, for example a court order.
This privacy notice explains why Ashford Medical Partnership (AMP) collects information about you, how we keep it safe and confidential and how that information may be used. The first section provides a summary of these areas followed by a section that explains in more detail on why and how we process information in different ways.
The Practice is computerised and registered under the Data Protection Act. Personal information remains confidential to the NHS unless you have given prior written consent for disclosure. Patient records may be audited for quality & clinical compliance purposes.
We provide a confidential service to all our patients, including those under the age of 16. Everyone working for the NHS has a legal duty to maintain the highest level of confidentiality in regards to patient information. Anything you say to any member of our team will remain confidential and not be passed on to any other party – including other family members, parents or carers – without your permission.
To obtain a copy of our updated full Privacy Notice as well as our Covid-19 COPI Privacy notice for your information, please contact the practice.
Patient Privacy Notice
Ashford Medical Partnership has a legal duty to explain how to use any personal information we collect about you, as a registered patient, at the practice. Staff at this practice maintain records about your health and the treatment you receive in electronic and paper format.
How we use your personal information
- Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the GDPR Regulations.
- The following notice reminds you of your rights in respect of the above legislation and how your GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.
This notice reflects how we use information for
- The management of patient records;
- Communication concerning your clinical, social and supported care;
- Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
- Participation in health and social care research; and
- The management and clinical planning of services to ensure that appropriate care is in place.
Data Controller
As your registered GP practice, we (Ashford Medical Partnership) are the data controller for any personal data that we hold about you.
What information do we collect and use?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- The General Data Protection Regulations Legislation (GDPR)
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012
- NHS Codes of Confidentiality and Information Security
Personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to your care. ‘Personal data’ means any information relating to an identifiable person who can be directly or indirectly identified from the data.
This includes, but is not limited to:-
- name, date of birth, full postcode, address, next of kin and NHS Number; and ‘Special category / sensitive personal data’ includes such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation etc and any other relevant information to enable us to deliver effective medical care.
We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care
- Details about you, such as your address, legal representative, emergency contact details
- Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
- Notes and reports about your health
- Details about your treatment and care
- Results of investigations such as laboratory tests, x-rays etc
- Relevant information from other health professionals, relatives or those who care for you
- Your records will be retained in accordance with the NHS Code of Practice for Records Management
Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services). These records may be electronic, a paper record or a mixture of both. We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.
Why do we collect this information?
The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training.
To do this we will need to process your information in accordance with current data protection legislation to:
- Protect your vital interests;
- Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
- Perform tasks in the public’s interest;
- Deliver preventative medicine, medical diagnosis, medical research; and
- Manage the health and social care system and services
How do we use this information?
Your data is collected for the purpose of providing direct patient care; however, we can disclose this information if it is required by law, if you give consent or if it is justified in the public interest. The practice may be requested to support research; however, we will always gain your consent before sharing your information with medical research databases such as the Clinical Practice Research Datalink and QResearch or others when the law allows.
In order to comply with its legal obligations, this practice may send data to NHS Digital when directed by the Secretary of State for Health under the Health and Social Care Act 2012. Additionally, this practice contributes to national clinical audits and will send the data that is required by NHS Digital when the law allows. This may include demographic data, such as date of birth, and information about your health which is recorded in coded form; for example, the clinical code for diabetes or high blood pressure.
Processing your information in this way and obtaining your consent ensures that we comply with Articles 6(1)(c), 6(1)(e) and 9(2)(h) of the GDPR.
How is the information collected?
Your information will be collected either electronically using secure NHS Mail or a secure electronic transfer over an NHS encrypted network connection. In addition physical information will be sent to your practice. This information will be retained within our electronic patient record or within your physical medical records.
Who will we share your information with?
In order to deliver and coordinate your health and social care, we may share information with the following organisations:
- NHS Trusts / Foundation Trusts
- ICBs/ICSs
- Other GP’s
- NHS Commissioning Support Units
- Independent Contractors such as dentists, opticians, pharmacists
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Social Care Services
- NHS Digital
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police & Judicial Services
- Other ‘data processors’ which you will be informed of
Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.
