Privacy Policy | RHA PCA

Rochdale Health Alliance – Privacy Notice

Coronavirus (COVID-19) pandemic and your information

The ICO recognises the unprecedented challenges the NHS and other health professionals are facing during the Coronavirus (COVID-19) pandemic.

The ICO also recognise that ‘Public bodies may require additional collection and sharing of personal data to protect against serious threats to public health.’

The Government have also taken action in respect of this and on 20th March 2020, the Secretary of State for Health and Social Care issued a Notice under Regulation 3(4) of The Health Service (Control of Patient Information) Regulations 2002 requiring organisations such as GP Practices to use your information to help GP Practices and other healthcare organisations to respond to and deal with the COVID-19 pandemic.

In order to look after your healthcare needs during this difficult time, we may urgently need to share your personal information, including medical records, with clinical and non-clinical staff who belong to organisations that are permitted to use your information and need to use it to help deal with the Covid-19 pandemic. This could (amongst other measures) consist of either treating you or a member of your family and enabling us and other healthcare organisations to monitor the disease, assess risk and manage the spread of the disease.

Please be assured that we will only share information and health data that is necessary to meet your and public healthcare needs.

The Secretary of State for Health and Social Care has also stated that these measures are temporary and will expire on 30th September 2020 unless a further extension is required. Any further extension will be communicated via an update to this Privacy Notice.

Please also note that the data protection and electronic communication laws do not stop us from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.

If you are concerned about how your information is being used, please contact our DPO using the contact details provided in this Privacy Notice.

Protecting Your Data

Introduction

This privacy notice explains in detail why we use your personal data which we, the Organisation, (Data Controller), collects and processes about you. A Data Controller determines how the data will be processed and used within the Organisation and with others with who we share this data with. We are legally responsible for ensuring that all personal data that we hold and use is done so in a way that meets the data protection principles under the General Data Protection Regulation (GDPR) and Data Protection Act 2018. This notice also explains how we handle that data and keep it safe.

Caldicott Guardian

The Organisation also has a Caldicott Guardian. A Caldicott Guardian is a senior person within a health or social care organisation, preferably a health professional, who makes sure that the personal information about those who use its services is used legally, ethically and appropriately, and that confidentiality is maintained. The Caldicott Guardian for Rochdale Health Alliance is:

Dr Zahir Mohammed – contact details – zahir.mohammed@nhs.net

Data Protection Officer (DPO)

Under GDPR all public bodies must nominate a Data Protection Officer. The DPO is responsible for advising on compliance, training and awareness and is the main point of contact with the Information Commissioner’s Office (ICO). The DPO for Rochdale Health Alliance is:

Dr Venk Mallya – contact details – Venkatesh.mallya@nhs.net

We will continually review and update this privacy notice to reflect changes in our services and to comply with changes in the Law. When such changes occur, we will revise the last updated date as documented in the version status in the header of this document.

What we do?

We are here to provide care and treatment to you as our patients. In order to do this, Rochdale Health Alliance keeps personal demographic data about you such as your name, address, date of birth, telephone numbers, email address, NHS Number etc and your health and care information. Information is needed so we can provide you with the best possible health and care. We also use your data to:

Confirm your identity to provide these services and those of your family/carers
Understand your needs to provide the services that you request
Obtain your opinion on our services (with consent)
Prevent and detect fraud and corruption in the use of public funds
Make sure we meet our statutory obligations, including those related to diversity and equalities
Adhere to a legal requirement that will allow us to use or provide information (e.g. a formal Court Order or legislation)

Definition of Data Types

We use the following types of information/data:

Personal Data
This contains details that identify individuals even from one data item or a combination of data items. The following are demographic data items that are considered identifiable such as name, address, NHS Number, full postcode, and date of birth. Under GDPR, this now includes location data and online identifiers.

Special categories of data (previously known as sensitive data)
This is personal data consisting of information as to: race, ethnic origin, political opinions, health, religious beliefs, trade union membership, sexual life and previous criminal convictions. Under GDPR, this now includes biometric data and genetic data.

