Who we are and what we do:

We are Integrated Care 24 limited also known as IC24. We are contracted by the NHS to provide local care services. Our services are currently formed of unscheduled Primary Care, Urgent Care services, NHS 111 Services, Pharmacy, GP Led Health Centres and Walk in Centre, Minor Injuries Units, ED support, Roving GP service, Community Nursing, Health and Justice services and Integrated Technology Solutions.

You can find an up to date list of all of our services here: http://www.ic24.org.uk/services/our-current-services/

And more information on whom we are here: http://www.ic24.org.uk/why-ic24/

This means that we are a business partner of the NHS and complete an annual toolkit (a very large and thorough assessment) to ensure we meet the high standards on all things handling data, which we do.

 

Data we collect and have shared with us:

The data that we collect and that is shared with us is needed to enable us to provide you with direct care.

This includes data not only from the call you are placing at the time with our services, but also data you have previously provided, data that we retrieve from the NHS Spine and Summary Care Record and data that is shared with us from your other health providers to ensure you receive a fast and effective integrated service.

We do not hold your full health and care (medical) records as your GP would, but do hold the following:

  •          your name, date of birth, address and contact details
  •          your NHS number, which makes sure your records are linked to you and you alone
  •          details of health conditions and illnesses
  •          medicines and other treatments
  •          records of contact you've previously had with us
  •          voice recordings
  •          Palliative care information

 

NHS 111 online

If you use the NHS 111 online service they will pass your answers and personal details to us as the healthcare service you have selected if you (or the person you are contacting them about), choose to be referred.

By agreeing to NHS 111 online referring you to another healthcare provider you are also agreeing that your data can be forwarded to us so that we can provide care.

For more information on this please see their website: https://111.nhs.uk/Help/Privacy

 

How and why we use your data:

Data Protection law allows us to use your data for specific purposes where we have a legal basis to do so. We have set out the reasons and lawful basis below:

Our main reason:

Providing Healthcare in the public interest on behalf of the NHS

As a Healthcare provider we are performing a task carried out in the public interest on behalf of the NHS. We are subject to statutory duty to collect (process) and to share information about our patients for their direct care.

As most of the information by its very nature of being health related is sensitive personal (special category) data we only use this for medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems.

This includes local administrative tasks which support this purpose such as:

• Waiting list management                    

• Performance against national targets

• Activity monitoring

• Local clinical audit

• Production of datasets to submit for commissioning purposes and national collections.

It also covers instances where we participate in activities with a statutory basis such as responding to a public health emergency. For example we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS).

IC24 record all telephone calls made to our services, these voice recordings are used for clinical negligence procedures, training, audit and quality monitoring purposes. Where non-clinical staffs need to access your data to enable them to investigate a complaint for example, consent will be sought for them to do so.

Your completed notes will be passed onto your GP to ensure continuity of care and ensure that there is a full record of your care held centrally. You are able to object to this sharing of data as we have an obligation to consider the common law duty of confidentiality, however, if we feel that not sharing the data would cause you serious harm we will consider your vital interests. This will be fully explained to you at the end of each period of care.

We are continuously striving to improve our services and your feedback is paramount to this. We do this by sending out patient experience questionnaires to randomly selected patients via mail and text message. We only send a text where we have received consent to do so. For more information please see https://patientexperience.ic24.org.uk/

Secondary uses:

Safeguarding children and vulnerable adults under a task carried out in the public interest.

Personal and health data is collected and shared with appropriate local authorities, other NHS bodies and if necessary the police. This is done to ensure that patients receive the right services at the right time.

We will always be open and honest with patients and their family (where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.

Sharing data where it is necessary for IC24 to comply with a legal obligation by assisting Commissioners.

Commissioners (clinically-led statutory NHS bodies responsible for the planning and commissioning of health care services for their local area) use this data to assess local needs, decide priorities and strategies and then buy services on behalf of the local population from providers such as hospitals, clinics etc to meet the need.

Only the minimum data necessary is shared for each purpose and this is reviewed regularly. Where it is possible to offer a choice over this sharing of data under the common law duty of confidentiality we will make this clear.

Duty of Confidentiality

Everyone working for the NHS is subject to the Common Law Duty of Confidentiality. Information provided in confidence will only be used for the purposes described below, unless there are other circumstances covered by the law. Under the NHS Confidentiality Code of Conduct, all our staff are also required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.