Your information will not be transferred outside of the European Union.
Who do we receive information from?
Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.
In addition, we receive data from NHS Digital (as directed by the Department of Health) such as the uptake of flu vaccinations and disease prevalence in order to assist us to improve “out of hospital care”.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information that has been collected lawfully. We adhere to the General Data Protection Regulation (GDPR), the NHS Codes of Confidentiality and Security, as well as guidance issued by the Information Commissioner’s Office (ICO). Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.
Do I need to give my consent?
The GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation.
However, consent is only one potential lawful basis for processing information. Therefore, we may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice. We will contact you if they are required to share your information for any other purpose which is not mentioned within this notice. Your consent will be documented within your electronic patient record.
What will happen if I withhold my consent or raise an objection?
You have the right to write to withdraw your consent at any time for any particular instance of processing, provided consent is the legal basis for the processing. Please contact your us for further information and to raise your objection.
Health Risk Screening / Risk Stratification
Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health. Usually this includes patients with long term conditions, e.g. cancer. Your information is collected by a number of sources, including Ashford Medical Partnership, and by using selected information such as age, gender, NHS number, diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care. This information is processed electronically and given a risk score which is relayed to us so we can then decide on any necessary actions to ensure that you receive the most appropriate care.
To summarise Risk Stratification is used in the NHS to
- Help decide if a patient is at a greater risk of suffering from a particular condition;
- Prevent an emergency admission;
- Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
- Review and amend provision of current health and social care services
We may use computer based algorithms or calculations to identify our registered patients who are at most risk, with support from the local ICB and/or a third party accredited Risk Stratification provider.
We mayroutinely conduct the risk stratification process outside of your GP appointment. This process is conducted electronically and without human intervention. The resulting report is then reviewed by a multidisciplinary team of staff within the Practice. This may result in contact being made with you if alterations to the provision of your care are identified.
A Section 251 Agreement is where the Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers. You have the right to object to your information being used in this way. However, you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care. Please contact the Practice General Manager to discuss how disclosure of your personal data can be limited.
The National Data opt-out service is available from May 25th 2018. Patients can decide if they want to share their personally identifiable data to be used for planning and research purposes. Please see the information in the Practice for more details or refer to NHS Digital here.
Opt-outs
You have a right to object to your information being shared. Should you wish to opt out of data collection, please contact a member of staff who will be able to explain how you can opt out and prevent the sharing of your information; this is done by registering to opt out online (national data opt-out programme) or, if you are unable to do so or do not wish to do so online, by speaking to a member of staff.
Sharing of Electronic Patient Records within the NHS
- Electronic patient records are kept in most places where you receive healthcare. Our local electronic system, EMIS, enables your record to be shared with organisations involved in your direct care, such as:
- Other GP practices
- Community services such as district nurses, rehabilitation services, telehealth and out-of-hospital services.
- Child health services that undertake routine treatment or health screening
- Urgent care organisations, minor injury units or out-of-hours services
- Community hospitals
- Palliative care hospitals
- Care Homes
- Mental Health Trusts
- Hospitals
- Social Care organisations
- Pharmacies
In addition, NHS England have implemented the Summary Care Record which contains information about medication you are taking, allergies you suffer from and any bad reactions to medication that you have had in the past.
Your electronic health record contains lots of information about you. In most cases, particularly for patients with complex conditions and care arrangements, the shared record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health. Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so. The shared record means patients do not have to repeat their medical history at every care setting.
Your record will be automatically set up to be shared with the organisations listed above; however you have the right to ask us to disable this function or restrict access to specific elements of your record. This will mean that the information recorded by us will not be visible at any other care setting.
You can also reinstate your consent at any time by giving your permission to override your previous dissent.
Invoice Validation
Your information may be shared if you have received treatment to determine which Integrated Care Board (ICB) is responsible for paying for your treatment. This information may include your name, address and treatment date. These details are held in a secure environment and kept confidential. This information is only used to validate invoices in accordance with the current Section 251 Agreement, and will not be shared for any further commissioning purposes.
