The Data Controller for the clinical data that is collected and processed for the Practitioner Health Matters Programme (PHMP) is its Medical Director, Dr. Íde Delargy.
Dr. Delargy can be contacted at 41 Main Street, Blackrock A94 D5P2, Telephone (01) 278 9369 or firstname.lastname@example.org.
Practice Privacy Statement
The PHMP wants to ensure the highest standard of medical care for our patients. We understand that a medical practice is a trusted community governed by an ethic of privacy and confidentiality. Our approach is consistent with the Medical Council guidelines and the privacy principles of the Data Protection Regulations. It is not possible to undertake medical care without collecting and processing personal data and data concerning health. In fact, to do so would be in breach of the Medical Council’s ‘Guide to Professional Conduct and Ethics for Doctors’. This leaflet is about advising you of our policies and practices on dealing with your medical information.
Legal Basis for Processing Your Data
This Practice has used the ICGP Data Protection Guideline. The processing of personal data in this practice is necessary in order to protect the vital interests of the patient and for the provision of health care and public health. You can access the Guideline at http://www.icgp.ie/data. In most circumstances we hold your data until 8 years after your death or 8 years since your last contact with the practice. There are exceptions to this rule and these are described in the Guideline referenced above.
Managing Your Information
In order to provide for your care, we need to collect and keep information about you and your health on our records.
- We retain your information securely.
- We will only ask for and keep information that is necessary. We will attempt to keep it as accurate and up to-date as possible. We will explain the need for any information we ask for if you are not sure why it is needed.
- We ask you to inform us about any relevant changes that we should know about. This would include such things as any new treatments or investigations being carried out that we are not aware of. Please also inform us of change of address and phone numbers.
- All persons in the practice (not already covered by a professional confidentiality code) sign a confidentiality agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty.
- Access to patient records is regulated to ensure that they are used only to the extent necessary to enable
the secretary or manager to perform their tasks for
the proper functioning of the practice. In this regard, patients should understand that practice staff may have access to their records for:
– Typing referral letters to hospital consultants or allied health professionals such as physiotherapists, occupational therapists, psychologists and dieticians.
– Opening letters from hospitals and consultants and scanning clinical letters or other reports and documents Checking for a patient if a hospital or consultant letter is back or if a laboratory or radiology result is back, in order to schedule a conversation with the GP.
– Handling, printing, photocopying and postage of medico legal and life assurance reports, and of associated documents.
– Sending and receiving information via Healthmail, secure clinical email.
– And other activities related to the support of medical care appropriate for practice support staff.
Disclosure of Information to Other Health and Social Care Professionals
We may need to pass some of this information to other health and social care professionals in order to provide you with the treatment and services you need. We will inform you if at any point we are required to do this. Only the relevant part of your record will be released. These other professionals are also legally bound to treat your information with the same duty of care and confidentiality that we do.
Disclosures Required or Permitted Under Law
The law provides that in certain instances personal information (including health information) can be disclosed, for example, in the case of infectious diseases.
Disclosure of information to Employers, Insurance Companies and Solicitors:
- In general, work-related Medical Certificates from your GP will only provide a confirmation that you are unfit for work with an indication of when you will be fit to resume work. Where it is considered necessary to provide additional information, we will discuss that with you. However, Department of Social Protection sickness certs for work must include the medical reason you are unfit to work.
- In the case of disclosures to insurance companies or requests made by solicitors for your records we will only release the information with your signed consent.
Use of Information for Quality Assurance
We work as a multidisciplinary team and it is usual to discuss patient case histories as part of their continuing medical education and gaining the benefit of other perspectives. In these situations, the identity of the patient concerned will not be revealed.
In other situations, however, it may be beneficial for other doctors within the practice to be aware of patients with particular conditions and in such cases this practice would only communicate the information necessary to provide the highest level of care to the patient.
Use of Information for Clinical Audit
Patient information can sometimes be used for clinical audit purposes in order to improve services and standards of practice. Information used for such purposes is done in an anonymised or pseudonymised manner with all personal identifying information removed.
If it were proposed to use your information in a way where it would not be anonymous or the PHMP was involved in external research, we would discuss with you before we proceeded and seek your written informed consent.
Your Right of Access to Your Health Information
You have the right of access to all the personal information held about you by this practice. If you wish to see your records, in most cases the quickest way is to discuss this with your doctor who will review the information in the record with you. You can make a formal written access request to the practice and receive a copy of your medical records. These will be provided to you within thirty days, without cost.
Transferring to Another Service or Doctor
If you decide at any time and for whatever reason to transfer to another practice, we will facilitate that decision by making available to your new doctor a copy of your records on receipt of your signed consent from your new doctor. For medico-legal reasons we will also retain a copy of your records in this practice for an appropriate period of time which may exceed eight years.
You have other rights under data protection regulations in relation to transfer of data to a third country the right to rectification or erasure, restriction of processing, objection to processing and data portability. Further information on these rights in the context of general practice is described in the Guideline available at http://www.icgp.ie/data. You also have the right to lodge a complaint with the Data Protection Commissioner.
We hope this leaflet has explained any issues that may arise. If you have any questions, please speak to the practice secretary or your doctor.