Practice Policies & Patient Information
Complaints Policy
We care about your views.
The practice has a formal complaints procedure and we always welcome the opportunity to deal with any part of the service which is causing you concern. Please contact our Practice Manager, Mrs Jasmine Burton to submit your complaint via telephone, in person or in writing. Note that all complaints are logged and dealt with, with the same level of diligence, whether made verbally or in writing.
Timescales
You should raise a complaint as soon as possible following the event, and at most 12 months after the occurrence or 12 months from the time you become aware of the issue.
You have a right to be regularly updated regarding the progress of your complaint. If you do make a written complaint, Jacksdale Medical Centre will aim to provide:
· An initial response to acknowledge receipt of your complaint within three working days
· Regular updates during the investigation
· Resolution of the complaint within 40 days
Confidentiality
Any complaint is investigated with the utmost confidence and all associated documentation is held separately from your medical records.
Note that if you are making a complaint on behalf of someone else, we will require their express consent to disclose any medical information, before we can provide a response.
Other Avenues
If we are unable to resolve the problem, you may wish to take your complaint further. If this is the case then please contact:
Patient Advisory and Liaison Service (PALS) as the next stage of the NHS complaints process. The nearest PALS is based at Ripley Resource Centre, DE5 3JE and number 01332 623700.
or
Nottingham and Nottinghamshire Intergrated Care Board
via Telephone: 0115 8839570
By post: Patient Experience Team, Civic Centre, Arnot Hill Park, Nottingham Road, Arnold, Nottingham, NG5 6LU;
By Email: [email protected]
Summary
The care and treatment delivered by Jacksdale Medical Centre is done so with due diligence and according to current guidelines. However, we acknowledge that sometimes things can go wrong. By having an effective complaints process in place, our practice is able to investigate and resolve complaints in a timely manner, achieving the desired outcome for our patients, whilst also identifying lessons learnt and ultimately improving the service we provide.
GDPR Policy
A. Confidentiality Notice
This document and the information contained therein is the property of Jacksdale Medical Centre.
This document contains information that is privileged, confidential and otherwise protected from disclosure. It must not be used by, or its contents reproduced or otherwise copied or disclosed without prior consent from Jacksdale Medical Centre.
B. Document details
Classification: Practice Administration/GDPR
Author and Role: Mel Lindley – Practice Manager
Organisation: Jacksdale Medical Centre
Current Version: 1.0
Current Document approved by: Dr Karen Brown Date Approved: 9th May 2018
C. Document Revision and Approval History
Version: 1.0
Date: 9.5.18
Version created by: Mel Lindley
Version Approved by Dr Karen Brown
Comments: New document
1
1 S: Protocols/GDPR/Privacy Notes for patients – Version 1
PRACTICE PRIVACY NOTICE FOR PATIENTS
What is a Privacy Notice?
A Privacy Notice (or “Fair Processing Notice”) is an explanation of what information the practice collects on patients and how it is used. Being transparent and providing clear information to patients about how the practice uses their personal data is an essential requirement of the Data Protection Act 1998.
Under the DPA, the first principle is to process personal data in a fair and lawful manner, and applies to everything that is done with patient’s personal information. In practice, this means that the Practice must:
- Have legitimate reasons for the use or collection of personal data
- Not use data in a way that may cause adverse effects on the individuals (e.g. improper sharing of their information with 3rd parties)
- Be transparent about how your data will be used and give appropriate privacy notices when collecting their personal data
- Handle personal data only as reasonably expected to do so
- Make no unlawful use of the collected data
- Fair Processing
Personal data must be processed in a fair manner – the DPA says that information should be treated as being obtained fairly if it is provided by a person who is legally authorised or required to provide it. Fair Processing means that the Practice has to be clear and open with people about how their information is used.
Providing a ‘Privacy Notice’ is a way of stating the Practice’s commitment to being transparent and is part of fair processing, however you also need to consider the effects of processing on the individuals and patients concerned: - What information are we collecting?