Retention Periods
In accordance with the NHS codes of Practice for Records Management, your healthcare records will be retained for 10 years after death or, if a patient emigrates, for 10 years after the date of emigration.
Change of Details
It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.
Your Right of Access to Your Records
The General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format. This is known as the “right of subject access”. If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information. This can be us, or another provider that is or has delivered your treatment and care. You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party.
If you would like to access the information Ashford Medical Partnership holds about you, please complete a Subject Access Request (SAR). Please ask at reception for a SAR form and you will be given further information. Furthermore, should you identify any inaccuracies; you have a right to have the inaccurate data corrected.
What To Do If You Have Any Questions
Should you have any questions about our privacy policy or the information we hold about you, you can:
- Contact the practice’s data controller via reception. GP practices are data controllers for the data they hold about their patients.
- Write to the data controller at Ashford Medical Practice, Willesborough Health Centre, Bentley Road, Ashford, TN24 0HZ .
- Contact the Surgery Here
- The GP Data Protection Officer (DPO) for Ashford Medical Partnership is based at Kent & Medway ICB
Complaints
In the event that you feel we have not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice
General Manager.
If you remain dissatisfied with our response you can contact the Information Commissioner’s Office here and select “Raising a concern” or call 01625 545700
Changes to Our Privacy Policy
We regularly review our privacy policy and any updates will be published on our website, in our newsletter and on posters to reflect the changes. This policy was last reviewed in November 2022 and is to be reviewed again in November 2023
The Subject Access Request Policy
The Subject Access Request Policy details how Ashford Medical Partnership will meet its legal obligations concerning individual’s access to their information. The requirements within the Policy are primarily based upon the DPA 1998 and EU GDPR 2018 as they are the key legislations covering rights to personal information.
This Subject Access Request Policy has been written to ensure that all staff of Ashford Medical Partnership are aware of their responsibilities to provide information if requested. This Policy also includes guidelines and information on how to request information of the deceased:
The current DPA 1998 and EU GDPR 2016 (hereinafter called the Data Protection Legislations) details rights of access to both manual data (which is recorded in a filing system) and computer data for the individual/data subject.
This right, commonly referred to as Subject Access Request (SAR) is created under section 7 of DPA 1998 and Article 15 of GDPR 2016, gives rights to a data subject/individual to request personal information Ashford Medical Partnershipholds about them. Anyone with full mental capacity can authorise a representative/third party, for example solicitors/advocates to help them make a SAR.
Under the DPA and GDPR Legislations data subjects have the right to obtain from Ashford Medical Partnershipconfirmation as to whether or not personal data concerning the individual/data subject are being processed, and, where that is the case, access to the personal data and the following information:
- a) the purposes of the processing;
- b) the categories of personal data concerned;
- c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- e) the existence of the right to request from the controller rectification or erasure (where necessary) of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- f) the right to lodge a complaint with a supervisory authority (Information Commission’s Office);
- g) where the personal data are not collected from the data subject, any available information as to their source;
- h) the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject;
- i) right to be informed about the appropriate safeguards where personal data is transferred to a third country or international organisation;
- j) right to request a copy of any personal data undergoing processing.
In line with the Information Commissioner’s subject access Codes of Practice, organisations are encouraged to have SAR Policy or Procedure in place to ensure that individuals’ rights of access are met within a timely and appropriate manner, and seek to enable all who wish to do so to have access to the records that are held about them.
Aim
This Subject Access Request Policy details how Ashford Medical Partnershipwill meet its legal obligations concerning individual’s access to their information. The requirements within the Policy are primarily based upon the DPA 1998 and EU GDPR 2016 as they are the key legislations covering rights to personal information.
This Subject Access Request Policy has been written to ensure that all staff of Ashford Medical Partnershipare aware of their responsibilities to provide information if requested.
Patients will also be given a patient information leaflet on Subject Access Requests available at reception.
