Covid19 Privacy Notice V14 19th March 2021 Dr Craven

covid-19 privacy notice v1.4 19th march 2021 dr craven and czepulkowski covid-19 privacy notice (this privacy notice is to run alongsid

Covid-19 Privacy Notice v1.4 19th March 2021 Dr Craven and
Czepulkowski
COVID-19 Privacy Notice
(This Privacy Notice is to run alongside our standard Practice Privacy
Notice)
Due to the unprecedented challenges that the NHS and we, Dr Craven and
Czepulkowski Practice face due to the worldwide COVID-19 pandemic,
there is a greater need for public bodies to require additional
collection and sharing of personal data to protect against serious
threats to public health.
In order to look after your healthcare needs in the most efficient way
we, Dr Craven and Czepulkowski may therefore need to share your
personal information, including medical records, with staff from other
GP Practices including Practices within our Primary Care Network, as
well as other health organisations (i.e. Clinical Commissioning
Groups, Commissioning Support Units, Local authorities etc.) and
bodies engaged in disease surveillance for the purposes of research,
protecting public health, providing healthcare services to the public
and monitoring and managing the Covid-19 outbreak and incidents of
exposure.
The Secretary of State has served notice under Regulation 3(4) of the
Health Service (Control of Patient Information) Regulations 2002
(COPI) to require organisations to process confidential patient
information in the manner set out below for purposes set out in
Regulation 3(1) of COPI.
Purpose of this Notice
The purpose of this Notice is to require organisations such as Dr
Craven and Czepulkowski Practice to process confidential patient
information for the purposes set out in Regulation 3(1) of COPI to
support the Secretary of State’s response to Covid-19 (Covid-19
Purpose). “Processing” for these purposes is defined in Regulation
3(2) and includes dissemination of confidential patient information to
persons and organisations permitted to process confidential patient
information under Regulation 3(3) of COPI. This Notice is necessary to
require organisations such as Dr Craven and Czepulkowski Practice to
lawfully and efficiently process confidential patient information as
set out in Regulation 3(2) of COPI for purposes defined in regulation
3(1), for the purposes of research, protecting public health,
providing healthcare services to the public and monitoring and
managing the Covid-19 outbreak and incidents of exposure.
Requirement to Process Confidential Patient Information
The Secretary of State has served notice to recipients under
Regulation 3(4) that requires Dr Craven and Czepulkowski Practice to
process confidential patient information, including disseminating to a
person or organisation permitted to process confidential patient
information under Regulation 3(3) of COPI, renewed 27 January 2021.
Dr Craven and Czepulkowski Practice is only required to process such
confidential patient information:
 where the confidential patient information to be processed is
required for a Covid-19 Purpose and will be processed solely for that
Covid-19 Purpose in accordance with Regulation 7 of COPI
 from 20th March 2020 until 30 September 2021.
Covid-19 Purpose.
A Covid-19 Purpose includes but is not limited to the following:
 understanding Covid-19 and risks to public health, trends in
Covid-19 and such risks, and controlling and preventing the spread of
Covid-19 and such risks
 identifying and understanding information about patients or
potential patients with or at risk of Covid-19, information about
incidents of patient exposure to Covid-19 and the management of
patients with or at risk of Covid-19 including: locating, contacting,
screening, flagging and monitoring such patients and collecting
information about and providing services in relation to testing,
diagnosis, self-isolation, fitness to work, treatment, medical and
social interventions and recovery from Covid-19
 understanding information about patient access to health services
and adult social care services and the need for wider care of patients
and vulnerable groups as a direct or indirect result of Covid-19 and
the availability and capacity of those services or that care
 monitoring and managing the response to Covid-19 by health and
social care bodies and the Government including providing information
to the public about Covid-19 and its effectiveness and information
about capacity, medicines, equipment, supplies, services and the
workforce within the health services and adult social care services
 delivering services to patients, clinicians, the health services and
adult social care services workforce and the public about and in
connection with Covid-19, including the provision of information, fit
notes and the provision of health care and adult social care services
 research and planning in relation to Covid-19.
Recording of processing
A record will be kept by Dr Craven and Czepulkowski Practice of all
data processed under this Notice.
Sending Public Health Messages
Data protection and electronic communication laws will not stop Dr
Craven and Czepulkowski Practice from sending public health messages
to you, either by phone, text or email as these messages are not
direct marketing.