Personal Confidential Data (PCD)
This term came from the Caldicott review undertaken in 2013 and describes personal information about identified or identifiable individuals, which should be kept private or secret. It includes personal data and special categories of data but it is adapted to include dead as well as living people and ‘confidential’ includes both information ‘given in confidence’ and ‘that which is owed a duty of confidence’.

Pseudonymised Data or Coded Data
Individual-level information where individuals can be distinguished by using a coded reference, which does not reveal their ‘real world’ identity. When data has been pseudonymised it still retains a level of detail in the replaced data by use of a key/code or pseudonym that should allow tracking back of the data to its original state.

Anonymised Data
This is data about individuals but with all identifying details removed. Data can be considered anonymised when it does not allow identification of the individuals to whom it relates, and it is not possible that any individual could be identified from the data by any further processing of that data or by processing it together with other information which is available or likely to be available.

Aggregated Data
This is statistical information about multiple individuals that have been combined to show general trends or values without identifying individuals within the data.

Our data processing activities

The law on data protection under the GDPR sets out a number of different reasons for which personal data can be processed for. The law states that we have to inform you what the legal basis is for processing personal data and also if we process a special category of data such as health data what the condition is for processing.

The types of processing we carry out in the organisation and the legal bases and conditions we use to do this are outlined below:

Provision of Direct Care and administrative purposes within the Rochdale Health Alliance

Type of Data

Personal Data – demographics
Special category of data – Health data

Source of Data

Patient and other health and care providers

Legal basis for processing personal data and Condition for processing special categories of data

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

Article 9(2)(h) – Processing is 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 and social care or treatment or the management of health and social care systems

Common-Law Duty of Confidentiality basis

Implied Consent

Direct care means a clinical, social or public health activity concerned with the prevention, investigation and treatment of illness and the alleviation of suffering of individuals. This is carried out by one or more registered and regulated health or social care professionals and their team with whom the individual has a legitimate relationship with. In addition, this also covers administrative purposes which are in the patient’s reasonable expectations.

To explain this, a patient has a legitimate relationship with the Rochdale Health Alliance in order for them to be treated and the Rochdale Health Alliance’s staff process the data in order to keep up to date records and to send referral letters etc.

Other local administrative purposes include waiting list management, performance against national targets, activity monitoring, local clinical audit and production of datasets to submit for national collections.

This processing covers the majority of our tasks to deliver health and care services to you. When we use the above legal basis and condition to process your data for direct care, consent under GDPR is not needed. However, we must still satisfy the common law duty of confidentiality and we rely on implied consent. For example, where a patient agrees to a referral from one healthcare professional to another and where the patient agrees this implies their consent.

Medicines Management and Optimisation

Type of Data

Personal Data – demographics
Special category of data – Health data

Source of Data

GP Practice

Legal Basis and Condition for processing special category of data under GDPR

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

Article 9 (2)(h) – Processing is 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 and social care or treatment or the management of health and social care systems

Common Law Duty of Confidentiality basis

Implied Consent

Rochdale Health Alliance pharmacists work with GP practices to provide advice on medicines and prescribing queries, process repeat prescription requests and review the prescribing of medicines to ensure that it is safe and cost-effective. This requires the use of identifiable information.

Direct clinical care is also undertaken through face to face and telephone consultations with patients. This activity is entered into the specific patient record on the GP clinical system

In cases where identifiable data is required, this is done with the practice agreement and through a signed practice confidentiality agreement, and in the case of repeat prescription processing with patient consent. No data is removed from the practice’s clinical system and no changes are made to patient records without permission from the GP. Patient records are viewed mainly through the practice’s computers at the practice premises and remotely via secure encrypted laptops.

Purposes other than direct care (secondary use)

This is information which is used for non-healthcare purposes. Generally, this could be for research purposes, audits, service management, safeguarding, commissioning, complaints and patient and public involvement.

When your personal information is used for secondary use this should, where appropriate, be limited and de-identified so that the secondary uses process is confidential.