Legislations and Code of Practice
For the purpose of this Policy, other relevant legislations and appropriate guidance may be referenced. The legislations listed below refer to issues of security and/or confidentiality of personal data:
- Freedom of Information Act 2000
- Regulation of Investigatory Powers Act 2000
- Crime and Disorder Act 1998
- Computer Misuse Act 1990
- Criminal Justice and Immigration Act 2008
- Information Commissioner’s Office: Subject Access Request Code of Practice
Roles and Responsibilities
Accountable Officer
The Data Protection Officer (DPO) Lois Cavallaro has overall accountability and responsibility for subject access requests. The DPO has delegated SAR operational responsibilities to the Senior Receptionist (Tracey Parsons).
Data Protection Officer
The Data Protection Officer (DPO) has day-to-day responsibilities for the management of all aspects relating to data protection matters. The responsibilities of the DPO include:
- To advise all staff on issues relating to data protection by providing guidance and templates;
- Monitor organisational compliance with the Data Protection Legislations including policies and procedures that underpins the protection of personal data within the organisation.
- To provide awareness-raising and training for staff involved in processing operations
- Liaise with the Information Commissioner’s Officer (ICO) on matters around confidentiality and data protection, information security and records management;
- To provide advice where requested as regards to Data Protection Impact Assessment (DPIA) and monitor the risk management process;
- To consult with the ICO prior to data processing where a DPIA indicates that the processing would result in a high risk in the absence of measures taken by the organisation to mitigate the risk.
The DPO shall in the performance of his functions have due regard to the risk associated with processing operations, taking into account the nature, scope, context and purposes of processing.
All Managers and Staff
The Management will ensure that all members of staff are aware of, and adhere to this SAR Policy. They are also responsible for ensuring that the staffs are updated with regards to any changes in the Policy.
All staff has a responsibility to ensure that they comply with the statutory obligations under the Data Protection Legislations, and any guidance lay down to ensure compliance.
Particularly, staff should ensure that:
- They are aware of their responsibility to support SARs and where in the organisation such requests are ultimately handled;
- Personal data and records (whether in electronic or manual) relating to patients/serviceusers and staff are kept secure, accurate, relevant and up to date.
Staff wishing to access personal confidential information that Ashford Medical Partnership holds about them should submit their requests in writing.
Ashford Medical Partnership as a Data Controller
Ashford Medical Partnerships a data controller in respect of any personal data and special categories of personal within its remit and as part of its statutory functions, Ashford Medical Partnership determine the purposes for which, and the manner in which those personal information are, or are to be, processed.
Request Process
Patients can make a subject access request in writing or face to face at reception. Patients will also be given a patient information leaflet on Subject Access Requests available at reception or on the practice website.
If a request is made verbally within a GP/nurse/HCA consultation, then the healthcare professional can, if appropriate and possible within the consultation, provide the requested information immediately as an electronic print off from the computer system. However it is expected that most requests will be formal SAR via reception and outside clinical contacts.
Requirements for a valid subject access request
Adequate steps must be taken to identify the identity of the requester. Each applicant/data subject must be asked to supply one of the following copies of their identification:
- Driving licence
- Passport
- Birth certificate
Notification of Requests
Ashford Medical Partnership will keep a central register of all requests in order to ensure that requests are cross-referenced with any complaints or incidents and that the deadlines for response are monitored and adhered to.
Providing personal information under subject access request
SAR provides a right for the data subject/applicant to see their own personal data, rather than a right to see copies of documents that contain their personal data. Often, the easiest way to provide the relevant information is to supply copies of original documents, where it is reasonable to do so.
Information must be supplied to the data subject/applicant in an intelligible, easy to understand form, unless to do so would involve ‘disproportionate’ effort. For manual records this would involve photocopies. For computerised records these can be supplied as a printout but must contain explanations of codes or abbreviations where appropriate. If the ‘disproportionate’ effort issue arises, the records can be shared with the individual on a face to face basis who can be asked to visit the premises to view their records.
It is expected that in the majority of cases copies of the relevant record will be give to the patient face to face at reception. It may be possible to post the information to the patient.
If sent by post:
- the record should be sent to a named individual
- by recorded delivery
- marked “private and confidential”
- “for addressee only” and the Practice details should be written on the reverse of the envelope.
