Practice Policies & Patient Information
Care Quality Commission Declarations Statement of Purpose
Changes to Data Storage System
Emis moving to Amazon Warehousing system for data storage
A data processor acting on our behalf, EMIS Health, is changing certain technical aspects of the way in which it delivers services to us, and as part of this transition it will be moving the data which it hosts on our behalf from its own data centre to a third party data centre, which is owned and operated by Amazon Web Services (AWS).
Delivery of the services is subject to the terms of the GP Systems of Choice Framework (GPSOC) which is managed by NHS Digital on behalf of the Secretary of State for Health.
The exercise will involve a change to the manner in which data is being processed on our behalf. Although this change does not introduce processing that is likely to result in a high risk to individuals (which would necessitate the undertaking of a DPIA), given that the data includes special category data we nevertheless feel that it is appropriate that we undertake a review.
As detailed above, the data (which includes special category data (i.e. health data) which is collected via the processor’s clinical IT system and which forms the patient’s medical record) will be stored in a third party data centre (which will act on the instructions of EMIS Health, who in turn will act in accordance with instructions received from (or on behalf of) ourselves as the relevant controller pursuant to our call off contract under the GPSOC framework or as otherwise documented).
Aside from the manner in which the data is being hosted, we have not identified, as part of this change, any material change to the manner in which the data is being processed (in terms of data sharing and/or use).
The scope of the data processing is as detailed in the relevant GP Systems of Choice contract (and related call off contract (and deed of undertaking)) or as otherwise agreed in writing between EMIS Health and ourselves.
As noted above, aside from the hosting element the manner in which the data is being used or otherwise processed will not materially change as a result of this change.
Complaints
In the first instance please discuss your complaint with the member of staff concerned. Where the matter cannot be solved at this stage, please ask to speak to one of our reception supervisors who will try to resolve the issue and offer you further advice on the complaints procedure. Depending on the issue, the reception supervisor may then pass your details to Alison Morden (Reception Manager) or Alahna Canning (Admin Manager) who will contact you to discuss your complaint.
If your complaint still cannot be resolved at this stage and you wish to make a formal complaint, please let us know as soon as possible, ideally within a matter of days. This will enable the practice to get a clear picture of the circumstances surrounding the complaint.
If it is not possible to raise your complaint immediately, please let us have details of your complaint within the following timescales:
- Within 12 months of the incident that caused the problem
OR
- Within 12 months of when the complaint comes to your notice
The practice will acknowledge your complaint with three working days. The practice may arrange a meeting with you to discuss the complaint, to agree with you how the complaint is going to be investigated and the timescale for this to be completed. When the practice looks into your complaint it aims to:
- Ascertain the full circumstances of the complaint.
- Make arrangements for you to discuss the problem with those concerned, if you would like this.
- Make sure you receive an apology, where this is appropriate.
- Identify what the practice can do to make sure the problem does not happen again.
Formal complaints must be submitted in writing. You can either write a letter yourself, obtain a complaints form from reception, print off the complaints form attached here or fill in the form below.
Complaining on behalf of someone else
Please note that the practice keeps strictly to the rules of medical confidentiality. If you are complaining on behalf of someone else, the practice needs to know that you have their permission to do so. A note signed by the person concerned will be required, unless they are incapable of providing this due to illness or disability.
Complaining to other authorities
The practice management team hope that if you have a problem with the service you have received, that you will use the practice complaints procedure. However, if you feel you cannot raise you complaint with us, you contact either of the following 2 official bodies:
NHS England Lancashire Local Area Team on 01772 214127 or email [email protected]
NHS England, PO Box 16738, Redditch, B97 9PT [email protected] – FAO The Complaints Manager.
0300 311 22 33 – Mon – Fri 8am to 6pm
Contacting the Care Quality Commission (CQC)
If you have a genuine concern about a staff member or regulated activity carried out by this practice then you can contact the Care Quality Commission on 03000 616161, or alternatively visit the following website: www.cqc.org.uk/contact-us
ICAS and Ombudsman
Advocacy service for NHS complaints
This is a national service that supports people who want to make a complaint about their NHS care or treatment. Your local service can be found on:
Independent Complaints Advocacy Service (ICAS) can be contacted on 0300 456 8350.
Ombudsman
If you have not received a satisfactory response from this practice, your local Clinical Commissioning Group, or NHS England, you can then refer your complaint to the Parliamentary and Health Service Ombudsman who investigates complaints about the NHS in England.