- Who collects the data
- How it is collected?
- Why do we collect it?
- How will we use that data?
- Who will we share it with?
- What is the effect on the individuals?
- If we use it as intended, will it cause individuals to object or complain?Conducting a Privacy Impact Assessment is an effective way of assessing whether you can safely collect or use patient data according to the DPA and Information Governance requirements. The Information Commissioners office has published guidance on carrying out a PIA and can be found here:
https://ico.org.uk/for-organisations/guide-to-data-protection/ico-codes-of-practice/data-sharing-a-code-of-practice/
Data Controllers
Under the Data Protection Act, the data controller is the person or organisation that will decide the purpose and the manner in which any personal data will be processed – they have overall control of the data they collect, and decide how and why it will be processed.
A GP Practice is a data controller for the patient information it collects and should already have data processing arrangements with third parties (e.g. IT systems, providers) to ensure they do not user or access data unlawfully; the data controllers will have ultimate responsibility for the Practices compliance with the DPA.
Risk Stratification
This is a process to identify and manage patients that are more likely to need secondary care – information is collected in order to assess their “Risk Score” and is sent to NHS organisations to assess and return the results to the GP Practice. This is an acceptable way of assessing patients’ needs and prevents ill health, however it is also regarded as a disclosure of personal information and patients have the option to opt out of any data collection at the Practice, and needs to be made clear to them.
Invoice Validations
If a patient has had NHS treatment, their personal information may be shared within a secure and confidential environment to determine which CCG should pay for the treatment received. This means sharing identifiable information such as names, address, date of treatment etc. to enable the billing process.
Partner Organisations
If the practice shares information with any external organisations (within or outside the NHS) then let patients know by listing them. Partner organisations will usually include NHS organisations such as hospitals, CCG’s, NHS England’s etc.) other public sectors (Education, Police, Fire etc.) and any other Data Processors that may be carrying out specific project work with the Practice (e.g. Diabetes UK)
Access to Personal Information
The DPA gives patients the right to view any information held about them – the ‘Right of Subject Access’. Explain the process and who to contact, you can find your practice registration number by entering your Practice name in the ‘Name’ box here:
https://ico.org.uk/ESDWebPages/Search
PRACTICE PRIVACY NOTICE
How we use your information
This privacy notice explains why we as a Practice collect information about our patients and how we use that information.
Jacksdale Medical Centre manages patient information in accordance with existing laws and with guidance from organisations that govern the provision of healthcare in England such as the Department of Health and the General Medical Council.
We are committed to protecting your privacy and will only use information collected lawfully in accordance with:
- Data Protection Act 1998
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 20132
- NHS Codes of Confidentiality and Information SecurityAs data controllers, GP’s have fair processing responsibilities under the Data Protection Act 1998. In practice this means ensuring that your personal confidential data (PCD) is handled clearly and transparently and in a reasonably expected way.
The Health and Social Care Act 2012 changed the way that personal confidential data is processed, therefore it is important that our patients are aware of and understand these changes, and that you have an opportunity to object and know how to do so.
The health care professionals who provide you with care, maintain records about your health and any NHS treatment or care you have received (e.g. NHSA Hospital Trust, GP Practice, Walk in Centres etc) These records help to provide you with the best possible healthcare.
NHS health records may be processed electronically, on paper or a mixture of both; a combination of working practices and technology are used to ensure that your information is kept confidential and secure. Records held by this GP practice may include the following information: - Details about you, such as address and next of kin
- Any contact the practice has had with you, including appointments (emergency or scheduled) clinic visits etc.
- Notes and reports about your health
- Details about treatment and care received
- Results of investigations such as laboratory tests, x-rays etc.
- Relevant information from other health professionals, relatives or those who care for you
The practice collects and holds data for the sole purpose of providing healthcare services to our patients and we will ensure that the information is kept confidential. However, we can disclose personal information if:
- It is required by law
- You provide consent – either implicitly or for the sake of their own care, or explicitly for other purposes
- It is justified to be in the public interestSome of this information will be held centrally and used for statistical purposes. Where we hold data centrally, we take strict and secure measures to ensure that individual patients cannot be identified.
