Privacy Policy – Your Data

How we use your personal information

In order to comply with data protection legislation, this notice has been designed to inform you of what you need to know about the personal information we process. This is your assurance that we are complying with our legal obligation to you and a good opportunity for you to understand or exercise your information rights. 

We are legally required to tell you:

  • What personal information we use
  • Why we need your personal information
  • The lawful basis for processing your personal information i.e. legitimate reasons for collecting, keeping, using and sharing it
  • How we use, store, protect and dispose of your personal information
  • How long we keep it for and who we may share it with
  • About your information rights 
  • How to report a complaint or concern

Your Personal Information

When we say personal information, we are referring to any information that can identify a specific person, either on its own or together with other information. The obvious examples are name, address and date of birth; however this could include other forms for data, such as email address, car registration, specific physical feature, NHS number, pictures, images and so forth.  

Most of the personal information we process is confidential or sensitive because of the nature of our business activities (health and social care). This could be used in a discriminatory way and is likely to be of a private nature, so greater care is needed to ensure this is processed securely. Confidential or sensitive information includes the racial or ethnic origin of the data subject, political opinions, religious beliefs or other beliefs of a similar nature, Trade Union membership, physical or mental health or condition, sexual life, commission, alleged commission of or proceeding for any offence.

Anonymised data is not personal information. This is any information that cannot reasonably identify you, so it cannot be personal, confidential or sensitive. Anonymisation requires the removal of personal information that might identify you.

The personal information we collect may be used for any of the following specific purposes: 
  • Health care for patients – diagnosis, treatment and referral
  • Accounting, financial management and auditing
  • Education and training
  • Consultancy and Advisory services
  • Human resources and staff administration
  • Crime prevention and prosecution 
  • Health administration and services management
  • Business activity information and databank administration
  • Contractual arrangements for data processing by third parties 
  • Occupational Health referrals
  • Research, national surveys
  • Security services e.g CCTV monitoring, confidentiality audits
Without your personal information, we cannot:
  • Direct, manage and deliver the health care you may require 
  • Ensure we have accurate and up to date information to assess and provide what you require
  • Provide the appropriate level of assistance or adequate guidance
  • Refer you to a specialist or another service
  • Protect the general public or promote public health
  • Manage, develop or improve our services
  • Investigate complaints or proceed with legal actions for claims
  • Employ you to join our workforce
  • Procure products and services
  • Commission business activities
  • Comply with a court order
  • Comply with regulatory requirements
  • Meet some of our legal obligations
  • Compile statistics to review our performance
  • Educate and train our workforce
  • Undertake clinical trials and research studies you have consented to
  • Complete occupational health checks you have consented to
  • Keep you and other service users safe on our premises

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

  • Data Protection Act 2018 (GDPR)
  • Human Rights Act 1998
  • Common Law Duty of Confidentiality
  • Health and Social Care Act 2012
  • NHS Codes of Confidentiality
  • Information, Security and Records Management
  • Information: To Share or Not to Share Review

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential. We will only ever use or pass on information about you if others involved in your care have a genuine need for it.

We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on. Health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;

  • NHS Trusts / Foundation Trusts,
  • GPs (When you change GP practices)
  • NHS Commissioning Support Units
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Clinical Commissioning Groups
  • Social Care Services
  • Health and Social Care Information Centre (HSCIC)
  • Local Authorities
  • Education Services
  • Fire and Rescue Services
  • Police and Judicial Services
  • Voluntary Sector Providers
  • Private Sector Providers
  • Other ‘data processors’ which you will be informed of

You will be informed who your data will be shared with and in some cases asked for explicit consent for this to happen when this is required.

We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to protect your data.

Access to personal information

You have a right under the Data Protection Act 2018 (GDPR) to access/view information the Practice holds about you, and to have it amended or removed should it be inaccurate. This is known as ‘the right of subject accesses’. If we hold information about you we will give you a description of it; tell you why we are holding it; tell you who it could be disclosed to; and, let you have a copy of the information in an intelligible form.

If you would like to make a ‘subject access request’ please contact the practice manager in writing. You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located. You will also need to complete a Subject Access Request form.

Change of details

It is important that you tell the Practice if any of your details such as your name or address have 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 accurate and up to date for you.

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential is: Merton Medical Practice. Any changes to this notice will be published on our website and on the Practice notice board. The Practice is registered as a data controller under the Data Protection Act 2017 and is compliant to the General Data Protection Regulation. The registration number is and can be viewed online in the public register at www.ico.org.uk.

Objections / complaints

Should you have any concerns about how your information is managed at the Practice, please contact the practice manager. If you are still unhappy following a review by us, you can then complain to the Information Commissioners Office (ICO). They are the Regulator for the Data Protection Act 2018 and offer independent advice and guidance on the law and personal data, including your rights and how to access your personal information). If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything.

The practice is also required to report any breeches of confidentiality to the ICO.

Last reviewed on 16/04/2024

Review due on 01/04/2025