Digital Consultations
It may also be necessary, where the latest technology allows Ashville
Medical Practice to do so, to use your information and health data to
facilitate digital consultations and diagnoses and we will always do
this with your security in mind.
Research and Pandemic Planning
The Secretary of State has directed NHS Digital to collect, process
and analyse data in connection with COVID-19 to support the Secretary
of State’s response to COVID-19 and support various COVID-19 purposes
set out in the COVID-19 Public Health Directions 2020, 17 March 2020
(as amended) (COVID-19 Direction) and below. This enables NHS Digital
to collect data and analyse and link the data for COVID-19 purposes
with other data held by NHS Digital.
The purpose of the data collection is also to respond to the intense
demand for General Practice data to be shared in support of vital
planning and research for COVID-19 purposes, including under the
general legal notice issued by the Secretary of State under Regulation
3(4) of the Health Service (Control of Patient Information)
Regulations 2002 (COPI).
NHS Digital has therefore been requested by the joint co-chairs of the
Joint GP IT Committee (JGPITC) (the BMA and RCGP) to provide a
tactical solution during the period of the COVID-19 pandemic to meet
this demand and to relieve the growing burden and responsibility on
General Practices. On 15 April 2020 the BMA and RCGP therefore gave
their support via JGPITC to NHS Digital’s proposal to use the General
Practice Extraction Service (GPES) to deliver a data collection from
General Practices, at scale and pace, as a tactical solution to
support the COVID-19 response in the pandemic emergency period.
It is a requirement of the JGPITC that all requests by organisations
to access and use this data will need to be made via the NHSX SPOC
COVID-19 request process, that will triage and prioritise these
requests and refer appropriate requests on to the NHS Digital Data
Access Request Service (DARS). NHS Digital will consult with
representatives of the BMA and the RCGP on all requests for access to
the data. An outline of the process for this agreed with the BMA and
the RCGP is published here. Requests by organisations to access record
level data from this collection will also be subject to Independent
Group Advising on the Release of Data (IGARD) consideration. Data
applicants will need to demonstrate they have a lawful basis to access
the data for COVID-19 purposes.
Benefits of this sharing
Organisations, including the Government, health and social care
organisations and researchers need access to this vital data for a
range of COVID-19 purposes, to help plan, monitor and manage the
national response to the COVID-19 pandemic, which will help save
lives. COVID-19 purposes for which this data may be analysed and used
may include:
• understanding COVID-19 and risks to public health, trends in
COVID-19 and such risks, and controlling and preventing the spread of
COVID-19 and such risks
• identifying and understanding information about patients or
potential patients with, or at risk of COVID-19, information about
incidents of patient exposure to COVID-19 and the management of
patients with or at risk of COVID-19 including: locating, contacting,
screening, flagging and monitoring such patients and collecting
information about and providing services in relation to testing,
diagnosis, self-isolation, fitness to work, treatment, medical and
social interventions and recovery from COVID19
• understanding information about patient access to health services
and adult social care services as a direct or indirect result of
COVID-19, and the availability and capacity of those services •
monitoring and managing the response to COVID-19 by health and social
care bodies and the Government including providing information to the
public about COVID-19 and its effectiveness and information about
capacity, medicines, equipment, supplies, services and the workforce
within the health services and adult social care services
• delivering services to patients, clinicians, the health services and
adult social care services workforce and the public about and in
connection with COVID-19, including the provision of information, fit
notes and the provision of health care and adult social care services;
and
• research and planning in relation to COVID-19.
Data may be analysed and linked to other data held by NHS Digital or
held by other organisations to which access to the data is granted for
COVID-19 purposes, through the process described above.
Data will be collected nationally from all GP Practices by NHS Digital
every fortnight. All requests to access this data will be triaged
through the NHSX SPOC COVID-19 request process and assessed and
fulfilled by NHS Digital through DARS. This will significantly reduce
the burden on General Practice at a time when demand on resources is
high, enabling General Practice to focus on delivering health care and
support to patients. It will also reduce compliance burden and risk
for General Practice associated with sharing data and complying with
the terms of the general legal notice issued under COPI, which applies
to General Practices.