- Use of fax, email and data storage devices is not routinely used.
Types of personal information that can be disclosed
Any information that constitutes personal data or special categories of personal data of the subject/applicant should be provided (subject to any data protection exemptions or information that may cause harm or distress).
Under the Data Protection Legislations the term “personal data” 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; they include:
- Demographics – name; address; postcode; telephone number; date of birth;
- an identification number – NHS number, National Insurance Number, location data, an online identifier and Driving licence number [Note that driving licence number is included in this list because it directly yields date of birth and first part of surname]
Special categories of personal data include:
- Health records or data concerning a natural person’s sex life or sexual orientation
- Genetic data
- Biometrics, DNA Profile, Fingerprints
- Child Protection Records
- Adoption Records
- Tax, Benefit or Pension Records
- Racial or ethnic origin;
- Social Services Records
- Housing Records
- Political opinions;
- Religious or philosophical beliefs
Timescales for responding to subject access requests
Under the EU GDPR Ashford Medical Partnership is required to respond to subject access requests without undue delay and in any event within one calendar month of receipt of the request from the data subject. The period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
In the case of further extension, the DPO or nominated deputy will inform the data subject of any such extension within one calendar month of receipt of the request, together with the reasons for the delay. Failure to do so is a breach of the Legislation and could lead to a complaint being made to the ICO.
To assist the obligation to provide information within the time limits, Ashford Medical Partnership will ensure that all staff is aware of the SAR process, and requirements to provide the information when requested by the DPO.
To obtain a copy of our full Subject Access Request policy, please contact the practice.
Patient Data Opt Out Policy
This Policy and patient information leaflet describes the practice’s approach on Patients opting out of data sharing for direct care and secondary uses:
In most cases the GP practice will only share data with other health and social care providers for direct care purposes with implied or explicit consent. However the NHS has systems in place for sharing of data for direct care and other so called secondary uses that go beyond direct patient care. These systems have been designed as “optout systems”. That is all NHS patients in England are opted into these national and local schemes but then patients have to opt out if they do not want their data to be used in this way. The onus is on the practice to highlight such data sharing. We do this through our Privacy Notice and information on our billboards and website. The following sections describe our approach to data opt-outs and the information we give our patients on this issue.
Data Sharing for Direct care
We share patients personal information on national (summary care record) and local (connect care) data sharing platforms to create care records that would allow healthcare professionals to see information on our patient’s medical history if needed in direct care clinical situations with the consent of the patient when possible. Even though these are direct care purposes, patients are able to opt out of such sharing.
Data Sharing for Secondary Uses
Data is also shared with national organisations and data processors based on national guidelines and law. This is for purposes that go beyond direct medical care that GP surgeries and other healthcare organisations provide patients.
Secondary purposes include healthcare planning, audit, population analytics, research, and commissioning at a local, regional or national level. Often this will include patient identifiable data but sometimes may be anonymised aggregate data. Patients are able to opt out of secondary uses of their information.
Summary care Records
The Summary Care Record (SCR) is an electronic record of important patient information, created from GP medical records. It can be seen and used by authorised staff in other areas of the health and care system involved in the patient’s direct care. This would normally be in a urgent or emergency clinical situation. Unlike connect care records which can only be viewed by health and social care professionals in South East London, this is a national care record, and can be accessed across England if the situation arose. Certain parts of patient medical records will be shared within the NHS to provide effective care to patients outside their GP practice. This will enable health care professionals to have quicker access to information about any medicines or allergies/bad reactions a patient may have had. The summary care record will contain Name, Date of Birth, NHS number, repeat medications and allergies. Information can only be accessed by an NHS professional that holds an NHS smart card with a chip and passcode. People accessing information can only see parts that are relevant to their job. Health care staff will ask for a patient’s permission every time they need to look at the summary care record. If the patient is unable to be asked, i.e. they are unconscious, the health care professional may look into the record if it is for the good of the patient but a note will be places in the medical records to show this. The SCR is run by NHS Digital. NHS Digital is the secure haven for NHS patient data, a single secure repository where data collected from all branches of the NHS is processed. NHS Digital provides reports on the performance of the NHS, statistical information, audits and patient outcomes as well as patient level clinical IT platforms.
For more information about summary care records, visit NHS England – Summary Care Records.
To obtain a copy of our full Opt-out policy, please contact the practice.
Children and Vulnerable Adults
We have a professional, legal and moral obligation to report suspicions of neglect or abuse of children or vulnerable adults to the relevant authorities. We will do all we can to involve parents and carers in this process but there may be times when this proves impractical.
Summary Care Record
Certain parts of patient medical records will be shared within the NHS to provide effective care to patients outside their GP practice. This will enable health care professionals to have quicker access to information about any medicines or allergies/bad reactions a patient may have had. The summary care record will contain Name, Date of Birth, NHS number, repeat medications, this information can only be accessed by an NHS professional that holds an NHS smart card that is password protected.
Personnel accessing information can only see parts that are relevant to their job. Health care staff will ask for a patient’s permission every time they need to look at the summary care record.
If the patient is unable to be asked, i.e. they are unconscious, the health care professional may look into the record if it is for the good of the patient but a note will be placed in the medical records to show this.
If you wish to opt opt out please visit the NHS website.
For more information please visit Summary Care record.
Healthy.io
ACR project for patients with diabetes
The data is being processed for the purpose of delivery of a programme, sponsored by NHS Digital, to monitor urine for indications of chronic kidney disease (CKD) which is recommended to be undertaken annually for patients at risk of chronic kidney disease e.g., patients living with diabetes.
The programme enables patients to test their kidney function from home. We will share your contact details with Healthy.io to enable them to contact you and confirm that you wish them to send you a test kit. This will help identify patients at risk of kidney disease and help us agree any early interventions that can be put in place for the benefit of your care.
Healthy.io will only use your data for the purposes of delivering their service to you. If you do not wish to receive a home test kit from Healthy.io we will continue to manage your care within the Practice. Healthy.io are required to hold data we send them in line with retention periods outlined in the Records Management code of Practice for Health and Social Care.
Same Day Access
Privacy notice excerpt as member of the Ashford and Faversham group delivering same day access hub (SDAH) to support the winter pressures
Same Day Access Hub (SDAH) – to support the winter pressures and increase capacity within primary care enabling more face to face appointments to be made available to meet demand.
Same Day Access Hub (SDAH) – the purpose of SDAH is to support the winter pressures and increase capacity within primary care enabling more face to face appointments to be made available to meet demand. The source of the information shared in this way is your electronic GP record that is accessed at a central or hub level. A constituent GP practice completes a cross organisational appointment booking from their clinical system within which the patient is registered to the central Clinical Service appointment book. Although this central clinical system will not hold patients’ healthcare information, it will contain the appointment booking itself which will include the patient’s full name, date of birth, age, NHS number and the reason for the appointment booking.
Data Retention Period
All records held by the Practice will be kept for the duration specified in the Records Management Codes of Practice for Health and Social Care. Any data (booking information) held by the hub will also be retained 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 UK 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 UK 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, (2) -health or social care purposes means the purposes of preventive or occupational medicine; medical diagnosis; the provision of health care or treatment; the provision of social care, or the management of health care systems or services or social care systems or services.
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:
ü accuracy of the data is contested,
ü the processing is unlawful or,
ü where we no longer need the data for the purposes of the processing.
Right to object:
In line with the UK 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 your GP Practice process your data, please contact your GP practice directly in the first instance via the ‘Contact Us’ section on our website.
Related Legislations:
Section 251B Health and Social Care (Safety and Quality Act) 2015 (Duty to Share);
You can also contact the Ashford GP Federation via [email protected] for strictly Federation related enquiries.
You also have the right to appeal/complain to the Information Commissioner’s Office (IC0). The IC0 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/
Zero Tolerance
In the unlikely event that a patient becomes abusive or violent, the patient may be asked to leave the surgery and the police will be informed.
In particularly serious cases the doctor will consider removing the patient from the list.