Information may be used for clinical audit purposes to monitor the quality of service provided, and may be held centrally and used for statistical purposes. Where we do this we ensure that patient records cannot be identified.
Sometimes your information may be requested to be used for clinical research purposes – the practice will always endeavour to gain your consent before releasing the information.
Improvements in information technology are also making it possible for us to share data with other healthcare providers with the objective of providing you with better care.
Patients can choose to withdraw their consent to their data being used in this way. When the practice is about to participate in any new data-sharing scheme we will make patients aware by displaying prominent notices in the surgery and on our website at least four weeks bore the scheme is due to start. We will also explain clearly what you have to do to ‘opt out’ of each new scheme.
A patient can object to their personal information being shared with the other health care providers but if this limits the treatment that you can receive then the doctor will explain this to you at that time. - Mobile Telephone
If you provide us with your mobile telephone number we may use this to send you reminders about any appointments or other health screening information being carried out - Practice Website
Our website does not use cookies to track your activity online.
Risk Stratification
Risk stratification is a process for identifying and managing patients who are at high risk of requiring emergency or urgent care. Typically this is because patients have a long term condition such as COPD, Cancer or other medical conditions at risk of sudden worsening. NHS England (the national Commissioning Board) encourages GP’s to use risk stratificationtools as part of their local strategies for supporting patients with long-term conditions and to provide care plans and planned care with the aim to prevent avoidable admissions or other emergency care.
Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information using software provided by eHealthScope as the data processor and is provided back in an identifiable format to your GP or member of your care team as data controller.
Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary your GP may be able to offer you additional services.
Please note that you have the right to ‘opt out’ of Risk Stratification
Should you have any concerns about how your information is managed, or wish to opt out of any data collections at the practice, please contact the practice or your healthcare professional to discuss how the disclosure of your personal information can be limited.
Patients have the right to change their minds and reverse a previous decision. Please contact the practice if you change your mind regarding any previous choices.
Invoice Validation
If you have received treatment within the NHS your personal information may be shared within a strictly monitored, secure and confidential environment in order to determine which Clinical Commissioning Group should pay for the treatment or procedure you have received.
Information such as your name, address and date of treatment may be passed on to enable the billing process – these details are held in a secure environment and kept confidential. This information will only be used to validate invoices and will not be shared for any further commissioning purposes.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with the Data Protection Act 1998 (which is overseen by the Information Commissioner’s Office)Human Rights Act, the Common Law Duty of Confidentiality and the NHS Codes of Confidentiality and Security. Every staff member who works for an NHS organisation has a legal obligation to maintain the confidentiality of patient information.
All of our staff, contractors and committee members receive appropriate and regular training to ensure they are aware of their personal responsibilities and have legal and contractual obligations to uphold confidentiality, enforceable through disciplinary procedures. Only a limited number of authorised staff has access to personal information where it is appropriate to their role and is strictly on a need-to-know basis.
We maintain our confidentiality to you at all times. We will only ever use or pass on information about you if other involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations) or where the law requires information to be passed on.
Who are our partner organisations?
We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:
- NHS Trusts
- pecial Trusts
- Independent Contractors such as dentists, opticians, pharmacists
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police
- Other ‘data processors’ Access to personal information
You have the right under the Data Protection Act 1998 to access/view information the practice holds about you and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject access’ If we do hold information about you we will
Give you a description of it
Tell you why we are holding it
Tell you who it could be disclosed to
Let you have a copy of the information in an intelligible form
If you would like to make a ‘subject access request’ please contact the Practice Manager in writing. There may be a charge for this service. Any changes to this notice will be published on our website in in reception
The practice is registered as a Data Controller under the Data Protection Act 1998. The registration number is ZA193559 and can be viewed online in the public register at http://www.ico.gov.uk
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 changed so our records are accurate and up to date for you.
