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Fair Processing Notice Fortune Green Practice 80 Fortune Green Road, London, NW6 1DS Website: www.fortunegreenpractice.nhs.uk Tel: 020 7472 5970/020 3435 5602 FAX: 020 7431 0789 Fair Processing Notice 1. What is this Fair Processing Notice about? Fair Processing is the conditions which have to be met for any activity involving personal data to be lawful. Being transparent and providing accessible information to individuals about how an organisation will use their personal data is a key element of the Data Protection Act 1998 (DPA) and the EU General Data Protection Regulation 2016 (GDPR). The most common way to provide this information is in a Fair Processing Notice (FPN). This FPN is part of our programme to make, data sharing and processing activities meet our obligations transparent. The FPN tells you about information we collect and hold about you, what we do with it, how we keep it secure (confidential), who we might share it with and what your rights are in relation to your information. 2. Who we are We are an NHS Primary Care Organisation governed by NHS England and locally by the Camden Clinical Consortia Group (CCG). 3. What kind of information we use? We use the following types of information/data: Personal data or sensitive personal/special categories of personal data such as: demographics – name, address, date of birth, postcode, NHS number racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, medical/health data, sexual life or sexual orientation data. pseudonymised - about individuals but with identifying details (such as name or NHS number) replaced with a unique code anonymised - about individuals but with identifying details removed aggregated - anonymised information grouped together so that it doesn't identify individuals 4. What do we use your personal data or sensitive personal/special categories of personal data for? We use and share information about you in a number of ways. These include: Primary uses of information from your GP medical record are those making information available to other NHS and public sector organisations, including their doctors, nurses and care professionals for the purpose of direct patient care. Secondary uses of information from your GP medical record involves extracting identifiable data and (usually) sharing that data with other NHS organisations, for the purpose of indirect care. Examples Fortune Green Practice 80 Fortune Green Road, London, NW6 1DS Website: www.fortunegreenpractice.nhs.uk Tel: 020 7472 5970/020 3435 5602 FAX: 020 7431 0789 include using your information for research, audit, healthcare planning, risk “stratification” (Population Health Management). There are some limited exceptions where we may share hold or use personal data or sensitive personal/special categories of personal data about you. For example, where we are required by law to perform certain services that involve the sharing and processing of personal data or sensitive personal/special categories of personal data. In this case, the conditions/legal basis and justification for the processing of your personal data or sensitive personal/special categories of personal data are: Fortune Green Practice 80 Fortune Green Road, London, NW6 1DS Website: www.fortunegreenpractice.nhs.uk Tel: 020 7472 5970/020 3435 5602 FAX: 020 7431 0789 Type Data Protection Act 1998 Data Protection Act 1998 General Data General Data Other Legal Basis and - Schedule 2 - - Schedule 3 - Protection Regulation Protection Regulation Justification - Article 6 - - Article 9 - Continuing Healthcare The processing of personal The processing of sensitive The processing of The processing of Section 251B Health and (CHC) data is permitted under the personal data is permitted personal data is special categories of Social (Safety and following paragraphs: under the following permitted under the personal data is Quality Act) 2015 (Duty to Share) paragraphs: following permitted under the 4 (processing for vital interests paragraphs: following paragraphs: of data subject); 7(1) (b) and/or 7(1) (c) (processing for statutory or (c) (processing for (c) (vital interests); 5(b), 5(c) and/or 5(d) governmental functions) legal obligation); (processing for statutory or (h) (processing for and/or; governmental or public (d) (process for vital medical purposes) functions). 