You can call the Ombudsman’s Complaints Helpline on 0345 015 4033 or visit www.ombudsman.org.uk Textphone (Minicom): 0300 061 4298
Confidentiality, Data Protection & GDPR
We respect your right to privacy and keep all your health information confidential and secure. It is important that the NHS keeps accurate and up-to-date records about your health and treatment so that those treating you can give you the best possible advice and care. This information is only available to those involved in your care and you should never be asked for personal medical information by anyone not involved in your care.
You have a right to know what information we hold about you. If you would like to see your records or require a copy, please view our Access to Medical Records policy (click the link below) and complete the appropriate form.
From 25th May 2018 the law is changed with the addition of the General Data Protection Regulation (GDPR). This regulation had an impact on how we handle your data. Further information can be found on General Data Protection Regulation (GDPR) – Official Legal Text (gdpr-info.eu) or in the following privacy notices & policies:
GP Net Earnings
All GP practices are required to declare the mean earnings (e.g. average pay) for GPs working to deliver NHS services to patients at each practice.
The average pay for GPs working in Adelaide Street Surgery in the last financial year was £103,866 before tax and National Insurance. This is for 3 full time GPs, 1 part time GP and 6 long term locums who worked in the practice for more than six months.
Disclaimer
NHS England require that the net earnings of doctors engaged in the practice is published, and the required disclosure is shown above. However it should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time doctors spend working in the practice, and should not be used to form any judgement about GP earnings, nor to make any comparison with any other practice.
How Adelaide Street Surgery implements the NHS Constitution
Principles
The Practice:
* Provides a comprehensive service, available to all irrespective of gender, race, disability, age, sexual orientation, religion, belief, gender reassignment, pregnancy and maternity or marital or civil partnership status, and has a duty to respect their human rights.
* Promotes equality through the service, providing and to paying particular attention to groups or sections of society where improvements in health and life expectancy are not keeping pace with the rest of the population.
* Provides access to services based on clinical need, not on an individual’s ability to pay.
* Aspires to the highest standards of excellence and professionalism, providing safe and effective high-quality care focused on patient experience.
* Ensures that it is effectively lead and managed and its staff receive relevant education, training and development.
* Its services reflect the needs and preferences of patients, their families and carers who will be involved in and consulted on all decisions about their care and treatment.
* Ensures that it works across organisational boundaries and in partnership with other organisations in the interest of patients, local communities and the wider population.
* Is accountable to the public, communities and patients that it serves.
* Supports staff when they raise concerns about the service by ensuring their concerns are fully investigated and that there is someone independent, outside of their team, to speak to.
Patient Rights
Patients have the right:
* To receive NHS services free of charge, apart from certain limited exceptions sanctioned by Parliament.
* To access NHS services and not be refused access on unreasonable grounds.
* To expect the Practice to assess the health requirements of the local community and to commission and put in place the services to meet those needs as considered necessary.
*In certain circumstances to go to other European Economic Area countries or Switzerland for treatment which would be available through the NHS.
*Not to be unlawfully discriminated against in the provision of NHS services including on grounds of gender, race, disability, age, sexual orientation, religion, belief, gender reassignment, pregnancy and maternity or marital or civil partnership status.
* To access services within maximum waiting times, or to be offered a range of alternative providers if this is not possible.
* To be treated with a professional standard of care, by appropriately qualified and experienced staff, in a properly approved or registered organisation that meets required levels of safety and quality.
* To be treated with dignity and respect, in accordance with their human rights.
* To accept or refuse treatment that is offered, and not to be given any physical examination or treatment unless valid consent has been given.
* To be given information about their proposed treatment in advance, including any significant risks and any alternative treatments which may be available, and the risks involved in doing nothing.
* To privacy and confidentiality and to expect the Practice to keep their confidential information safe and secure.
* To access their own health records.
* To choose their GP practice, and to be accepted by that Practice unless there are reasonable grounds to refuse, in which case they will be informed of those reasons.
* To express a preference for using a particular doctor within their GP Practice.
* To make choices about their NHS care and to information to support these choices.
* To be involved in discussions and decisions about their healthcare, and to be given information to enable them to do this.
* To be involved, directly or through representatives, in the planning of healthcare services, the development and consideration of proposals for changes in the way those services are provided, and in decisions to be made affecting the operation of those services.
* To have any complaint they make about NHS services dealt with efficiently, to have it properly investigated, know the outcome and how to escalate the complaint to the independent Health Service Ombudsman.
