Whilst we try our best to provide patients with a friendly and efficient service, we do recognise that there may be room for improvement and are open to constructive suggestions. Suggestions for ways of improving the service will always be considered seriously.

We hope that most concerns and queries can be sorted out quickly and easily, but if you wish to make a formal complaint about our services, please make this in writing to the Practice Manager.

If you feel you require further advice, you can contact the health board via Complaints – Betsi Cadwaladr University Health Board for further information and next steps.

The Freedom of Information Act 2000 obliges the Practice to produce a Publication Scheme. A Publication Scheme is a guide to the “classes” of information the Practice intends to make available routinely. This scheme is available on written request.

We encourage our patients to share responsibility for their healthcare. We will help patients to make the right treatment decisions for them by sharing the treatment options in a way which they understand. We aim always to treat our patients with dignity and respect. We will provide the same standard of care irrespective of age, gender, disability or race.

Patients have the right to express a preference to see a particular practitioner in accordance with paragraph 18 of Schedule 6 of the GP Contract. Please make your preferences known to any member of staff.

We expect our patients to treat the practice staff with courtesy and respect, and to use the service responsibly.

We will expect you to have assessments and tests taken, be willing to attend appointments with the doctors and nurses when requested to do so, and to comply (wherever possible) with any medication advised. Please ensure that you attend all appointments, or cancel them as soon as possible if you find that you no longer need them. Do not misuse urgent appointments or home visits because it causes unnecessary difficulties for other patients.

In accordance with standard NHS policy, we do not accept abuse or violence, or the threat of violence from patients. We aim to provide a high standard of care and do not deserve to be threatened. Should this happen, we will ask you to find another GP elsewhere.

We are a GP practice working within the area of the Betsi Cadwaladr Health Board. We serve a practice population of 7000 patients and employ a number staff including GPs, Nurses, Healthcare Assistants and Administrative staff. Kinmel Bay Medical Centre aims to ensure the highest standard of medical care for our patients. To do this we keep records about you, your health and the care we have provided or plan to provide to you.

Why issue a privacy notice?

Kinmel Bay Medical Centre recognises the importance of protecting personal and confidential information in all that we do and takes care to meet its legal and regulatory duties. This notice is one of the ways in which we can demonstrate our commitment to our values and being transparent and open.

This notice also explains what rights you have to control how we use your information.

What are we governed by?

The key pieces of legislation/guidance are:

• General Data Protection Regulations
• Human Rights Act 1998 (Article 8)
• Access to Health Records Act 1990
• Freedom of Information Act 2000
• Health & Social Care Act 2012, 2015
• Public Records Act 1958
• Copyright Design and Patents Act 1988
• The Re-use of Public Sector Information Regulations 2015
• The Environmental Information Regulations 2004
• Computer Misuse Act 1990
• The Common Law Duty of Confidentiality
• Information Security Management
• NHS Code of Practice

Who are we governed by?

• Department of Health
• Information Commissioners Office
• Health Inspectorate Wales
• NHS Wales
• General Medical Council (GMC)

Why and how we collect information

Information which can be accessed, where there is a need, includes:

• personal information, such as name, date of birth, gender;
• allergies;
• medication;
• hospital admission, attendances and referral dates;
• vaccinations and immunisations;
• test results, including measurements such as blood pressure;
• diagnoses (current and previous problems);
• treatment and medical procedures.

How we use information

• To help inform decisions that we make about your care
• To ensure your treatment is safe and effective
• To work effectively with other organisations who may be involved in your care
• To support the health of the general public
• To ensure our services can meet future needs
• To review care provided to ensure it is of the highest standard possible
• To train healthcare professionals
• For research and audit
• To prepare statistics on performance
• To monitor how we spend public money

There is a huge potential to use your information to deliver care and improve health and care services across the NHS and social care. The information can be used to help:

• Improve individual care
• Understand more about disease risks and causes
• Improve diagnosis
• Develop new services
• Improve patient safety
• Evaluation of policy/procedures/pathways

It helps because:

• Accurate and up to date information assists us in providing you with the best possible care.
• If you see another healthcare professional, specialist from another part of the NHS, they can readily access the information they need to provide you with the best care possible.
• Where possible, when using information to inform future services and provision, non-identifiable information will be used.

Disclosure of Information to Other Health and Social Professionals

We work with a number of other NHS and partner agencies to provide healthcare services to you, for example:

• Other  NHS hospitals
• Relevant GP Practices
• Dentists, Opticians and Pharmacies
• Private Sector Providers (private hospitals, care homes, hospices, contractors providing services to the NHS)
• Voluntary Sector Providers who are directly involved in your care
• Ambulance Service
• Specialist Services
• Associated healthcare and social care staff working within the locality
• Out of Hours Medical Service
• NHS Wales

We may also share your information with your consent, and subject to strict sharing protocols, about how it will be used, with other Health and Social Care departments and the Police and Fire Services.

Risk Prediction

Risk prediction data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive information. Information about you is collected from a number of sources in NHS Wales including this GP Practice.

A risk score is then arrived at through an analysis of your de-identifiable information by the NHS Informatics Service and is only provided back to your GP’s Data Controller in an identifiable form. Risk prediction enables your GP to focus on preventing ill health and not just the treatment of illness. If necessary, your GP may be able to offer you additional services.

My Health Online (MHOL) – Online Registration for Ordering Repeat Prescriptions

Registering for My Health Online allows you check your repeat medication, order repeat prescriptions and make changes to your email and mobile contact number where appropriate. Patients aged 16 years and over can register to use this service and can de-register at any time. In the future, more services will be added, such as the facility to book appointments and view test results. Please enquire at Reception if you need information.

