INTRODUCTION

By law, all organisations that use personal information (personal data) must provide a clear description of how it is used and also provide any related information to ensure the processing is carried out lawfully and fairly. Your GPs main Privacy Notice is available on their website. The additional information provided below describes only the use of your information when you use your GPs online consultation service.

Please ensure you read your GPs main Privacy Notice and if you wish to use their online consultation service here, please also read the supplementary information below:

Your GP Practice has engaged a specialised online consultation supplier which is approved to NHS England technical standards and has gone through stringent scrutiny and achieved all necessary requirements to provide Online Consultations. NHS England, on behalf of your GP, contracts with the supplier and acts as a Joint Controller with your GP for this system. However, NHS England will not receive any of your personal information, so your GP remains responsible for your data and will ensure that any data you provide to use this service is used for online consultation purposes only.

The name of the organisation we have engaged to provide this service is Capri Healthcare Ltd. (v-Consult), which will act as a Processor of your personal data under GDPR.

WHAT IS THE LAWFUL BASIS FOR YOUR GPS ONLINE CONSULTATION SERVICE?

The following legal bases set out in the General Data Protection Regulation (GDPR) and UK Data Protection Act 2018 allow your GP to use your information when you use this online consultation service provided by them:

  1. 1.When using your Personal Information (Personal Data):
    Article 6 (1) (e) of the GDPR, which permits us to process your personal information that is necessary to provide a service which is in the public interest


  2. 2.When using your Sensitive Personal Information (Sensitive Personal Data):
    Article 9(2) (h) of the GDPR which permits us to process your health information which is necessary for the provision of health treatment.
WHAT ARE THE PURPOSES OF THE PROCESSING?

Online consultations allow the GP’s patients to contact the Practice without having to wait on the phone or take time to come into the practice in person especially if a patient is not sure whether they need a face to face consultation. Online consultations enable patients to use a secure online system to ask questions, report symptoms and we can then respond by signposting patients to the right person e.g. a Doctor or to appropriate service or support.

WHAT PERSONAL INFORMATION IS USED?

Because this service is online, your GP’s need to ensure that they continue to provide you with a confidential and high-quality service. To do so, they need to properly identify you, accurately note both your request and their responses. If they were prevented from using this essential information, then they would be unable to provide the service securely and confidentially.

Information which is not needed for the service is not collected by v-Consult.

Your GP uses the following information to identify and deal with your request.

  1. 1.Identity and Contact Information: includes name, date of birth, NHS number(optional), email address and telephone number, postal address. If you have created an NHS login account you will already have verified who you are and you can, if you wish, use those details from your NHS login account to save you time and avoid having to manually enter your details to re-identify yourself to use the Online Consultation service.


  2. 2.Special Categories of Personal Information: your health information such as your symptoms, conditions, medication and other details which are already held in your GP records and / or which you provide through the online consultation process.
DO WE SHARE YOUR PERSONAL INFORMATION? YOUR GP CONTROLS YOUR INFORMATION?

For GP Practices, NHS England confirms that they will only use your information to provide you with health services.

As mentioned earlier, your GP has engaged v-Consult, a specialised organisation to provide this online consultation service on their behalf, so your personal data will be shared with them in order for them to provide this service to you.

If you are advised to seek urgent care, your information will not be shared with other health and care providers.
Whenever your GP shares your information, they will always comply with the law.

WHERE IS YOUR INFORMATION PROCESSED AND STORED?

It is processed and stored within the United Kingdom.

HOW LONG IS YOUR PERSONAL INFORMATION KEPT?

Your GP practice sets the retention periods for your information and instructs v-Consult, their engaged contractor that provides this service on your GP practice’s behalf, to comply with these periods. When your information has been copied to your GP’s own systems then your sensitive information will be deleted by v-Consult. v-Consult retains your contact details (name, email) for up to 6 weeks, in order to facilitate communication relating to the consultation, after which they are automatically deleted.

If you have been advised online to seek urgent care elsewhere, then your information will not be transferred to us and will not be retained after you have read the advice given.

YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

  • Your right of access- You have the right to ask for copies of your personal information


  • Your right to rectification- You have the right to ask to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is complete


  • Your right to erasure- You have the right to ask us to erase your personal information in certain circumstances


  • Your right to restriction of processing- You have the right to ask us to restrict the processing of your information in certain circumstances


  • Your right to object to processing- You have the right to object to the processing of your personal data in certain


  • Your right to data portability- You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances


  • You are not required to pay any charge for exercising your rights. However, we can charge you a “reasonable fee” for the administrative costs of complying with your request if

  • it is manifestly unfounded or excessive; or


  • you request further copies of your data following an initial request.


  • If you make a request, we have within one month to respond to you. If the request is complex or you have submitted a number of requests, we may inform you that we have extended this time period up to a maximum of a further two months. If you wish to make a request please contact us at:

    Compliance Officer

    Name: Capri Healthcare Ltd

    Address: 20 Widney Lane, Solihull, B91 3LS

    Phone Number: 0330 133 4047

    E-mail: security@caprihealthcare.co.uk

    HOW TO COMPLAIN

    We encourage you to bring concerns to our attention if you think that our collection or use of information is unfair, unlawful or misleading. If you wish to make a complaint please contact us in the first instance using the contact details referred to above. You can also complain to the ICO if you are unhappy with how we have used your data.

    ICO – Registration Number ZA543839

    The ICO’s address is:

    Information Commissioner’s Office

    Wycliffe House

    Water Lane, Wilmslow

    Water Lane, Wilmslow

    Helpline number: 0303 123 1113