Notification
The Data Protection Act 1998 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information. This information is publicly available on the Information Commissioners Office website www.ico.org.uk The practice is registered with the Information Commissioner’s Office (ICO)
Who is the Data Controller?
The Data Controller responsible for keeping your information secure and confidential is Dr Karen Brown. Any changes to this notice will be published on our website and displayed in prominent notices in the surgery.
The Practice is registered as a Data Controller under the Data Protection Act 1998. Registered number : ZA193559
Further Information
Further information about the way in which the NHS uses personal information and your rights in that respect can be found in
- The NHS Constitution: https://www.gov.uk/government/publications/the-nhs- constitution-for-england
- NHS Digital’s Guide to Confidentiality in Health and Social Care give more information on the rules around information sharing http://content.digital.nhs.uk/article/4979/Assuring-informationAn independent review of information about patients is shared across the health and care system led by Dame Fiona Caldicott was conducted in 2012. The report Information: To share or not to share? The Information Governance Review can be found at https://www.gov.uk/government/publications/the-information-governance-review
NHS England – Better Data, Informed Commissioning, Driving Improved Outcomes – Clinical Data Sets provides further information about the data flowing within the NHS to support commissioning
Please visit the NHS Digital Website for further information about their work. Information about their responsibility for collecting data from across the health and social care system can be found
GP Earnings
The average pay for GPs working in Jacksdale Medical Centre in the last financial year was £61,882 before tax and national insurance. This is for 1 part time GP and 2 locums who worked in the practice for more than six months.
The cost of Locum doctors are very expensive and therefore the actual practice profit is lower than this.
Missed Appointments Policy
Patients who do not attend for appointments are monitored closely. Patients who fail to attend on 3 occasions will be called into the practice to discuss their non-attendance. Practice Policy states that patients can then be removed from the practice list.
Our Mission Statement
We aim to treat all our patients equally and to give you a high standard of service that is sensitive to your needs. We also need your help to do this. Please help us to help you.
Zero Tolerance and Social Media
The Practice takes it very seriously if a member of staff is treated in an abusive or violent way, in person or on social media. Derogatory comments regarding the practice or practice staff on social media is not acceptable and can result in you being removed from the practice list.
The Practice supports the government’s ‘Zero Tolerance’ campaign for Health Service Staff. This states that GPs and their staff have a right to care for others without fear of being attacked or abused. This abuse can be either physically or verbally. To successfully provide these services a mutual respect between all the staff and patients has to be in place.
Our Practice staff aim to be polite, helpful, and sensitive to all patients’ individual needs and circumstances. They would respectfully remind patients that very often staff could be confronted with a multitude of varying and sometimes difficult tasks and situations, all at the same time. The staff understand that ill patients do not always act in a reasonable manner and will take this into consideration when trying to deal with a misunderstanding or complaint.
However, aggressive behaviour, be it violent or abusive, will not be tolerated and may result in you being removed from the Practice list and, in extreme cases, the Police being contacted.
In order for the practice to maintain good relations with their patients the practice would like to ask all its patients to read and take note of the occasional types of behaviour that would be found unacceptable:
- Using bad language or swearing at practice staff either verbally or online
- Any physical violence towards any member of the Primary Health Care Team orother patients, such as pushing or shoving
- Verbal abuse towards the staff in any form including verbally insulting the staff either in person, via telephone or online – social media.
- Racial abuse and sexual harassment will not be tolerated within this practice
- Persistent or unrealistic demands that cause stress to staff will not be accepted.Requests will be met wherever possible and explanations given when they cannot
- Causing damage/stealing from the Practice’s premises, staff or patients
- Obtaining drugs and/or medical services fraudulently
- We ask you to treat your GPs and their staff courteously at all times.
The Legal Position
As a responsible employer, the Practice has a duty as a provider of NHS healthcare to protect the health, safety and welfare of staff under the Health & Safety at Work Act. This includes a risk assessment of violence towards staff and taking steps to mitigate this under the Management of Health and Safety at Work Regulations 1999.