* To make a claim for judicial review if they think they have been directly affected by an unlawful act or decision of an NHS body.
* To compensation where they have been harmed by negligent treatment.
Patient Responsibilities
* To make a significant contribution to their own, and their family’s, good health and well-being, and take some personal responsibility for it.
* Register with a GP Practice.
* To treat NHS staff and other patients with respect and recognise that causing a nuisance or disturbance on NHS premises could result in prosecution.
* To provide accurate information about their health, condition and status.
* To keep appointments, or cancel within reasonable time.
* To follow the course of treatment which they have agreed, and talk to their clinician if they find this difficult.
* To participate in important public health programmes such as vaccination.
* To ensure that those closest to them are aware of their wishes about organ donation.
* To give feedback – both positive and negative – about the treatment and care they have received, including any adverse reactions they may have had.
Practice Staff Rights
Practice Staff have the right:
* To a good working environment with flexible working opportunities, consistent with the needs of patients and with the way that people live their lives.
* To have a fair pay and contract framework;
* To be involved and represented in the workplace;
* To have healthy and safe working conditions and an environment free from harassment, bullying or violence;
* To be treated fairly, equally and free from discrimination; and
* To raise an internal grievance and if necessary seek redress, where it is felt that a right has not been upheld;
* To raise any concern with their employer, whether it is about safety, malpractice or other risk, in the public interest, without suffering any detriment.
NHS Pledge to Staff Members
The NHS Commits:
* To provide a positive working environment for staff and to promote supportive, open cultures that help staff do their job to the best of their ability;
* To provide all staff with clear roles and responsibilities and rewarding jobs for teams and individuals that make a difference to patients, their families and carers and communities;
* To provide all staff with personal development, access to appropriate training for their jobs and line management support to succeed;
* To provide support and opportunities for staff to maintain their health, well-being and safety;
* To engage staff in decisions that affect them and the services they provide, individually, through representative organisations and through local partnership working arrangements. All staff will be empowered to put forward ways to deliver better and safer services for patients and their families;
* To have a process for staff to raise an internal grievance;
* To support all staff in raising concerns at the earliest reasonable opportunity about safety, malpractice or wrongdoing at work, responding to and, where necessary, investigating the concerns raised and acting consistently with the Public Interest Disclosure Act 1998.
Practice Staff have the duty:
* To accept professional accountability and maintain the standards of professional practice as set by the appropriate regulatory body applicable to their profession or role.
* To take reasonable care of health and safety at work for themselves, their team and others, and to co-operate with employers to ensure compliance with health and safety requirements.
* To act in accordance with the express and implied terms of their contract of employment.
* Not to discriminate against patients or staff and to adhere to equal opportunities and equality and human rights legislation.
* To protect the confidentiality of personal information that they hold unless to do so would put anyone at risk of significant harm.
* To be honest and truthful in applying for a job and in carrying out that job.
* To play their part in ensuring the success of the NHS and delivering high-quality care by:
– Maintaining the highest standards of care and service, taking responsibility not only for the care they personally provide, but also for their wider contribution to the aims of their team and the NHS as a whole.
– Taking up training and development opportunities provided over and above those legally required of their particular post.
– Actively taking part in sustainably improving services by working in partnership with patients, the public and communities.
– Raising any genuine concern they may have about a risk, malpractice or wrongdoing at work (such as a risk to patient safety, fraud or breaches of patient confidentiality), which may affect patients, the public, other staff or the Practice itself, at the earliest reasonable opportunity.
– Involving patients, their families, carers or representatives fully in decisions about prevention, diagnosis, and their individual care and treatment.
– Being open with patients, their families, carers or representatives, including if anything goes wrong; welcoming and listening to feedback and addressing concerns promptly and in a spirit of co-operation.
– Contributing to a climate where the truth can be heard, the reporting of, and learning from errors is encouraged and colleagues are supported where errors are made.
– Viewing the services they provide from the standpoint of a patient, and involve patients, their families and carers in the services they provide, working with them, their communities and other organisations, and making it clear who is responsible for their care.
– To take every appropriate opportunity to encourage and support patients and colleagues to improve their health and well-being.
– To contribute towards providing fair and equitable services for all and play your part, wherever possible, in helping to reduce inequalities in experience, access or outcomes between differing groups or sections of society requiring health care.
– To inform patients about the use of their confidential information and to record their objections, consent or dissent.
