Privacy Policy and Cookies

CSH Surrey (Central Surrey Health LTD) is a Data Controller and is registered with the Information Commissioner’s Office (ICO), registration number is Z9948287. Our registered address is Ewell Court Clinic, Ewell Court Avenue, Ewell KT19 0DZ and our company registration number is 5700920.

As an organisation, we are committed to protecting your information and respecting your privacy in accordance with the Data Protection Act 1998 and General Data Protection Regulation 2018.

This notice explains what information we collect, why we collect it and how we keep it secure. It also explains your rights and our legal obligation. We undertake information audits to establish clear lines on what personal data we hold and what we do with it.

Notification of changes to this privacy notice

This privacy notice was last updated 23 May 2018. If we use your personal data for any new purposes, updates will be made to the policy information and changes communicated, where necessary in accordance with current legislation. For all queries relating to our privacy policy, please contact:

Naomi Barnes, Information Governance and Information Security Officer, email: csh.ig@nhs.net

How the NHS and care services use your information 

CSH Surrey is one of many organisations working in the health and care system to improve care for patients and the public.

Whenever you use a health or care service, such as using Community Care services, important information about you is collected to help ensure you get the best possible care and treatment.

The information collected about you when you use these services can also be provided to other approved organisations, where there is a legal basis, to help with planning services, improving care provided, research into developing new treatments and preventing illness. All of these help to, provide better care for you, your family and future generations. Confidential personal information about your health and care is only used in this way where allowed by law and would never be used for insurance or marketing purposes without your explicit consent.

You have a choice about whether you want your confidential patient information to be used in this way.

To find out more about the wider use of confidential information and to register your choice to opt out if you do not want your data to be used in this way, visit www.nhs.uk/my-data-choice. If you do choose to opt out you can still consent to your data being used for specific purposes.

If you are not happy with this use of information you do not need to do anything. You can change your choice at any time.

For patients 

How we use your information

What information we collect?

If you are a patient, we hold records about you which may include:

Personal information such as, name, address, date of birth, gender, telephone number (s), email address(s), next of kin, emergency contact information, ethnicity, disability, religion, registered GP, clinical information.

Why do we collect this information?

CSH Surrey aims to provide you with the highest quality of health care. To do this we must keep records about you, your health and the care we have provided, or plan to provide to you. Health records are held on paper and electronically, and we have a legal duty to keep these confidential, accurate and secure at all times in line with the Data Protection Act 1998 and General Data Protection Regulation 2018.

We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never collected for direct marketing purposes, and is not sold on to any other third parties. Information is held for specified periods of time as set out in this policy under, your rights.

CSH Surrey has to provide a legal basis for the processing of your information under the General Data Protection Regulation 2018.

If we need to use your personal information for any reason beyond those stated within this policy, CSH Surrey will communicate these changes before starting any new processing activity.  

Our obligations

We have a duty to:

  • Inform you of the legal basis for processing your information, as required under the Data Protection legislation.

CSH Surrey may rely on the following legal basis when processing your personal information:

Legal obligation

When required to comply with the law. This may be in circumstances to:

  • Communicating when things go wrong: we have a duty to which is set out under The Health and Social Care Act 2008 (HSC) 2008 to report incidents, set out in the HSC 2008.
  • Safeguard individuals, set out in the (Safeguarding Vulnerable Groups Act 2006), Children Act 1989 & 2004.
  • Notify officials of infectious diseases which present significant risk to human health and the wider public, set out in The Public Health (Control of Disease) Act 1984 and the Health Protection (Notification) Regulations 2010.
  • Support other organisations with their regulatory requirements, eg Care Quality Commission (CQC), Information Commissioner's Office (ICO).
  • Support detection, investigation or to prevent a serious crime, monitor referral to treatment times and ensuring compliance with the NHS Constitution and the NHS Operating Framework, conduct audits to measure compliance with the law (eg Confidentiality Audits), respond to the rights of individuals requests under data protection law, share information relating to vulnerable individuals  with emergency services in the event of an emergency (Civil Contingencies Act 2004). 
  • To support court orders requiring us to share information.

Vital interests

To protect someone’s life. This may be in circumstances to:

  • Share information to safeguard an individual and therefore prevent harm. 

Public task

When carrying out statutory, governmental or statutory functions. This may be in circumstances to:

Deliver patient care, when responding to complaints or concerns relating to the delivery of care, when monitoring patient pathways, to share information about a patient for their direct care (subject to both the common law duty of confidence, data protection legislation), and statutory duty under section 251B of the Health and Social Care Act 2012, to manage waiting lists, performance against national targets, activity monitoring e.g. number of referrals, when undertaking local clinical audits, commission funding for treatment and/or equipment.

