PRIVACY NOTICE - Last Updated March 2026
We are committed to protecting your privacy. You can access our website without giving us any information about yourself. But sometimes we do need information to provide services that you request, and this statement of privacy explains data collection and use in those situations.
In general, you can visit our web site without telling us who you are and without revealing any information about yourself. However there may be occasions when you choose to give us personal information, for example, when you choose to contact us or request information from us. We will ask you when we need information that personally identifies you or allows us to contact you.
From April 2026 the DPO is
Dan Clement
Associate Director of Information Governance – Kent and Medway ICB
NHS Kent and Meway, 2nd Floor, Gail House, Lower Stone Street, Maidstone, ME15 6NB
01634 335095
Fair Processing Notice (Privacy Notice)
Your Personal Information – what you need to know
This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.
Why we collect information about you?
Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare and help us to protect your safety.
We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form
Our Commitment to Data Privacy and Confidentiality Issues
As a GP practice, all our staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation. This includes the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful. In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.
Data we collect about you
Records which this GP Practice will hold or share about you will include the following:
· Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
· Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a persons sex life or sexual orientation.
· Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.
· Pseudonymised - The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
· Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place
· Aggregated - Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.
How we use your information
Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care. For example, it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing at Appendix A.
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 treatments
• 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 when 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.
A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.
How long do we hold information for?
All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for Health and Social Care 2016.
Individuals Rights under GDPR
Under GDPR 2016 the Law provides the following rights for individuals. The NHS uphold these rights in several ways.
1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure (not an absolute right) only applies in certain circumstances
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.
Third party processes
To deliver the best possible service, the practice will use carefully selected third party service providers. When we use a third party service provider to process data on our behalf, we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share the information other than in accordance with our instructions and that they operate securely.
Examples of functions that may be carried out by third parties include companies that provide.
· IT services and support, including our clinical systems,
· systems which manage patient facing services (e.g. our website)
· Data hosting service providers,
· Systems which facilitate appointment bookings, electronic prescription services,
· Document management service
· Your right to opt out of data sharing and processing
· The NHS Constitution states, ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’.
Type 1 Opt Out
This is an objection that prevents an individual's personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If patients wish to apply a Type 1 Opt Out to their record, they should make their wishes know to the practice manager.
National data opt-out
The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs. By 2020 all health and care organisations were required to apply national data opt-outs where confidential patient information is used for research and planning purposes. NHS Digital has been applying national data opt-outs since 25 May 2018. Public Health England has been applying national data opt-outs since September 2018.
The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to National data opt out programme
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
Right of Access to your information (Subject Access Request) Under Data Protection Legislation
Everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access, and you may find information has been redacted or removed for the following reasons.
· Does not cause harm to the patient
· That legal confidentiality obligations for the non-disclosure of third-party information are adhered to
You do not need to give a reason to see your data. And requests can be made verbally or in writing. Although we may ask you to complete a form in order that we can ensure that you have the correct information you require. Where multiple copies of the same information is requested, the surgery may charge a reasonable fee for the extra copies. You will need to provide proof of identity to receive this information.
Change of Detail
It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error. Mobile telephone number If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile. Where you have provided us with your email address, with your consent we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email, please let us know.
Notification
Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.
We are registered as a Data Controller, and our registration can be viewed online http://ico.org.uk/what_we_cover/register_of_data_controllers
Any changes to this notice will be published on our website.
What is the right to know?
The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However, you can request this under a right of access request – see section above ‘Access to your information’.
Right to Complain
If you have concerns or are unhappy about any of our services, please contact the Practice Manager at practicemanager.thewallhouse@nhs.net
For independent advice about data protection, privacy and data-sharing issues, you can contact:
The Information Commissioner Wycliffe House
Water Lane Wilmslow Cheshire SK9 5AF
Phone: 0303 123 1113 Website: https://ico.org.uk/global/contact-us
The NHS Care Record Guarantee
The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, and how data is protected under Data Protection Legislation. http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf
The NHS Constitution
The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong. https://www.gov.uk/government/publications/the-nhs-constitution-for-england
Appendix A
The practice will share your information with these organisations where there is legal basis to do so:
Surrey Heartlands ICB
Purpose – Anonymous data is used by the ICB for planning and performance as directed in the practices contract.
Legal Basis – Contractual
Authorised healthcare staff involved in your direct care
Including – Clinical staff in secondary care, urgent care centre staff, SEACAMB, out of hours services and anyone that uses an NHS Smartcard to access their clinical system.