Safeguarding

Type of Data

Personal Data – demographics
Special category of data – Health data

Source of Data

Patient and other health and care providers

Legal Basis and Condition for processing special category of data under GDPR

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

Article 9 (2)(b) – Processing is necessary for the purposes of carrying out the obligations and exercising the specific rights of the controller or the data subject in the field of …social protection law

Common-Law Duty of Confidentiality basis

Overriding Public Interest/children and adult safeguarding legislation

Information is provided to care providers to ensure that adult and children’s safeguarding matters are managed appropriately. Access to personal data and health information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned. For the purposes of safeguarding children and vulnerable adults, personal and healthcare data is disclosed under the provisions of the Children Acts 1989 and 2006 and Care Act 2014.

Risk Stratification

Type of Data

Personal Data – demographics
Special category of data – Health data

Source of Data

GP Practice and other care providers

Legal Basis and Condition for processing special category of data under GDPR

Article 6 (1)(c) – Processing is necessary for compliance with a legal obligation

Section 251 NHS Act 2006

Risk stratification entails applying computer based algorithms, or calculations to identify those patients who are most at risk from certain medical conditions and who will benefit from clinical care to help prevent or better treat their condition. To identify those patients individually from the patient community would be a lengthy and time-consuming process which would by its nature potentially not identify individuals quickly and increase the time to improve care. A GP / health professional reviews this information before a decision is made.

The use of personal and health data for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (known as Section 251 approval). This approval allows RHA Clinical staff (Primary Care Nurses and Clinical Pharmacists) who are responsible for providing your care, to see information that identifies you.

NHS England encourages GPs and RHA to use risk stratification tools as part of their local strategies for supporting patients with long-term conditions and to help and prevent avoidable admissions. RHA also supports the use of risk stratification tools to support patients with long term conditions and to help prevent avoidable admissions.

Knowledge of the risk profile of our population helps to commission appropriate preventative services and to promote quality improvement.

Risk stratification tools use various combinations of historical information about patients, for example, age, gender, diagnoses and patterns of hospital attendance and admission and primary care data collected in GP practice systems.

Our data processor for Risk Stratification purposes is HMR CCG. The name of the Risk Stratification Provider will be NW DSCRO and CCG’s BI Teams.

If you do not wish information about you to be included in our risk stratification programme, please contact the GP Practice. We can add a code to your records that will stop your information from being used for this purpose. Please see the section below regarding objections for using data for secondary uses.

National Clinical Audits

Type of Data

Personal Data – demographics
Special category of data – Health data
Pseudonymised
Anonymised

Source of Data

GP Practice and other care providers

Legal Basis and Condition for processing special category of data under GDPR

Article 6 (1)(c) – Processing is necessary for compliance with a legal obligation

Section 251 NHS Act 2006, NHS Constitution (Health and Social Care Act 2012)

Rochdale Health Alliance contributes to national clinical audits and will send the data which are required by NHS Digital when the law allows. This may include demographic data such as data of birth and information about your health which is recorded in coded form, for example, the clinical code for diabetes or high blood pressure.

Research

Type of Data

Personal Data – demographics
Special category of data – health data

Source of Data

GP Practice

Legal Basis and Condition for processing special category of data under GDPR

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

Article 9 (2)(j) – Processing is necessary for…scientific or historical research purposes…

Common law duty of confidentiality – explicit consent or if there is a legal statute for this which you will be informed of

All NHS organisations (including Health & Social Care in Northern Ireland) are expected to participate and support health and care research. The Health Research Authority and government departments in Northern Ireland, Scotland and Wales set standards for NHS organisations to make sure they protect your privacy and comply with the law when they are involved in research. Our research ethics committees review research studies to make sure that the research uses of data about you are in the public interest, and meet ethical standards. Health and care research may be exploring prevention, diagnosis or treatment of disease, which includes health and social factors in any disease area. Research may be sponsored by companies developing new medicines or medical devices, NHS organisations, universities or medical research charities. The research sponsor decides what information will be collected for the study and how it will be used.