Legitimate interests

This may be in circumstances to:

Support business functions, eg raising system level tickets, arranging access to system, take photos of service users to publish on twitter and interests’ websites, for general website enquiries, store next of kin data in the event of a medical emergency record of CCTV.

Your rights

We have a duty to provide you with rights of access to your data when requested.

Under the Data Protection Legislation, patients have the right to obtain a copy of their personal records held by us; this is called a Subject Access Request (SAR). 

To obtain a copy of your medical records, please submit your request to the CSH Surrey Subject Access Request Team.

Address: Caroline Williams, CSH Surrey Therapies Block J, Therapies Department, Epsom General Hospital, Dorking Road, Epsom, Surrey, KT18 7EG

Email: csh.sarteam@nhs.net

Tel: 01372 735 6403

You will need to provide your information (eg full name, address, date of birth, Hospital/NHS number) and forms of identification. If you wish for another person to process your request on your behalf they will need to obtain your written permission to do so before we can provide copies of medical records. This ensures we are providing confidential information to authorised persons(s).

An individual may choose to nominate a representative (such as a solicitor or relative) to make a request on their behalf, however when this happens the request must be explicitly authorised by the person (e.g. evidenced by a signed letter of consent).

Those who hold Lasting Power of Attorney for Health and Welfare for an individual can apply for that individual’s records.

Further guidance and assistance can be obtained from the Subject Access Request Team.

 

Under Data Protection legislation, you have a right to:

Be informed

Be informed about the collection and use of your personal data. This communication is done through this privacy policy.

Object and restrict

The legislation gives individuals the right to object to the processing of their personal data in some circumstances. This will depend on the legal basis (as described above) for processing your information. In order to formally object, you will need to do so verbally or in writing to:

Naomi Barnes, Information Governance and Information Security Officer, email: csh.ig@nhs.net

Request the restriction of your personal data, however this will only applies when/if you contest the accuracy of the personal data, the data has been unlawfully processed and/if you oppose erasure and requests. You can make a request for restriction verbally or in writing to:

Naomi Barnes, Information Governance and Information Security Officer, email: csh.ig@nhs.net

Rectification and erasure

Have inaccurate personal data rectified, or completed if it is incomplete.

The legislation states that, `personal data is inaccurate if it is incorrect or misleading as to any matter of fact`. You can make a request for rectification verbally or in writing to:

Naomi Barnes, Information Governance and Information Security Officer, email: csh.ig@nhs.net

Consent

When you are providing this for the purpose of processing your personal data and activity, you will always have the freely given right to actively accept and withdraw.

CSH Surrey manages consent when processing data in the following ways:

Regularly reviewing consents to check that the relationship with the individual and the purpose for processing information has not changed. By having appropriate processes in place to refresh consent at appropriate intervals, including any parental consents. Acting on withdrawals of consent as soon as reasonably possible. 

How long will we hold your information?

Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for the specific purposes. CSH Surrey will regularly review the length of time we keep your personal data and securely delete information that is no longer needed for the purposes it was originally intended. This process will enable clear and accurate data, keeping it up to date, available and confidential.

How we share your information

If and when we need to share your personal data; we will always account the justifications for doing so.

When data sharing external to our organisation, CSH Surrey will always assess the potential benefits and risks to you and others, we will weigh the proportionality for the purpose and what we are trying achieve by this activity. We will consider if the objective be achieved without sharing personal data and have measures to ensure adequate security is in place to protect the data when sharing this.

International transfer of your personal data

CSH Surrey does not transport or share personal data outside of the European Union.

Links to other publiciations - websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Cookie Policy

Cookies allow a website to recognise a user’s device and respond to them as an individual. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

What cookies we use and how we use them

Business Critical Cookies

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These cookies allow CSH Surrey to count visits and traffic sources to measure and improve the performance of its website. They help us to know which pages are the most and least popular and see how visitors move around our site. All information these cookies collect is aggregated and therefore anonymous. We use the Google Analytics service for this purpose. We also use a cookie for the cookie bar to remember you have accepted cookies: CP_allowcookies

Essential Cookies

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These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by visitors which amount to a request for services, such as logging in or filling in forms. Visitors can set their browser to block or alert them about these cookies; however some parts of the site will not then work. These cookies do not store any personally identifiable information.

​You can choose to accept or decline cookies although this may prevent you from taking full advantage of the website.

Complaints

If you have any comments, queries or complaints about this Privacy Notice or the processing of your personal information please address these to:  Quality and Governance Team, Central Surrey Health, Leatherhead Community Hospital, Poplar Road, Leatherhead, Surrey, KT22 8SD

Email: qandgteam@nhs.net 

Alternatively, you are entitled to appeal to the Information Commissioners Office (ICO). The Information Commissioners Office enforces and oversees the Data Protection Regulations. To find out more about the information rights in the public interest, further details can be found at: www.ico.org.uk