Privacy statement

In order to provide a healthcare service, we need to collect and use personal information for a range of purposes.  Primarily, we collect data for healthcare and administration purposes.  For example, a health professional will record treatment details as this is essential information in order to provide a healthcare service.  Patient consent is sought wherever appropriate. 

There are some cases where it is necessary and a legal requirement to process personal information even without the consent of the individual whom the information relates to. If we do not have accurate, up to date information, this may impact on the services (such as effective treatment) that we provide.  

Where we have not collected your information directly ourselves (such as GP or social workers), this will be clearly documented and/or stated to the individual, in line with the requirements under the General Data Protection Regulations.

CLCH respects patient choice and will respect an individual’s request to withhold information from someone or an agency unless there is a legal requirement to disclose the information.

Other purposes for data collection and usage may include:

• Staff Administration, i.e. pay, discipline, work management
• Improving services, i.e. patient satisfaction survey
• Training purposes to ensure staff are adequately trained to carry out their role
• To conduct an investigation in response to a complaint or police enquiry
• Accounts and records, i.e. keeping accounts related to business activity, customers, financial management, responding to freedom of information requests
• Research purposes, i.e. health or scientific research (any published data will always be anonymous)
• Performance monitoring and analysis to help us assess the quality and standard of our healthcare services

We exercise our official authority by collecting, using and where applicable sharing your information in order to provide you with care. The lawful basis for processing the data are for the Trust’s compliance with a legal obligation, public health interest and for the provision of health care.

This table shows the legal basis for the different purposes for using your data.

We collect information pertaining to your identity, contact information, health status information, diagnoses, and other information which allows us to support and administer healthcare. To minimise additional collation of information, the Trust will utilise information that is already held about you.

If you are a substantive member of staff, the Trust as your employer holds some personal information about you for employment purposes. Similarly, if you are an agency or contract staff, the Trust holds some information about you for the purposes of your provision of services to the Trust. It is important to note that there is no linkage of your Electronic Staff Records to the submissions made to Public Health England.

As the data subject, you have the following rights in relation to your data:

1. The right to be informed,
2. The right of access,
3. The right to rectification,
4. The right to erasure,
5. The right to restrict processing,
6. The right to data portability, and
7. The right to object.

All personal data held by CLCH is held for a time period in accordance to the NHS Records Management Code of Practice and social care 2021. 

The Records Management Code of Practice for Health and Social Care 2021 sets out what people working with or in NHS organisations in England need to do to manage records correctly. The data will also be retained in line with the Data Protection and the Control of Patient Information (COPI) Regulations.

You have a choice about how you want your confidential patient information to be used. If you're happy for us to use your information, you do not need to do anything.

If you choose to opt out, your confidential patient information will still be used to support your individual care. To find out more or to register your choice to opt out, visit nhs.uk/your-nhs-data-matters. Here you can:

• find out what is meant by confidential patient information
• find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
• find out more about the benefits of sharing data
• understand more about who uses your data
• find out how your data is protected
• access the system to view, set or change your opt-out setting
• find a contact telephone number to find out more or opt-out by phone
• find out in which situations the opt-out does not apply

You can find out more about how patient information is used at:

• Health Resource Authority - Information about patients
• Understanding Patient Data - What you need to know

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies, or used for marketing purposes. Data would only be used in this way with your specific agreement.      

Health and care organisations had until 2020 to put systems and processes in place so they can be compliant with the national data opt-out, and apply your choice to any confidential patient information they use or share, for purposes beyond your individual care. Our Trust is currently compliant with the national data opt-out policy.

By law you are entitled to request a copy of the information we hold about you. This is known as a Subject Access Request. To submit such a request, we ask that you contact the Information Governance Team via:

• Email: clchig@nhs.net
• Phone: 020 8102 5005
• Post: Information Governance Department, Parsons Green Health Centre, 5-7 Parsons Green, SW6 4UL

If you have any queries in relation to the processing of your personal data, please contact the Information Governance team via the contact details provided above.

If you have any issues or concerns, you can contact the Patient and Liaison Service (PALS) via e-mail clchpals@nhs.net.

The Trust’s Data Protection Officer is Caroline Law and can be contacted as follows:-

• E-mail: caroline.law3@nhs.net
• Phone: 020 8102 5297
• Mobile: 07506937257

The Trust is registered as a Data Controller with the Information Commissioners Office under registration number Z2416880.

The Information Commissioner’s Office (ICO) is the body that regulates the Trust under Data Protection and Freedom of Information legislation.

You can complain to the ICO at

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

or

on the ICO’s website via the following link: https://ico.org.uk/global/contact-us/.

A cookie is a piece of data stored on the user's hard drive while they are visiting a particular website. The benefit of using cookies is that it allows us to monitor website traffic and record user's preferences.

CLCH will ensure that the use of cookies is managed in accordance with national and legal guidelines, such as those that require the consent of website visitors for their use.

For more information on cookies, and how our website uses them, please see our Sexual Health South West London cookies policy.

Our website may contain links to other websites that may be of interest. However, once you click on these links and exit our site, please be aware that we do not have any control over the content or management of that website.

As a result, we cannot be held responsible for the protection and privacy of any information which you provide whilst visiting such sites as these are not subject to this privacy notice. We recommend that you review the websites privacy policy as a precautionary measure.

For Pat, our sexual health chatbot - accessible at https://www.sexualhealthhertfordshire.clch.nhs.uk/ - one of our main priorities is the privacy of our chatbot visitors. This Privacy Policy document contains types of information that is collected and recorded by Pat and how we use it. 

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at clchig@nhs.net. 

This privacy policy applies only to our online chatbot and is valid for visitors to our website with regards to the information that they shared and/or collected in Pat. We only collect data when you interact with the chatbot. This policy is not applicable to any information collected offline or via channels other than this chatbot.