Health and care research should serve the public interest, which means that research sponsors have to demonstrate that their research serves the interests of society as a whole. They do this by following the UK Policy Framework for Health and Social Care Research. They also have to have a legal basis for any use of personally identifiable information.

How patient information may be used for research?

When you agree to take part in a research study, the sponsor will collect the minimum personally identifiable information needed for the purposes of the research project. Information about you will be used in the ways needed to conduct and analyse the research study. NHS organisations may keep a copy of the information collected about you. Depending on the needs of the study, the information that is passed to the research sponsor may include personal data that could identify you. You can find out more about the use of patient information for the study you are taking part in from the research team or the study sponsor. You can find out who the study sponsor is from the information you were given when you agreed to take part in the study.

For some research studies, you may be asked to provide information about your health to the research team, for example in a questionnaire. Sometimes information about you will be collected for research at the same time as for your clinical care, for example when a blood test is taken. In other cases, information may be copied from your health records. Information from your health records may be linked to information from other places such as central NHS records, or information about you collected by other organisations. You will be told about this when you agree to take part in the study.

Even though consent is not the legal basis for processing personal data for research, the common law duty of confidentiality is not changing, so consent is still needed for people outside the care team to access and use confidential patient information for research, unless you 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 or similar arrangements elsewhere in the UK

Your choices about health and care research

If you are asked about taking part in research, usually someone in the care team looking after you will contact you. People in your care team may look at your health records to check whether you are suitable to take part in a research study, before asking you whether you are interested or sending you a letter on behalf of the researcher.

In some hospitals and GP practices, you may have the opportunity to sign up to a register to hear about suitable research studies that you could take part in. If you agree to this, then research nurses, researchers or administrative staff authorised by the organisation may look at your health records to see if you are suitable for any research studies.

It’s important for you to be aware that if you are taking part in research, or information about you is used for research, your rights to access, change or move information about you are limited. This is because researchers need to manage your information in specific ways in order for the research to be reliable and accurate. If you withdraw from a study, the sponsor will keep the information about you that it has already obtained. They may also keep information from research indefinitely.

If you would like to find out more about why and how patient data is used in research, please visit the Understanding Patient Data website.

https://understandingpatientdata.org.uk/what-you-need-know

In England you can register your choice to opt-out via the “Your Data Matters” webpage on the link below:

https://www.nhs.uk/your-nhs-data-matters/

If you do choose to opt out you can still agree to take part in any research study you want to, without affecting your ability to opt out of other research. You can also change your choice about opting out at any time.

To find out more about GDPR and using personal data for research, please visit the Health Research Authority website on the link below:

https://www.hra.nhs.uk/hra-guidance-general-data-protection-regulation/

Current Research Projects

NHS organisations are expected to publish information about the research projects they are involved in. Where research projects are taking place RHA will list details of the sponsor, allowing participants to access further transparency information provided by sponsors

Complaints

Type of Data

Personal Data – demographics
Special category of data – health data

Source of Data

Data Subject, Primary Care, Secondary Care and Community Care

Legal Basis and Condition for processing special category of data under GDPR

Article 6 (1)(a) – Explicit Consent

Article 9 (2)(h) – Processing is 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 and social care or treatment or the management of health and social care systems

Common law duty of confidentiality – explicit consent

If you contact the Rochdale Health Alliance about a complaint, we require your explicit consent to process this complaint for you. You will be informed of how and with whom your data will be shared by us, including if you have or you are a representative you wish the Rochdale Health Alliance to deal with on your behalf.

Purposes requiring consent

There are also other areas of processing undertaken where consent is required from you. Under GDPR, consent must be freely given, specific, you must be informed and a record must be made that you have given your consent, to confirm you have understood.

Patient and Public Involvement

Type of Data

Personal Data – demographics

Source of Data

GP Practice

Legal Basis and Condition for processing special category of data under GDPR

Article 6 (1)(a) – Explicit Consent

Article 9 (2)(a) – Explicit Consent

If you have asked us to keep you regularly informed and up to date about the work of the Rochdale Health Alliance or if you are actively involved in our engagement and consultation activities or patient participation groups, we will collect and process personal confidential data which you share with us.