Mail to Patients

We sometimes use a printing company to send letters to our patients, for example to remind you about flu vaccination campaigns. Data sent is encrypted and the Company puts it in a format to print the letter, despatch via Royal Mail or courier, and then delete the information we send.

Text messages to Patients

If we have your current mobile telephone number, we will send you appointment reminder text notifications, information about flu clinics, health promotion information, cancellation of clinics and changes in service provision. Please ensure that we have your most up to date mobile telephone number for this to continue. You can opt out of the text notification service at any time by contacting the practice.

Emergency Care Summary (ECS)

Emergency care information such as your name, date of birth, the name of your GP, any medicines which your GP has prescribed, any medicines you are allergic to or react badly to, is shared with Out of Hours as this might be important if you need urgent medical care when the GP surgery is closed.

NHS staff (Doctors, Nurses, Accident and Emergency, Ambulance control and crews) can look at your ECS if they need to treat you when the surgery is closed. They will ask for your consent before they look at your records. In an emergency and if you are unconscious, staff may look at your ECS without your agreement to let them give you the best possible care. Whenever NHS staff looks at your ECS, a record will be kept so we can always check who has looked at your information.

Medicine Management

The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost effective treatments. This service is provided by our clinicians and Pharmacists provided by the local Health Board.

Computer System

This Practice operates a Clinical Computer System on which NHS Staff record information securely. This information can then be shared with other Clinicians so that everyone caring for you is fully informed about your relevant medical history.

How We Keep Your Information Confidential and Secure

We are committed to protecting your privacy and will only use information collected lawfully in accordance with the Data Protection Act 1998, Article 8 of the Human Rights Act, the Common Law of Confidentiality, the General Data Protection Regulation and the NHS Codes of Confidentiality and Security. Everyone working in or for the NHS must use personal information in a secure and confidential way.

Please be aware that your information will be accessed by non-clinical Practice staff in order to perform tasks enabling the functioning of the Practice. These are, but are not limited to:

• Typing referral letters to Hospital Consultants or allied Health Professionals
• Opening letters from hospitals and Consultants
• Scanning clinical letters, reports and any other documents not available electronically
• Photocopying or printing documents for referral to Consultants
• Handling, printing, photocopying and postage of medico legal and life assurance reports and other associated documents
• When you register with the Practice we may ask for proof of ID; this is to ensure that no one tries to register you at the Practice using your identity but without your knowledge. Please be assured that any copies of ID that we take at that point are destroyed once we have confirmation of your registration by NHS Wales. This takes 2-3 days maximum.

To protect your confidentiality, we will not normally disclose any medical information about you over the telephone, or by fax, unless we are sure that we are talking to you. This means that we will not disclose information to your family, friends, and colleagues about any medical matters at all, unless we know that we have your consent to do so.

We will only ever use or pass on your information if there is a genuine need to do so. We will not disclose information about you to third parties without your permission unless there are exceptional circumstances, such as when the law requires.

All persons in the Practice (whether employed by the Doctors, or for the Local Health Board) sign a confidentiality agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty.

Right of Access to Your Health Information

The General Data Protection Regulation allows you to find out what information about you is held on computer and in manual records. This is known as “right of subject access” and applies to personal information held about you. If you want to see or receive information that the Practice holds about you:

• You will need to make a request to the practice manager.
• We may ask you to complete a request form to establish exactly what parts of your record you need.
• You will need to give us adequate information for us to be sure that your request is legitimate (address, date of birth, NHS number etc) plus two forms of identification to enable us to confirm your identity.
• There may be a charge for excessive requests for information held about you.
• We are required to respond to your request within one month.

Who Else May Ask to Access Your Information

• The Court can insist that we disclose medical records to them

• Solicitors often ask for medical reports. We will require your signed consent for us to disclose information. The consent should be provided on The Law Society’s standard consent form. We will not normally release details about other people that are contained in your records (e.g. wife, children parents etc.) unless we also have their consent

• Social Services and other agencies may require medical reports on you from time to time. We will need your signed consent to provide information to them.

• Life Assurance Companies/Employers/Occupational Health Doctors frequently ask for medical reports on individuals. These are always accompanied by your signed consent form.

We will only disclose the relevant medical information as per your consent. You have the right, should you request it, to see reports prepared for Insurance Companies, employers or occupational Health doctors before they are sent.

Sharing Your Information without Consent

We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:

• Where there is a serious risk of harm or abuse to you or other people
• Where a serious crime, such as assault, is being investigated or where it could be prevented
• Where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not sensitive information such as HIV/AIDS)
• Where a formal Court Order has been issued
• Where there is a legal requirement, e.g. if you had committed a Road Traffic Offence

The practice is committed to ensuring that your privacy is protected.

Change of Details

It is important that you tell us if any of your details such as your name, address, home telephone number or mobile telephone number has 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 kept accurate and up to date at all times.

Your NHS Number

Every person registered with the NHS in England and Wales has their own unique NHS number. It is made up of 10 digits – for example 123 456 7890.

Your NHS number is used by healthcare staff to identify you correctly. It is an important step towards improving the safety of your healthcare. To improve safety and accuracy always check your NHS number on correspondence the NHS sends to you.

If you don’t know your NHS number, ask at the Practice. You may be asked for proof of identify for example a passport of other form of identity. This is to protect your privacy.

This Privacy Notice does not provide exhaustive details of all aspects of the collection and use of personal information by Kinmel Bay Medical Centre. However, we are happy to provide any additional information or explanation needed. If you wish to request further information please contact:

Practice Manager,
Kinmel Bay Medical Centre,
The Square,
Kinmel Bay,
LL18 5AU

Telephone: 01745 338989

Complaints 

Should you have a complaint about how your information is managed at the practice, please contact the Practice Manager. If you remain unhappy with the Practice’s response, you can complain to the Information Commissioner Office www.ico.gov.uk.