Privacy Notice for IGPR 

We use a processor, iGPR Technologies Limited (“iGPR”), to assist us with responding to report requests relating to your patient data, such as subject access requests that you submit to us (or that someone acting on your behalf submits to us) and report requests that insurers submit to us under the Access to Medical Records Act 1988 in relation to a life insurance policy that you hold or that you are applying for.

iGPR manages the reporting process for us by reviewing and responding to requests in accordance with our instructions and all applicable laws, including UK data protection laws.

The instructions we issue to iGPR include general instructions on responding to requests and specific instructions on issues that will require further consultation with the GP responsible for your care.

1. Data Controller contact details

2. Data Protection Officer contact details

GP Data Protection Officer (DPO)
NHS Kent and Medway Clinical Commissioning Group
Unit A, Compass Centre North, Pembroke Road, Chatham Maritime, Kent, ME4 4YG

Email:  kmicb.gpdpoteam@nhs.net

3. Purpose of the  processing

• To enable you to have a preference as to how we contact you
• To enable us to communicate and manage our relationship with you while we deliver the programme to you, this will include sending appointment reminders
• To ensure eligibility for the programme
• To have a unique identifier for yourself when we communicate with you
• To ensure eligibility for the programme, as you must be over the age of 18
• To ensure that we can communicate with you effectively while we deliver the programme to you
• To enable you to have a chosen representative who we can speak with on your behalf if you require us to
• To enable us to provide an individual service tailored to individual needs
• To monitor results for demographics and improve our services in the future
• To address any concerns and improve our service
• Investigate or prevent any complaints or incidents raised
• To carry out or assist with any legal or regulatory investigation
• To support your success on the programme and share progress with NHSE

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 official authority…’.
• 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 services...”  

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.  

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 or speak to the practice.

9. Right to Complain

You have the right to complain to the Information Commissioner’s Office

* “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.