We obtain your consent for this purpose. Where you submit your details to us for involvement purposes, we will only use your information for this purpose. You can opt-out at any time by contacting us using our contact details at the end of this document.

Using anonymous or coded information

This type of data may be used to help assess the needs of the general population and make informed decisions about the provision of future services. Information can also be used to conduct health research and development and monitor NHS performance where the law allows this. Where information is used for statistical purposes, stringent measures are taken to ensure individual patients cannot be identified. Anonymous statistical information may also be passed to organisations with a legitimate interest, including universities, community safety units and research institutions.

National Data Opt-Out

Whenever you use a health or care service, such as attending the practice, 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 like this where 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.

You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt-out your confidential patient information will still be used to support your individual care.

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

You can also find out more about how patient information is used at:

https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research);

and,

https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)

You can change your mind about your choice at any time.

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.

Health and care organisations have until 2020 to put systems and processes in place so they can apply your national data opt-out choice. The services we provide are in conjunction with your GP and therefore opting out via the GP Practice process will then apply to our direct care services too.

How we protect your personal data

We will use the information in a manner that conforms to the General Data Protection Regulations (GDPR) and Data Protection Act 2018. The information you provide will be subject to rigorous measures and procedures to make sure it can’t be seen, accessed or disclosed to any inappropriate persons. We have an Information Governance Framework that explains the approach within the Organisation, our commitments and responsibilities to your privacy and covers a range of information and technology security areas.

Access to your personal confidential data is password protected on secure systems and securely locked in a filing cabinet when on paper.

Our IT Services provider, Greater Manchester Shared Service, regularly monitor our system for potential vulnerabilities and attacks and looks to always ensure security is strengthened.

All our staff have received up-to-date data security and protection training. They are obliged in their employment contracts to uphold confidentiality and may face disciplinary procedures if they do not do so. We have incident reporting and management processes in place for reporting any data breaches or incidents. We learn from such events to help prevent further issues and inform patients of breaches when required.

How long do we keep your personal data?

Whenever we collect or process your data, we will only keep it for as long as is necessary for the purpose it was collected. The Organisation complies with the Records Management NHS Code of Practice which states that we keep records for 10 years after the date of death. Following this time, the records are securely destroyed if stored on paper, deleted on the electronic health record system or archived for research purposes where this applies.

Destruction

This will only happen following a review of the information at the end of its retention period. Where data has been identified for disposal we have the following responsibilities:

to ensure that information held in manual form is destroyed we use a confidential waste company ‘Shred It’ that complies with European Standard EN15713 and obtain certificates of destruction.
to ensure that electronic storage media used to hold or process information are destroyed or overwritten to national standards.

Who do we share your data with?

As stated above, where your data is being processed for direct care this will be shared with other care providers who are providing direct care to you such as:

NHS Trusts / Foundation Trusts
GP’s
Independent Contractors such as dentists, opticians, pharmacists
Private Sector Providers
Voluntary Sector Providers
Ambulance Trusts
Social Care Services
Out-of-hours providers
Walk-in centres / Urgent Care Treatment Centres
Clinics

We work with third parties and suppliers (data processors) to be able for us to provide a service to you. These include:

[EMIS ] – to provide our electronic clinical system
NHS Greater Manchester Shared service – to provide our IT services

The following services/providers are ot used by RHA, but for completeness, we have retained the areas covered and should there come the need to commission these services we will add the relevant details and reasons:

Any other third-party supplier who may access PCD]
Archiving companies/storage companies used
Risk Stratification Provider and/or Invoice Validation provider
Any destruction companies used

There may be occasions whereby these organisations have potential access to your personal data, for example, if they are fixing an IT fault on the system. To protect your data, we have contracts and/or Information Sharing Agreements in place stipulating the data protection compliance they must have and re-enforce their responsibilities as a data processor to ensure your data is securely protected at all times.

