Fair Processing Notice – General Data Protection Regulation 2018
Your Information and how we use it
Why we collect information about you
The Patient Pack is designed, created and maintained by Substrakt Health Ltd on behalf of your registered GP practice and associated Clinical Commissioning Group. Substrakt Health Ltd is committed to providing patients high quality access to their healthcare data and services offered by their registered GP practices or accredited NHS partners organisations. Therefore, Substrakt Health offers a wide range of high quality digital health and social care services delivered via our PatientPack App onbehalf of our NHS clients. Any use of the digital and underlying healthcare services provided on the PatientPack App will be offered under the NHS with patients remaining as registered with their usual GP Practice.
When registering for the PatientPack App, we will require your consent to access your GP medical record and Registered GP practice system. This access will be limited to GP practice and you with data remaining under the control of your Registered GP. No data will be shared with any other organisation unless your explicit consent has been provided. Substrakt Health will only process the data to provide you with access to the data, unless your explicit consent has been provided.
When you use any of our digital or physical healthcare services offered within the app and/or physical locations, you may be asked to provide consent other than that of when you registered for the PatientPack App. This consent is to enable us to share your data with the required NHS organisations or accredited partners who are responsible for delivering the requested NHS service you are access. All sharing of such data will comply with the General Data Protection Regulation 2018 and NHS information governance rules. Substrakt Health will always request your explicit consent to do this providing you detail of what data will be shared and with whom it is shared and for how long. Sharing of your data for use of the given health service will not prohibit nor infringe on your rights under the General Data Protection Regulation 2018. To ensure that we comply with our General Data Protection Regulation responsibilities in keeping your information safe you will be asked to give your consent in the PatientPack app and in the physical service when the required clinician wishes to access your data.
How we keep your records confidential
Everyone working for the NHS and Substrakt Health is subject to the Common Law Duty of Confidence. Information provided in confidence will only be used for the purposes stated and where the patient has given their explicit consent, unless there are other circumstances covered by the law.
Information Sharing with Other NHS and Non-NHS Organizations
For your benefit, we may also need to share information we hold about you with other organizations involved in your care such as other NHS organisations, Social Services or charitable and voluntary bodies working with us to improve your care. However, we will not disclose any information to third parties without your explicit consent, unless there are exceptional circumstances, such as when the health or safety of yourself or others is at risk or where the law requires it.
If we are asked to share information with a non-NHS organisation that does not directly relate to your care, we will always seek your explicit consent prior to any information being shared. If you choose not to consent to this when asked, then that decision will be recorded and respected.
Your right to object to us sharing your personal information
You have the right to object to the sharing of your personal information or for your data to be removed from Substrakt Health Ltd. In this instance, we will remove your data as requested. However, the responsible NHS organisation for your data and delivery of care you have received by be required to retain your data on a legal basis for a predefined time period. If this is the case, such reasons will be outlined within the relevant NHS organisations Data Retention Policy, available on request from your Registered GP practice.
Your rights under the General Data Protection Regulation 2018
Patients and service users, as data subjects, have a number of rights under the General Data Protection 2018, including a general right of access to personal data (electronic or paper) held about them, the right to remove such data. You have the right to be forgotten by Substrakt Health Ltd, requiring us to remove any data permitting to you as the Data Subject. Substrakt Health enable this to occur, however, if your data is under the control of your registered GP practice, they may still retain your data as required by the NHS to ensure deliver healthcare and safety for you. For further information on this, please contact your Registered GP practice.
In addition, Substrakt Health will always obtain explicit consent before accessing or viewing your data. Substrakt Health will not have access to sensitive information such as Fertility treatments/embryology; Sexually Transmitted Infections; Gender reassignment; HIV/AIDs diagnosis; termination of pregnancy. In addition, you have the right to object to any of your healthcare data being shared with Substrakt Health. These requests must be made to your Registered GP practice as the Data Controllers of this information.
Right of Access to Your Substrakt Health Data
You can make your own application to see all information Substrakt Health holds about you, or you can authorize someone else to make an application for you. A parent or guardian, a patient representative, or a person appointed by the Court may also apply. If you wish to access your personal data, then please contact:
Substrakt Health Ltd
2a Victoria Works
Please note that Substrakt Health do not store or retain your Registered GP data longer than required, specifically your healthcare data, thus this may require an additional request to your Registered GP for such right of access.
In order for Substrakt Health to fulfil its responsibilities under the General Data Protection Regulation, you may be asked to provide proof of your identity, and any further information required to locate the record you have requested.
Withholding information about you
As Substrakt Health Ltd provides the PatientPack App on behalf of your Registered GP Practice, we will be required to confirm with them that such data can be released to you. Information may be withheld by the Registered GP Practice if the organisation believes that releasing the information to you could cause serious harm to your physical or mental health. We do not have to tell you that information has been withheld.
Information may also be withheld if another person (i.e. third party) is identified in the record, and they do not want their information disclosed to you. However, if the other person was acting in their professional capacity in caring for you, in normal circumstances they could not prevent you from having access to that information.
Correcting inaccurate information
Substrakt Health and all NHS organisations we act on behalf of have a duty to ensure your information is accurate and up to date to make certain we have the correct contact and treatment details about you.
If your information is not accurate and up-to-date, you can ask us to correct the record. If such as request is made to Substrakt Health, but we are not the responsible organisation holding the data, we will forward such requests to the required NHS organisation. If we/they agree that the information is inaccurate or incomplete, it will be corrected. If we/they do not agree that the information is inaccurate, we will ensure that a note is made in the record of the point you have drawn to the organisation’s attention.
If you would like to know more about Substrakt Health please go to our website at substrakthealth.com If you would like to know about how we use your information, or if (for any reason) you do not wish to have your information used in any of the ways described above, please log a support ticket on our app or registration page and will be happy to assist.