St Joseph’s Hospital is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to protecting the privacy and security of your personal information. This privacy notice describes, in line with GDPR, how we collect and use personal data about you during and after your time as a patient of this Hospital. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This notice applies to current and former patients.
The Hospital is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: St Joseph’s Hospital, Harding Avenue, Malpas, Newport, NP20 6ZE
In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:
Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
We hold many types of data about you:
In some cases there are "special categories" of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. You would be prior informed if any of this information was required.
We will only use your special category data:
We must process special categories of data in accordance with more stringent guidelines. We will process special categories of data only when the following applies:
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
We collect data about you in a variety of ways and this will usually start when you make an enquiry to the Hospital and continue when you attend your first and subsequent appointments. At this Hospital, we keep paper and electronic records. Information we write down on paper may be transferred to our electronic system. We may receive information about you from your GP or other health care provider regarding your referral or, with your permission, additional information that will help us continue with your treatment. We may also hold the results of tests that you have undertaken and that are relevant to your treatment with the Hospital.
Personal data is kept electronically in the Hospital in our customer management systems called Compucare, NovaPacs and our electronic record store. All of these are hosted in a secure on site location with back up and disaster recovery policies in place. All Physical copies are held in our Records department by our Record keeping staff. All data is governed by legal dates for expiry and more information can be acquired through contacting our GDPR response team on GDPR@stjosephshospital.co.uk
The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances:
We may use your personal information in these rare situations:
We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations.
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of care with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained. We may also be prevented from continuing with your treatment with us due to our legal obligations.
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your data will be shared with colleagues within the Hospital but only where it is necessary for them to undertake their duties. This includes, for example, other Consultants working for, at or on behalf of the Hospital, reception staff and administrative staff. Medical notes are only available to the healthcare practitioners and record keeping staff.
We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, investigation or to keep your GP informed about your progress with treatment
We may also share your data with third parties as part of a Hospital sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.
We may share your data with bodies outside of the European Economic Area should the need arise. It is likely that this situation would be to share information regarding your treatment or ongoing care with healthcare practitioners in these countries in accordance with your wishes. However, we would not transfer your data unless we were assured that the country in question had data security and protection laws of equivalence to those of the UK and the European Economic Area. We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that process it in a way required by EU and UK data protection laws
We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data. Documentation on this is available on a written or emailed request to: GDPR@StJosephsHospital.co.uk
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your being a patient with us and we are legally required, by the Physiotherapy (CSP) regulator, to keep this data for eight years after your time as a patient has ended. To determine the any appropriate retention period for personal data beyond at least eight years we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements. We actively maintain and update regularly a schedule of retention periods that are also available upon request.
Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner that maintains data security.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time as a patient with us.
The law on data protection gives you certain rights in relation to the data we hold on you.
If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Records Manager at St Joseph’s Hospital, preferably in writing.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Where you have provided consent to the collection, processing and transfer of your data, you have the right to withdraw that consent at any time. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate legal reason for doing so.
To withdraw consent, contact GDPR@StJosephsHospital.co.uk or write to GDPR Response Team, St Joseph’s Hospital, Harding Avenue, Malpas, Newport, NP20 6ZE
If you have any questions about this Privacy Notice or how we handle your information, please contact the Hospital’s Data Protection Officer. They can be contacted on GDPR@StJosephsHospital.co.uk or in writing to: GDPR Response Team, St Joseph’s Hospital, Harding Avenue, Malpas, Newport, NP20 6ZE
You have the right to make a complaint at any time to the supervisory authority in the UK for data protection matters, the Information Commissioner’s Office (ICO).
© St. Joseph's Hospital 2019