Key details about who can see your SCR:
- Permission: Staff must ask for patient permission to view the SCR, except in emergencies (e.g., if the patient is unconscious).
- Purpose: The record is only viewed to provide safer, direct care, such as accessing medication or allergy information.
- Security: Every access is logged, and patients can request a record of who has accessed their file (a Subject Access Request).
- Access Areas: Authorized staff in various NHS settings, including community pharmacies and 111 services, can access this information, says Community Pharmacy England
Legal Basis – Direct Care
The relevant COPI notice states that its purpose: “…is to require organisations to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose).
“Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential
patient information under Regulation 3(3) of COPI.”
Full details of the Summary Care Record supplementary privacy notice can be found here
Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that by opting out of having your information shared with the Summary Care Record could result in a delay care that may be required in an emergency.
NHS England and NHS Digital via GP connect
Research
Purpose – We many share personal confidential or anonymous information with research companies. Where you have opted out of having your identifiable information shared for this purpose your information will be removed.
Legal Basis – consent is required to share confidential patient information for research, unless there is have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales
Accurx
Software to enable the practice to communicate with each other and pateitns. Accurx support online consultations and is the platform that is used when you submit online requests to the practice. Please see their privacy policy here https://www.accurx.com/privacy-notice
Legal Basis - consent is required to share confidential patient information for research, unless there is have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales
Abtrace
Purpose: Abtrace CDSS is a Clinical Decision Support System in the form of software, which analyses clinical data within primary care electronic health records to improve clinical care of patients.
Legal Basis:
Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’
Article 9(2)(h) ‘… the provision of health or social care or treatment of management of health or social care systems…’
Please see the privacy policy for abtrace here:
https://www.abtrace.com/privacy-policy
NHS Surrey Heartlands Safeguarding Team
Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns. We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns.
Legal Basis - Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.
NHS Surrey Heartlands
Risk Stratification – Preventative Care
Purpose - ‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.
Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health.
If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.
Legal Basis
GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to
the end of September 2020 NHS England Risk Stratification which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.
Public Health Screening programmes (identifiable) Notifiable disease information (identifiable) Smoking cessation (anonymous) Sexual health (anonymous)
Purpose – Personal identifiable and anonymous data is shared.
The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.
More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes
Legal Basis - Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Care Quality Commission
Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.
You can find more details Privacy statement - Care Quality Commission
Legal Basis - Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below
Payments, Invoice validation
NHS Surrey Heartlands and Surrey County Council
Primary Care Support England
Calculating Quality Reporting Service
Purpose - Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amounts paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non-patient related elements such as premises. Finally, there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. To make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.
Legal Basis - Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below
https://pcse.england.nhs.uk/privacy-notice
https://digital.nhs.uk/about-nhs-digital/privacy-and-cookies
https://www.surreycc.gov.uk/council-and-democracy/your-privacy/our-privacy-notices
https://www.surreyheartlands.org/privacy-notice-nhs-surrey-heartlands-icb
IGPR
Purpose – iGPR (Intelligent General Practice Reporting) is an NHS Digital-accredited software used by UK GP practices to securely process medical reports, Subject Access Requests (SARs), and insurance reports. It automates data redaction, ensures GDPR compliance, and facilitates electronic sharing of patient records, making the process faster and more secure
Legal Basis Health data needs an additional condition:
- Article 9(2)(h)
→ Processing for “the provision of health or social care or treatment” - Article 9(2)(g) (with DPA 2018 support)
→ Substantial public interest (e.g., insurance or legal reports where appropriate safeguards exist)
NHS South, Central and West Commissioning Support Unit – Child Health Information Services (CHIS)
Purpose – South, Central and West Child Health Information Services (SCW CHIS) is commissioned by NHS England to support the monitoring of care delivered to children. Personal data is collected from the child’s GP record to enable health screening, physical examination and vaccination services to be monitored to ensure that every child has access to all relevant health interventions.
For more information: Fair Processing Notice Child Health Information Services - NHS SCW Support and Transformation for Health and Care (scwcsu.nhs.uk)
Legal Basis – Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and Article
9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services...”
Processor – SCW, Apollo Medical Software Solutions, System C
Neighbourhood Navigators / Social Prescribing Service
Joy Connect Social Prescribing
Purpose – the purpose of this service is to improve the efficiency of social prescribing and care navigation, to improve the mental health and wellbeing of patients by connecting them to local interventions such as exercise groups and activities.