8(1) (processing for medical interests of data and/or; purposes). subject) and/or; (i) (public interest in (e) (public interest or the area of public in the exercise of health). official authority). Supporting Medicines The processing of personal The processing of sensitive The processing of The processing of Section 251B Health and Management data is permitted under the personal data is permitted personal data is special categories of Social (Safety and following paragraphs: under the following permitted under the personal data is Quality Act) 2015 (Duty to Share) paragraphs: following permitted under the 4 (processing for vital interests paragraphs: following paragraphs: of data subject); 7(1) (b) and/or 7(1) (c) (processing for statutory or (c) (processing for (c) (vital interests); 5(b), 5(c) and/or 5(d) governmental functions) legal obligation); (processing for statutory or (h) (processing for and/or; governmental or public (d) (process for vital medical purposes) 8(1) (processing for medical interests of data Fortune Green Practice 80 Fortune Green Road, London, NW6 1DS Website: www.fortunegreenpractice.nhs.uk Tel: 020 7472 5970/020 3435 5602 FAX: 020 7431 0789 functions). purposes). subject) and/or; and/or; (e) (public interest or (i) (public interest in in the exercise of the area of public official authority). health). Integrated Urgent Care The processing of personal The processing of sensitive The processing of The processing of Section 251B Health and Service (IUC) - covering data is permitted under the personal data is permitted personal data is special categories of Social (Safety and Out of Hours and NHS following paragraphs: under the following permitted under the personal data is Quality Act) 2015 (Duty 111 service to Share) paragraphs: following permitted under the 4 (processing for vital interests paragraphs: following paragraphs: of data subject); 7(1) (b) and/or 7(1) (c) (processing for statutory or (c) (processing for (c) (vital interests); 5(b), 5(c) and/or 5(d) governmental functions) legal obligation); (processing for statutory or (h) (processing for and/or; governmental or public (d) (process for vital medical purposes) functions). 8(1) (processing for medical interests of data and/or; purposes). subject) and/or; (i) (public interest in (e) (public interest or the area of public in the exercise of health). official authority). A process where we or The processing of personal The processing of sensitive The processing of The processing of you can request data is permitted under the personal data is permitted personal data is special categories of treatments that is not following paragraphs: under the following permitted under the personal data is routinely funded by the paragraphs: following permitted under the NHS, which are known as 1 (consent); paragraphs: following paragraphs: Individual Funding 1 (consent); 4 (processing for vital interests Requests (c) (processing for of data subject); 7(1) (b) and/or 7(1) (c) legal obligation); (processing for statutory or (c) (vital interests); 5(b), 5(c) and/or 5(d) governmental functions) (d) (process for vital (processing for statutory or (h) (processing for Fortune Green Practice 80 Fortune Green Road, London, NW6 1DS Website: www.fortunegreenpractice.nhs.uk Tel: 020 7472 5970/020 3435 5602 FAX: 020 7431 0789 governmental or public and/or; interests of data medical purposes) functions). subject) and/or; and/or; 8(1) (processing for medical purposes). (e) (public interest or (i) (public interest in in the exercise of the area of public official authority). health). Safeguarding Concerns – The processing of personal The processing of sensitive The processing of The processing of to prevent an individual, data is permitted under the personal data is permitted personal data is special categories of Care Act 2012 or to prevent a serious following paragraphs: under the following permitted under the personal data is crime paragraphs: following permitted under the 4 (processing for vital interests paragraphs: following paragraphs: of data subject); 7(1) (b) and/or 7(1) (c) (processing for statutory or (c) (processing for (c) (vital interests); 5(b), 5(c) and/or 5(d) governmental functions) legal obligation); (processing for statutory or (h) (processing for and/or; governmental or public (d) (process for vital medical purposes) functions). 8(1) (processing for medical interests of data and/or; purposes). subject) and/or; (i) (public interest in (e) (public interest or the area of public in the exercise of health). official authority). Camden Primary Care The processing of personal The processing of sensitive The processing of The processing of Section 251B Health and Services (GP Practices) data is permitted under the personal data is permitted personal data is special categories of Social (Safety and delivering local care following paragraphs: under the following permitted under the personal data is Quality Act) 2015 (Duty service to Share) paragraphs: following permitted under the 4 (processing for vital interests paragraphs: following paragraphs: of data subject); 7(1) (b) and/or 7(1) (c)
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