Legal Basis for this collection
NHS Digital has been directed by the Secretary of State under section
254 of the 2012 Act under the COVID-19 Direction to establish and
operate a system for the collection and analysis of the information
specified for this service: GPES Data for Pandemic Planning and
Research (COVID-19). A copy of the COVID-19 Direction is published
here:
https://digital.nhs.uk//about-nhs-digital/corporate-information-and-documents/directions-anddata-provision-notices/secretary-of-state-directions/covid-19-public-health-directions-2020.
Details of the information to be collected can be found on the NHS
Digital website – Specification of this DPN. Type 1 objections will be
upheld in collecting this data from General Practices and therefore
the data for those patients who have registered a Type 1 objection
with their GP will not be collected. The Type 1 objection prevents an
individual’s personal identifiable confidential information from being
shared outside of their GP Practice except when it is being used for
the purposes of their direct care. The National Data Opt-Out will not
apply to the collection of the data, as this is a collection which is
required by law.
This information is required by NHS Digital under section 259(1)(a) of
the 2012 Act to comply with the COVID-19 Direction. In line with
section 259(5) of the 2012 Act, all organisations in England that are
within the scope of this Notice, as identified below under Health and
Social Care Bodies within the scope of the collection, must comply
with the requirement and provide information to NHS Digital in the
form, manner and for the period specified in this Notice. This Notice
is issued in accordance with the procedure published as part of NHS
Digital’s duty under section 259(8) of the 2012 Act.
In August 2020, the NHS announced that the seasonal national flu
immunisation programme criteria for 2020 - 2021 will be expanded to
include patients on the SPL. Therefore, to provide information that
will support the identification of patients at moderate or high risk
of complications from flu, a revision to the weekly extract of data
has taken place. This, version three of the extract for the purpose of
maintaining and updating the SPL, will continue until the expiry of
the COVID-19 Direction. This is currently 31 March 2022 but will be
reviewed in September 2020 and every six months thereafter. The
frequency of the data collection may change in response to demand.
Data collection extracted on a weekly basis week commencing 13 April
2020
Revised weekly data collection. The first collection is due week
commencing 28 September 220
All patients with defined long-term medical conditions which pose a
COVID-19 risk, identified as clinically extremely vulnerable to that
risk and/or on certain drug treatments as below:
All patients with defined long-term medical conditions which pose a
COVID-19 risk, identified as clinically extremely
vulnerable/potentially clinically vulnerable to that risk and/or on
certain drug treatments as below:
Medical Conditions that provide information on clinically vulnerable
patients
 Severe asthma and dust related lung disease with relevant treatment
in the last 12 months (asthma treatment & prednisolone OR high dose
cortiscosteroid safety card)
 COPD emphysema, and associated lung diseases with relevant treatment
in the last 12 months (COPD drugs OR high dose high dose
cortiscosteroid safety card
 Non-asthma and non-COPD respiratory disease
 Cancer(haem and others)
 Genetic, metabolic or autoimmune disease
 Immunosuppression drugs in the last 12 months
 Flu-like symptoms or respiratory tract infections from 1 November
2019
 Transplants with severe Immunosuppression drug treatment in the last
12 months
 Pregnant in last 9 months
Medical Conditions that provide information on clinically vulnerable
patients
 Severe asthma and dust related lung disease with relevant treatment
in the last 12 months (asthma treatment & prednisolone OR high dose
cortiscosteroid safety card)
 COPD emphysema, and associated lung diseases with relevant treatment
in the last 12 months (COPD drugs OR high dose high dose
cortiscosteroid safety card
 Non-asthma and non-COPD respiratory disease
 Cancer(haem and others)
 Genetic, metabolic or autoimmune disease
 Immunosuppression drugs in the last 12 months
 Flu-like symptoms or respiratory tract infections from 1 November
2019
 Transplants with severe Immunosuppression drug treatment in the last
12 months
 Pregnant in last 9 months
No change
 Patients designated separately as at risk from COVID-19 using
high/medium/low risk SNOWED CT Codes, for example
 Patients designated separately as at risk from COVID-19 using
high/medium/low risk SNOWED CT Codes,
The Secretary of State has directed NHS Digital to collect, process
and analyse data in connection with COVID-19 to support the Secretary
of State’s response to COVID-19 and support various COVID-19 purposes
set out in the COVID-19 Public Health Directions 2020, 17 March 2020
(COVID-19 Direction) (as amended) (COVID-19) Direction) and below.