We will not disclose your information to any 3rd party without your consent unless:

there are exceptional circumstances (life or death situations)
where the law requires information to be passed on as stated above
required for fraud management – we may share information about fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
It is required to be disclosed to the police or other enforcement, regulatory or government body for prevention and/or detection of crime

Where is your data processed?

Your data is processed with the Rochdale Health Alliance and by other third parties as stated above who are UK-based. Your personal data is not sent outside of the UK for processing.

Where information sharing is required with a country outside of the EU you will be informed of this and we will have a relevant Information Sharing Agreement in place. We will not disclose any health information without an appropriate lawful principle unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it, or to carry out a statutory function i.e. reporting to external bodies to meet legal obligations

What are your rights over your personal data?

You have the following rights over your data we hold:

Subject Access Rights – you can request access to and or copies of personal data we hold about you, free of charge (subject to exemptions) and provided to you within 1 calendar month. We request that you provide us with adequate information in writing to process your request such as full name, address, date of birth, NHS number and details of your request and documents to verify your identity so we can process the request efficiently. On processing a request, there may be occasions when information may be withheld if the organisation believes that releasing the information to you could cause serious harm to your physical or mental health. 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.

To request a copy or request access to the information we hold about you and/or to request information to be corrected if it is inaccurate, please contact:

The Data Protection Officer – Dr V. Mallya at :

Rochdale Health Alliance

No 2

The Esplanade

Rochdale

OL16 1AE

Or via email to : nwch.rha@nhs.net

Right to rectification – The correction of personal data when incorrect, out of date or incomplete which must be acted upon within 1 calendar month of receipt of such request. Please ensure Rochdale Health Alliance has the correct contact details for you.
Right to withdraw consent – If we have your explicit consent for any processing we do, you have the right to withdraw that consent at any time
Right to Erasure (‘be forgotten’)
If we obtain consent for any processing we do, you have the right to have that data deleted/erased. Please note this does not apply to health records.
Right to Data Portability
If we obtain consent for any processing we do, you have the right to have data provided to you in a commonly used and machine-readable format such as an Excel spreadsheet or CSV file.
Right to object to processing – you have the right to object to processing however please note if we can demonstrate compelling legitimate grounds which outweigh the interest of you then processing can continue. If we didn’t process any information about you and your health care if would be very difficult for us to care for and treat you.
Right to restriction of processing
This right enables individuals to suspend the processing of personal information, for example, if you want to establish its accuracy or the reason for processing it.

Objections to processing for secondary purposes (other than direct care)

The NHS Constitution states “You have the right to request that your confidential information is not used beyond your own care and treatment and to have your objections considered”. The possible consequences (i.e. lack of joined-up care, delay in treatment if information has to be sourced from elsewhere, medication complications which all lead to the possibility of difficulties in providing the best level of care and treatment) will be fully explained to you to allow you to make an informed decision.

If you wish to opt out of your data being processed and/or shared onwards with other organisations for purposes not related to your direct care, please contact the Rochdale Health Alliance at: nwch.rha@nhs.net

Complaints / Contacting the Regulator

If you feel that your data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, please contact our Data Protection Officer / Head of Operations at the following contact details:

Email us at: nwch.rha@nhs.net

Or write to us at:

Rochdale Health Alliance

Second Floor

The Old Post Office

No 2

The Esplanade

Rochdale

OL16 1AE

If you are not happy with our responses and wish to take your complaint to an independent body, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1133

Or go online to www.ico.org.uk/concerns (opens in a new window, please note we can’t be responsible for the content of external websites)

Further Information / Contact Us

We hope that the Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. Should you have any questions / or would like further information, please visit the websites below and/or contact either our Caldicott Guardian / Data Protection Officer / Information Governance Officer at the following contact details:

Email us at: nwch.rha@nhs.net

Or write to us at:

Rochdale Health Alliance

Floor 2

No 2

The Esplanade

Rochdale

OL16 1AE

Links

If you would like to find out more information on the wider health and care system approach to using personal information or other useful information, please click and/or search for the following on the internet: