As part of the University Medical Centre we abide by strict GDPR principles. This service keeps data on you relating to who you are, where you live, possibly your family, your problems and any previous diagnosis that you make us aware of.
We will have data for the reasons you seek help, your appointments, where you are seen and when you are seen, and who by, referrals to specialists and other healthcare providers, treatments provided and outcomes of treatments, any history of previous episodes within our service, as well as notes made by professionals within our service who are appropriately involved in your treatment of care.
We would like to assure you that the content of your therapy sessions will be handled confidentially in line with NHS standards for information handling and that all notes are stored securely. Any statistical data acquired from our routine outcome measures is anonymised to protect your confidentiality. However, your therapist has a duty of care for your personal safety and the safety of others and this may require them to discuss your details with other professionals or agencies.
If your health needs require care from others elsewhere outside of this service, we will exchange whatever information about you that is necessary for them to provide that care.
When you make contact with healthcare providers outside our service but within the NHS it is usual for them to send us information relating to that encounter.
Your consent to this sharing of data, within the service and with other providers outside our service 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 administration staff will normally take your name, address, contact details and GP Practice information to refer you into the service. Further information will then be gathered in your first assessment appointment.
You have the right to object to 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 following 9 subsections.
|1) Data Controller contact details
|University Medical Centre,
Kent, CT2 7PB
|2) Data Protection Officer contact details
|Dr Michael Norman
University Medical Centre,
Kent, CT2 7PB
|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:
– Article 6(1)(e) ‘…necessary for the
performance of a task carried out in
the public interest or in the exercise of
– Article 9(2)(h) ‘necessary for the
purposes of preventative or
occupational medicine for the
assessment of the working capacity of
the employee, medical diagnosis, the
provision of health or social care or
treatment or the management of
health or social care systems and
We will also recognize 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.
[if possible list actual named sites
such as local hospital)(s) name]
|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
|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.
or speak to the practice.
|9) Right to Complain
|You have the right to complain to the
Information Commissioner’s Office,
you can use this link
or calling their helpline
Tel: 0303 123 1113 (local rate)
or 01625 545 745 (national rate)
There are National Offices for
Scotland, Northern Ireland and Wales,
(see ICO website)
* “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.
T: 01227 469 338
E: [email protected]