PRIVACY NOTICE
PRIVACY NOTICE AGED 13-16 2023
Automatic Prospective Online Records Access -Practice Statement
Update October 2023
NHS digital has proposed that from 1st November 2023 all patients will be able to access full prospective data from their record, with full historic access to follow shortly. This has been delayed since 2022.
Your GP medical record contains consultation notes based on conversations between you, your GP and their team: medicines prescribed to you; all test results including hospital investigations; allergies; vaccines; and your medical conditions along with documents that may have been sent from local hospitals, clinics or other agencies, eg the police. There is likely to be sensitive and personal information within your medical record.
We and many other practices are concerned that sufficient safeguards are not yet in place to guarantee the security of patient data, and avoid risks of data breach in certain situations.
We have also been asked to make "judgement based exceptions" preventing patients with certain conditions from accessing their data by default (e.g. Learning Disabilities) which we believe may be discriminatory and will potentially damage the relationship between GPs and Patients.
There is also a risk that for example results from hospitals will become visible to patients before seen by GPs , and before explanations are possible which may cause distress to patients.
There is potential risk of online accounts being opened up without consent, or knowledge of the GP practice for less tech savvy (older/ vulnerable) patients. P
We were are early adopter of online patient access, and around 4500 patients are already registered online so we are supportive of technology ,and providing patient access. However, we are legally the data controller for the records that we hold and take our responsibilities seriously, and have legal duties under the data protection act 2018. We have performed a data protection impact assessment that has highlighted risks, many of which cannot be mitigated. The BMA has published concerns which align with ours.
We have raised our concerns locally and nationally and to our MP, as have other practices. It is possible that it will be further delayed nationally , but if it isn't we propose to switch off automatic access until we are confident that data safeguards are in place, and that staff are adequately trained. This will not affect existing users in any way. We will update when we hear more about the national decision.
Just to clarify, we are in favour of patients accessing and operating their record, and have been an early adopter of online access. Around 50 % of our patients actively use online platforms (e.g. NHS app ) to communicate with the practice. If you haven't got online access yet -you can register with NHS app easily. For those who would like access, we are happy to explain the different levels you might like. We may ask for identification. We have an application form on our website -which outlines the benefits and risks of more extensive access.
Many thanks
Dr Richard Greenway
On Behalf of the Partners
Update 17/10/2023