 

Sharing and using data for research purposes in the public and our legitimate interests

IC24 shares data with other NHS bodies and Clinical Commissioning Groups to assist health research for scientific research purposes, statistical purposes to develop and monitor NHS performance. Where data is used for statistical purposes, stringent measures are taken to ensure individual patients cannot be identified. Where it is not sufficient to use anonymised information, personal or sensitive (special category) data will be used, but only for essential NHS purposes. In these circumstances, where it is not practical to obtain your explicit consent, we are informing you through this notice.

Where research is being conducted by IC24 it is in line with our legitimate interests as a business to enable us to be innovative and assist the NHS in creating new systems and services. You will be fully informed and asked for your consent under the common law duty of confidentiality, in these circumstances to proceed.

Organisations with whom we share your personal information

The main people we share you data with are:

-          Your GP practice

-          NHS Digital

-          NHS Pathways

-          NHS England

-          NHS trusts;

o   Your local hospital

o   Other NHS 111 providers

o   Ambulance services

o   Pharmacies

-          Local Clinical Commissioning Groups

 

You will be informed of the exact local service that your data is shared at the time of contact.

 

Your individual rights

The following will explain your rights over your data with IC24.

The right to be informed

You have a right to be informed about the collection and use of your data. This notice is one of the ways that we are informing you but if at any time you wish to have further details on the categories of data we’re processing or the purposes for a specific instance then you have a right to ask for this.

The right of access

You have the right to obtain confirmation that we are processing your personal data and a copy of that data.

This includes the right to ask for supplementary information about the third parties it is shared with, the parties we have collected it from, if any and how long it is stored for.

We will provide you with the information within one month of your request.

You should be aware that in certain circumstances your right to see some details in your health records may be limited in your own interest or where it adversely affects the rights and freedoms of other (e.g. another person’s confidentiality). We will however, tell you if we can’t meet your request for that reason.

If you want to access your health records you should make a written request to the Clinical Governance Team at IC24, Kingston House, The Long Barrow, Orbital Park, Ashford, Kent, TN24 0GP or via email to CG.admin@nhs.net

The right to rectification

You have a right for to have inaccurate personal data rectified, or completed if it is incomplete. You can make a request verbally or in writing and we will respond to you within a month.

The right to erasure

This right is to have personal data erased.

However, where we are processing data for public health purposes in the public interest this right does not apply. You can make a request and we will advise accordingly.

The right to restrict processing

You have the right to request the restriction or suppression of your personal data.

The right to data portability

You have a right to have your data transferred to another service, as we do not currently use online portals we do not have information we can transfer to another service.

The right to object

You have the right to object to the processing of your personal data in certain circumstances. We will adhere to this in circumstances where we do not believe we have a compelling reason for doing so.

You can make an objection verbally or in writing and we have one calendar month to respond to an objection.

 

You have the right to lodge a complaint regarding our use of your data

Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline 0303 123 1113or directed on their website at www.ico.org.uk or via post:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

How secure is the data we collect?

We have physical, electronic, and Information Governance procedures in place to safeguard and secure the information we collect. We have a whole host of manages that take responsibility and are accountable for ensuring that the data we collect and use is done so in a lawful and ethical manner. They ensure that all of the relevant and most up to date security measures are taken to protect the data and question each secondary use regularly.

 

The Information Governance Team, including the Data Protection Officer is a part of this function. We also have an Information Governance Lead, a Caldicott Guardian and a Senior Information Risk Officer (SIRO).

 

With all of the above in place we hope to reduce the possibility of any breaches of data however if you believe your privacy has been breached please contact us immediately on igteam@ic24.nhs.uk

 

For further information see our Security Statement.

 

Retention

IC24 do not transfer or store your data outside the EEA.

IC24 has adopted the retention periods set out in the Records Management Code of Practice for Health and Social Care 2016, Appendix 3. The retention schedule will be reviewed annually or as necessary to reflect changes in law. The retention schedule as set out in the Records Management Code of Practice for Health and Social Care 2016 can be found here: https://digital.nhs.uk/data-and-information/looking-after-information/data-security-and-information-governance/codes-of-practice-for-handling-information-in-health-and-care/records-management-code-of-practice-for-health-and-social-care-2016

 

Last Updated: September 2018