Privacy Notice - Public Health

 

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Public health encompasses everything from national smoking and alcohol policies, the management of epidemics such as flu, the control of large-scale infections such as TB and Hepatitis B to local outbreaks of food poisoning or Measles. Public Health England (PHE) monitors the numbers of certain infections that occur in healthcare settings through routine surveillance programmes and advises on how to prevent and control infection in establishments such as hospitals, care homes and schools. 

In order to allow PHE to carry out accurate monitoring of infections, it may rely on information held by the Practice with regards to Healthcare Acquired Infections (HCAIs). 

This will necessarily mean the subjects personal and health information being shared with the Public Health organisations.
 
Some of the relevant legislation includes: 

Health Protection (Notification) Regulations 2010 (SI 2010/659) 
Health Protection (Local Authority Powers) Regulations 2010 (SI 2010/657) 
Health Protection (Part 2A Orders) Regulations 2010 (SI 2010/658) 
Public Health (Control of Disease) Act 1984 
Public Health (Infectious Diseases) Regulations 1988 and 
The Health Service (Control of Patient Information) Regulations 2002

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 There are occasions when medical data needs to be shared with Public Health England, the Local Authority Director of Public Health, or the Health Protection Agency, either under a legal obligation or for reasons of public interest or their equivalents in the devolved nations.
4) Lawful basis for processing

The legal bases will be under UK GDPR:
Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject” 
and 
Article 9(2)(i) “processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices,..” 
5) Recipient or categories of recipients of the shared data  

The data will be shared with Public Health England https://www.gov.uk/government/organisations/public-health-england and other bodies as appropriate.
6) Rights to object 

You have the right under Article 21 of the GDPR to object to your personal information being processed. Please contact the Practice if you wish to object to the processing of your data. You should be aware that this is a right to raise an objection which is not the same as having an absolute right to have your wishes granted in every circumstance.

Patients may not opt out of having their personal information shared for Public Health Reasons.
7) Right to access and correct

You have the right to access copies of your data we hold and have any inaccuracies corrected. 

There is no right to have accurate medical records deleted except when ordered by a Court of Law.
8) Retention period 

The data will be retained for active use during the period of the public interest and according to legal requirements and the UK Health Security Agency criteria on storing identifiable data. 

https://www.gov.uk/government/organisations/uk-health-security-agency 
9)  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).