This enables NHS Digital to collect data and analyse and link the data
for COVID-19 purposes with other data held by NHS Digital. The
rationale for changing the data extraction is that the initial data
collection was based on an existing specification for flu vaccination
eligibility. This data extraction was then refined in order to more
accurately reflect the patients who are clinically extremely
vulnerable to COVID-19 and also to minimise the data we are
collecting. A further refinement of the data extraction has taken
place leading to the inclusion of new data being extracted. This will
provide information to inform vaccination programmes. This General
Practice Extraction
Service (GPES) data will be extracted weekly and be used to assist in
producing a weekly update of the SPL. The objective of this collection
is on an ongoing basis to identify patients registered at General
Practices who may be: • clinically extremely vulnerable if they
contract COVID-19 • at moderate or high risk of complications from flu
or COVID-19. The data collected will be analysed and linked with other
data NHS Digital or other organisations hold to identify: • a list of
clinically extremely vulnerable patients who will be advised to take
shielding measures to protect themselves. Advice given to these
patients has been published by Public Health England and is available
here:
https://www.gov.uk/government/publications/guidance-on-shielding-and-protectingextremely-vulnerable-persons-from-covid-19/guidance-on-shielding-and-protectingextremely-vulnerable-persons-from-covid-19#what-do-we-mean-by-extremelyvulnerable
• a list of patients at moderate or high risk of complications from
flu to inform the flu call/recall vaccination programme.
Benefits of the collection
Organisations, including Government, health and social care
organisations need to access this vital data for a range of COVID-19
purposes, to help plan, monitor and manage the national response to
the COVID-19 pandemic, which will help save lives. COVID-19 purposes
for which this data may be analysed and used may include: •
understanding COVID-19 and risks to public health, trends in COVID-19
and such risks, and controlling and preventing the spread of COVID-19
and such risks • identifying and understanding information about
patients or potential patients with, or at risk of COVID-19,
information about incidents of patient exposure to COVID-19 and the
management of patients with or at risk of COVID-19 including:
locating, contacting, screening, flagging and monitoring such patients
and collecting information about and providing services in relation to
testing, diagnosis, self-isolation, fitness to work, treatment,
medical and social interventions and recovery from COVID19. Data will
be analysed and linked to other data held by NHS Digital or held by
other organisations to which access to the data is granted for
COVID-19 purposes, through the process described above. Data will be
collected nationally from all General Practices by NHS Digital every
week. All requests to access this data will be through Data Access
Request Service (DARS). This will significantly reduce the burden on
General Practice at a time when demand on resources is high, enabling
General Practice to focus on delivering health care and support to
patients. It will also reduce compliance burden and risk for General
Practice associated with sharing data and complying with the terms of
the general legal notice issued under the National Health Service
(Control of Patient Information Regulations) 2002 (COPI), which
applies to General Practices Patients facing the greatest risk if they
contract COVID-19 and/or are in the moderate to high risk of
complications from flu:
• will be identified and known to health organisations
• will have a greater awareness of the recommended preventative
shielding measures
• will be able to follow clear advice
• will be able to ask for help and support, including social care
support and essential food supplies, through the Extremely Vulnerable
Persons service operated by gov.uk.
It will enable the SPL to be updated weekly to identify new patients
and changes to patients on the List and will enable support provisions
to be more dynamic and responsive to both social and clinical need.
It will also enable vital planning, commissioning, and research to be
carried out for COVID-19 purposes. If patients facing the greatest
risk follow advice, it is hoped that this will contribute to the delay
and mitigation of the spread of COVID-19 and save lives.
Visitors to The Practice
We have an obligation to protect our staff and employees’ health, so
it is reasonable for staff at Dr Craven and Czepulkowki practice to
ask any visitors to our practice to tell us if they have visited a
particular country, or are experiencing COVID-19 symptoms. This must
only be in pre-approved circumstances and we would also ask all
patients to consider government advice on the NHS 111 website and not
attend the practice.
Where it is necessary for us to collect information and specific
health data about visitors to our practice, we will not collect more
information than we need, and we will ensure that any information
collected is treated with the appropriate safeguards.
Review and Expiry of this Notice
This Notice will be reviewed on or before 30 September 2021 and may be
extended by The Secretary of State. If no further notice is sent to Dr
Craven and Czepulkowksi by The Secretary of State, this Notice will
expire on 30 September 2021.