Staff members who are victims of violent conduct or assault have the right to sue their employers for compensation if the risk of violence could have been reduced or removed completely, but the employers did not act upon this information.
Examples of security issues:
- Security of grounds and car parking
- Security of premises – incl. storage, “out of hours”
- CCTV
- Cash and staff – storing, handling and transferring
- Security Systems
- Security of equipment – medical devices, computers
- Communication of national security alerts
- Information records
- Contingency planning.
- Security of employees
- Staff working on their own
- (Staff can be lone workers when making domiciliary visits or within a hospital department e.g. out of hours) This list is not exhaustive.For example a lone working risk assessment must provide the lone worker full knowledge of the hazards and risks to which he or she is being exposed and what they must need to do will something go wrong. Other responsible persons must know the whereabouts of lone workers and what they are doing;
Violence at Work
The practice acknowledges that there may be instances where violence and / or aggression forms part of a patient’s illness. In these circumstances, the issue will be discussed with the patient and form part of their care planning.
This information will be recorded in the patient’s medical record and flagged to ensure that members of staff are aware. In addition, where deemed necessary, appropriate support will be put in place, e.g. staff members do not see the patient alone.
Definition of Physical and Verbal Abuse and Violence:
Physical and verbal abuse includes:
- Unreasonable and / or offensive remarks or behaviour / rude gestures / innuendoes
- Sexual and racial harassment
- Threatening behaviour (with or without a weapon)
- Actual physical assault (whether or not it results in actual injury) includes beingpushed or shoved as well as being hit, punched or attacked with a weapon, or beingintentionally struck with bodily fluids or excrement.
- Attacks on partners, members of staff or the public
- Discrimination of any kind
- Damage to an employee’s or employer’s property
- Derogatory personal comments against individuals either face to face, via telephoneor online (social media or emails)The Practice supports the Zero Tolerance stance adopted by the NHS.The HSE (Health and Safety Executive) defines work-related violence as:
“Any incident, in which a person is abused, threatened or assaulted in circumstances relating to their work”.
Violence and aggression towards a person may also be defined as:
“A physical contact with another person which may or may not result in pain or injury. The contact is uninvited and is an attempt to cause harm, injury or to intimidate. Non-physical aggression includes the use of language which causes offence or threatens the safety of a member of staff”.
Under the Health and Safety at Work Act 1974, the practice will also undertake the following measures to ensure a safe work environment:
- Carry our risk assessments to assess and review the duties of employees, identifying any “at risk” situations and taking appropriate steps to reduce or remove the risk to employees, particularly if they are working alone.
- Assess and review the layout of the premises to reduce the risk to employees where physically possible.
- Assess and review the provision of personal safety equipment, such as alarms.
- Develop surgery policies, procedures and guidelines for dealing with physical and verbalabuse.
- Provide support and counselling for victims, or refer to suitably qualified healthprofessionals.
- Make employees aware of risks and ensure employee involvement in suitable trainingcourses.
• Record any incidents on a Significant Event form and take any remedial action to ensure similar incidents are prevented in future.
REMOVAL FROM THE PRACTICE LIST
The removal of patients from our list is an exceptional and rare event and is a last resort in an impaired patient-practice relationship. We value and respect good patient-doctor relationships based on mutual respect and trust. When trust has irretrievably broken down, the practice will consider all factors before removing a patient from their list, andcommunicate to them that it is in the patient’s best interest that they should find a new practice. An exception to this is in the case of immediate removal on the grounds of violence e.g. when the Police are involved.
Removing other members of the household
Because of the possible need to visit patients at home, it may be necessary to terminate responsibility for other members of the family or the entire household to ensure the safety of practice staff.
The prospect of visiting patients that is the residence of a relative who is no longer a patient of the practice, or the risk of being regularly confronted by the removed patient, may make it difficult for the practice to continue to look after the whole family. This is more likely where the removed patient has been violent or displayed threatening behaviour, and keeping the other family members could put doctors or their staff at risk.