Use of Your Personal Information
This privacy notice explains how and why we collect information about you through our websites– cwth.isarriving.com, www.cwintegratedprimarycare.co.uk and www.cw-ipc.co.uk – and how that information may be used.
Coventry and Warwickshire Integrated Primary Care Limited (IPC) is the parent organisation responsible for delivering the Coventry and Warwickshire Training Hub and is the data controller for all data processed under these services.
Coventry & Warwickshire Integrated Primary Care Limited is the data controller.
Registered office address:
Coventry & Warwickshire Integrated Primary Care
c/o Ballards LLP
Oakmoore Court
Kingswood Road
Hampton Lovett
Droitwich
Worcs
WR9 0QH
Our team who provide you with our services collect and maintain personal information to enable us to provide training and support services. In some cases, this may include information about health conditions or other information you disclose to help us provide the best service or meet accessibility needs.
Your records include electronic, paper or a mixture of both. We have measures in place to ensure that such information is maintained within a secure environment. The records which we could hold about you may include the following information: –
- Personal details relating to you, including your address and contact details.
- Any contact we have had or intend to have with you such as training sessions.
- Notes and reports about your health which is deemed to be of a sensitive nature
Your records will be used to facilitate the services that we provide. Information could also be used within our organisation for the purposes of audits which in turn will provide monitoring of the quality of the services we provide.
Some of this information may be used for statistical purposes and we will ensure that individuals cannot be identified. For situations where we may contribute to research projects we will always gain your explicit consent before releasing any relevant information.
Where healthcare professionals make use of the Coventry & Warwickshire Training Hub (a service delivered by Coventry & Warwickshire Integrated Primary Care Ltd) we may store the following information of those people:
- Name, email, practice, role
- Courses previously attended
This data will be stored by our newsletter distributor MailChimp. As part of this we will gather statistics regarding email openings and clicks, to help us monitor and improve the newsletter for you. MailChimp is a Privacy Shield registered organisation and complies with NHS Digital requirements as a non EU-EA registered organisation.
A privacy impact assessment for the services utilised on this website is available on request.
Maintaining the Confidentiality of Your Records
We will take all possible care to protect your privacy and will only use information collected with the law including: –
- Data Protection Act 2018 and the General Data Protection Regulation 2018 from 25th May 2018
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2012 (if appropriate)
- Codes of Confidentiality, Information Security and Records Management
Our staff are all trained and briefed in data protection principles and understand they have a legal obligation to keep information about you confidential. They also understand that information about you will only be shared with other parties if there is an agreed need to do so or a legal reason. We will only share your data without your permission if there are very exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the Caldicot Principle 7 e.g. to share or not to share. This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott Principles. Whilst the Caldicott Principles were originally developed for NHS purposes, we have adopted the underlying principles in order to align with best practice.
All personal information that we manage is stored within the UK within a secure environment and we always use suitably protected methods and systems to transfer your personal information.
Data Protection Officer
Coventry and Warwickshire Integrated Primary Care Limited (IPC) is required to have a Data Protection Officer (DPO). Our appointed DPO is:
Judith Jordan
NHS Arden and Greater East Midlands Commissioning Support Unit (AGEM CSU)
Email: agem.dpo@nhs.net
You may contact the DPO directly if you have concerns about the way your personal data is handled or wish to raise a privacy issue in confidence.
Legal Basis for Processing
Our legal basis for processing your data relies on certain conditions set out GDPR Articles 6 and 6(1)(a), consent to processing for specific purposes (Training) and 9(2)(a) Explicit Consent and 9(2)(h) Occupational Needs of the Trainee – which will be relevant from 25th May as part of the 2018 UK Data Protection Act.
Partner Organisations
It may be possible that we will share your information with other organisations, if this is required we will apply very strong controls. The current organisations who we share data with include: –
- Coventry & Warwickshire ICB – Training Data
- Coventry & Warwickshire Health & Care Partnership – Workforce information
- External training providers
It is noted that the above list is not exhaustive, and we may contract with other external organisations to undertake processing of your personal information. These 3rd party organisations will abide with our stringent contractual conditions regarding the protection of personal data.
In some cases, you will be requested to provide positive consent if we intend to share your personal details with other organisations.
Access to Personal Information and Your Rights
You have a right under the Data Protection Act 2018 from 25th May 2018, to request access to view or to obtain a copy of what information the organisation holds about you and to have it modified should it be inaccurate. The process to access your records is known as a Subject Access Request (SAR) and the way it works is outlined below: –
- Your SARs request can be be made in writing or in person to the organisation’s IG Lead at the address shown above or by email to cw.traininghub@nhs.net
- The latest regulations state that there is no charge to have a copy of your electronic or paper information, unless the request is repetitive.
- The request will be reviewed and if possible completed within one calendar month (subject to our possible requests for further clarification for you)
- You will need to provide adequate proof of your identity before we will release the requested details (e.g. full name, address, date of birth, NHS number and details of your request), you must also provide two forms of proof of address
In addition to the right of access, under the Data Protection Act 2018, you will also have the following rights: –
- Erasure, which is the right to request that your personal data is removed from our systems be they paper or electronic – please note that under certain circumstances we are legal obliged to maintain a copy of your data for contractual and or statutory reasons
- Restriction of processing, this is the right for you to request that we only process certain parts of your data
- Objection – you have the right to object to the way that we are processing your data
- Data portability – this concerns the right to request that we provide a copy of your data in an easily transportable format.
- Automatic processing – you have the right to object to the way we automatically process data – in the case of our organisation we do not, at present, carry out automatic processing of your data
- If you have provided us with your consent to process your data for the purpose of providing our services, you have the right to withdraw this at any time. In order to do this should contact us by emailing or writing to the organisation.
Retention of your data
Your data will be retained for no longer than is absolutely necessary and in accordance with our Documentation Management Lifecycle Policy and the associated Schedule of Retention
Cookies
This website makes use of cookies to optimise user experience. By using our website, you consent to all cookies in accordance with our cookie policy.
If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
You can learn more about cookies and the following third-party websites:
AllAboutCookies: allaboutcookies.org
Network Advertising Initiative: networkadvertising.org
Updating Personal Details
If any of your details e.g. your name, address or other personal data have changed or are incorrect you have a responsibility to inform the professional treating you who will arrange for the necessary updates to be made. This will help us to ensure that the data we hold about you is accurate and complete.
Notification
The Data Protection Act 2018 requires organisations that control data to register with the Information Commissioners Office (ICO) website www.ico.org.uk
The organisation is registered with the ICO as a Data Controller under the Data Protection Act 2018. The registration number is ZA792332 and can be viewed online in the public register at http://www.ico.gov.uk/
Complaints
Should you have any concerns about how your information is managed by the Organisation please contact us at: –
Coventry & Warwickshire Integrated Primary Care
c/o Ballards LLP
Oakmoore Court
Kingswood Road
Hampton Lovett
Droitwich
Worcs
WR9 0QH
If you are still unhappy following a review by the Organisation you can then complain to the Information Commissioners Office (ICO) via their website www.ico.org.uk
or in writing to: –
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
If you are happy for your data to be extracted and used for the purposes described in this Privacy Notice, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact us.