Privacy Notice - Ardens Manager

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As part of our commitment to improving patient care and population health management, this GP practice uses Ardens Manager, a secure clinical analytics platform.

1) Controller contact details	Lee Road Surgery 20 Lee Road London SE3 9RT
2) Data Protection Officer contact details	John Eni-Uwubame South East London Integrated Care System 160 Tooley Street London SE1 2TZ Email: gpdpo@selondonics.nhs.uk Telephone: 02081761198
3) Purpose of the processing	Ardens Manager allows us to securely analyse pseudonymised patient data from our clinical system (EMIS) to: • Identify areas for improving quality of care and outcomes • Monitor performance against national and local indicators (e.g Quality and Outcomes Framework (QOF)) • Support proactive care for at-risk patients • Fulfil our contractual and clinical governance responsibilities What data is shared? • The data processed by Ardens Manager is pseudonymised. This means personal identifiers like your name or NHS number are removed and replaced with codes. The data no longer identifies you, but it can be re-identified by authorised staff within the practice if needed to support your care. • Pseudonymised data may be shared securely with other NHS organisations only for direct care, planning, quality improvement, and assurance purposes, and never for marketing or commercial use. Who can access the data? • Access is limited to authorised staff within the practice and approved roles within our Primary Care Network (PCN) and Integrated Care Board (ICB) who are involved in planning and managing services. • We remain the data controller. Ardens (the data processor) acts on our behalf under a strict Data Processing Agreement and complies with UK GDPR and NHS Digital standards.
4) Lawful basis for processing	We process this data under UK General Data Protection Regulation (GDPR) Article 6(1)(e), the performance of task carried out in public interest. For health data, the condition is Article 9(2)(h), the provision of health and social care.
5) Rights to object	Under the UK GDPR, you have the right to object to your data being processed in this way, that is, used in a pseudonymised form for service planning, performance monitoring, and care improvement via Ardens Manager platform. If you wish to object, please contact the Practice Manager. We will carefully consider your request and assess whether we can reasonably stop processing your data without affecting our ability to deliver safe, effective care or meet our legal obligations. Please note that: • The data used by Ardens Manager is pseudonymised and does not directly identify you. • The processing supports important functions such as identifying gaps in care, reviewing service quality and managing local health needs. • In some cases, we may need to continue using your data where we have a compelling legal or clinical grounds to do so in the public interest. This is different from the NHS National Data Opt-Out which allows you to stop your identifiable information being used for research and planning outside of your direct care. To manage your national preferences, visit www.nhs.uk/your-nhs-data-matters
6) Right to access and correct	The Data Subjects or their legal representatives have the right to access the data that is being processed or shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.
7) Retention period	The data will be retained for active use during and thereafter retained in an inactive stored form according to the law and national guidance
8) Right to Complain.	You have the right to complain to the Information Commissioner’s Office, you can use this link https://ico.org.uk/make-a-complaint/data-protection-complaints/ or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website).