Legal Basis
Article 6(1)(e) ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
Article 9 (2) (h) ‘processing is necessary for the purposes of preventive or occupational medicine.. the provision of health or social care or treatment or the management of health or social care systems and services’Controllers – the Practice and First Community Health & Care (see Home | First Community Health & Care) are joint data controllers of the personal data processed for this service
Processors are Pungo Limited trading as Joy which provide the ICT system used to process data for these services.
Quantamloop
We use an AI-powered virtual receptionist system provided by Quantum Loop (known as “Emma”) to support our administrative and patient communication services.
Purpose of processing
The system is used to:
- Handle patient enquiries (e.g. appointment requests, general queries)
- Direct patients to appropriate services
- Improve access to the practice and reduce waiting times
- Support administrative efficiency within the practice
The system may process personal data such as your name, contact details, and limited information relating to your enquiry.
Legal basis for processing
We process your personal data using this system under:
- Article 6(1)(e) UK GDPR – Public task
Processing is necessary for the performance of a task carried out in the public interest, namely the provision of NHS primary care services. - Article 9(2)(h) UK GDPR – Health or social care purposes
Where health information is involved, processing is necessary for the provision and management of health care services.
Data processor
Quantum Loop acts as a data processor on behalf of the practice. We have a Data Processing Agreement in place to ensure your data is handled securely and in accordance with UK data protection law.
Data protection and confidentiality
All data processed via the AI receptionist is subject to strict confidentiality and security measures. The system is designed to ensure that only relevant information is collected and shared appropriately with practice staff.
You have the right to object to this service although would therefore need to use alternative contact methods such as in person attendance or via the use of online form.
Surgery Connect – X-ON
We use a cloud-based telephone system called Surgery Connect, provided by , to manage incoming and outgoing calls to the practice.
Purpose of processing
This system is used to:
- Handle patient telephone enquiries and appointment requests
- Route calls to appropriate members of staff or services
- Record calls for training, monitoring, and quality assurance purposes (where applicable)
- Improve patient access and service delivery
The system may process personal data such as your phone number, call recordings, and information you provide during the call.
Legal basis for processing
We process your personal data using this system under:
- Article 6(1)(e) UK GDPR – Public task
Processing is necessary for the performance of a task carried out in the public interest, namely the provision of NHS primary care services. - Article 9(2)(h) UK GDPR – Health or social care purposes
Where health information is shared during calls, processing is necessary for the provision and management of health care services.
Data processor
X-on Health acts as a data processor on behalf of the practice. We have a Data Processing Agreement in place to ensure your data is handled securely and in accordance with UK data protection law.
Call recording
Where call recording is in use, this is for training, monitoring, and service improvement purposes. All calls inbound and outbound are recorded.
Data protection and confidentiality
All calls and associated data are handled in line with NHS confidentiality requirements and UK data protection legislation, with appropriate technical and organisational safeguards in place.
Your rights
You have the right to object to this service although would therefore need to use alternative contact methods such as in person attendance or via the use of online form.
In health (Lung Cancer Screening)
In health processes personal data to deliver healthcare services, using it for treatment, quality assurance, and legal compliance, primarily under legitimate interest. They share data with partners like the NHS and GP practices. Patients have rights to access, rectify, or erase data by contacting data.protection@inhealthgroup.com.
InHealth processes personal data to provide safe, effective, and high-quality healthcare services. This includes using personal information for patient assessment, diagnosis, treatment, appointment management, and ongoing care. Personal data is also used to support service improvement, clinical audit, quality assurance, staff training, and to ensure continuity of care across healthcare providers.
In addition, InHealth processes personal data to meet its legal and regulatory obligations, including compliance with healthcare laws, safeguarding requirements, and reporting to relevant authorities.
The primary legal basis for processing personal data is the legitimate interests of InHealth in delivering healthcare services and ensuring operational effectiveness. Where applicable, processing is also carried out to fulfil legal obligations and, for special category health data, for the provision of health or social care and treatment in accordance with applicable data protection laws.
Personal data may be shared with trusted partners, including NHS organisations and GP practices, where necessary to support patient care and service delivery.
Privacy Policy - InHealth Group
Interface Clinical Services (IQVIA)
The Practice is currently working with an independent company, Interface Clinical Services (an IQVIA business), to review data from the records of patients who have [Condition] to help provide you with the best possible care. The company fully complies with data protection legislation and their work is overseen by your GP. Your personal data will be treated as strictly confidential but anonymised summary data may be collated for the purposes of reporting.