– To provide access to a patient’s information to other relevant professionals, always doing so securely, and only where there is a legal and appropriate basis to do so.
National Data Opt-Out
Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment.
The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
- improving the quality and standards of care provided
- research into the development of new treatment
- preventing illness and diseases
- monitoring safety
- planning services
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care.
To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:
- See what is meant by confidential patient information
- Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
- Find out more about the benefits of sharing data
- Understand more about who uses the data
- Find out how your data is protected
- Be able to access the system to view, set or change your opt-out setting
- Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
- See the situations where the opt-out will not apply
You can also find out more about how patient information is used at:
https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and
https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)
You can change your mind about your choice at any time.
Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.
Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care. Our organisation is not currently compliant with the national data opt-out policy due to our clinical system not currently having the correct functionality.
Practice Charter
The care of your health is a partnership between yourself and the primary health care team. The success of that partnership depends on an understanding of each other’s needs and co-operation between us.
Our Responsibility To You:
- You will be greeted courteously.
- You have a right to confidentiality.
- You have the right to see your medical records subject to the limitations of the law.
- You will be seen the same day if your problem is urgent.
- You will be seen by your own doctor whenever possible.
- You will be informed if there will be a delay of more than 20 minutes for your appointment.
- You will be referred to a consultant when your GP thinks it necessary.
- You will be given the result of any test or investigation on request or at your next appointment.
- Your repeat prescription will normally be ready for collection within 48 hours of your request.
- Your suggestions and comments about the services offered will be considered sympathetically and any complaint dealt with quickly.
Your Responsibility To Us:
- Please treat all surgery staff with the same respect – we are all just doing our job.
- Do not ask for information about anyone other than yourself.
- Tell us of any change of name or address, so that our records are accurate.
- Only request an urgent appointment if appropriate.
- Home visits should only be requested if you are really too ill to attend surgery, and night visits should be for emergencies only.
- Please cancel your appointment if you are unable to attend.
- Please be punctual, but be prepared to wait if your own consultation is delayed by an unexpected emergency.
- Please allow sufficient time for your consultant’s letter or the results of any tests to reach us.
- Use the tear-off slip to request your repeat prescription whenever possible.
- Please attend for review, when asked, before your next prescription is due.
- We would, of course, be pleased to hear when you feel praise is due as well.
Privacy Notices
Please find below all our neccessary Privacy Notices:
Privacy Notice – Waiting Room Poster
Privacy Notice – Summary Care Record
Privacy Notice – Risk Stratification
GDPR – Subject Access Requests
Zero Tolerance Policy
As an employer, the practice has a duty to care for the health and safety of its staff. The practice also has a legal responsibility to provide a safe and secure working environment for staff. All patients are expected to behave in an acceptable manner and violent or abusive behaviour towards staff or patients may result in removal from our practice list or even criminal proceedings. The practice follows the NHS guidance concerning Zero Tolerance.
The Practice has a policy of “zero tolerance” of verbal and physical violence towards GP’s, staff or other patients.
The practice will request the removal of any patient from the practice list who is aggressive or abusive towards a doctor, member of staff, other patient, or who damages property.
All instances of actual physical abuse on any doctor or member of staff, by a patient or their relatives will be reported to the police as an assault.
We expect all patients to be responsible and avoid attending the surgery under the influence of alcohol or illegal drugs. Any alteration of prescriptions is illegal and will not be tolerated.
If you are seriously unhappy with the quality of service you have the right to register with another practice without notifying us. Similarly, on the very rare occasions when a patient repeatedly ignores their responsibilities to the Practice, we have the right to remove the patient from our Practice list.
Examples of Unacceptable Standards of Behaviour
- Violence.
- Excessive noise e.g. recurrent loud or intrusive conversation or shouting.
- Threatening or abusive language involving swearing or offence remarks.
- Derogatory racial or sexual remarks.
- Malicious allegations relating to members of staff, other patients or visitors.
- Offensive sexual gestures or behaviours.
- Abusing alcohol or drugs on practice premises.
- Drug dealing on practice premises.
- Wilful damage to practice property.
- Threats or threatening behaviour.
- Theft
Our Staff have the right to be treated with dignity and respect at all times.
They should be able to do their jobs without being PHYSICALLY or VERBALLY ABUSED.
The vast majority of our lovely patients respect this.
Anyone found abusing the staff in person or on the telephone will be asked to leave the practice.
This behaviour will NOT be tolerated.