Data Protection (Updated for 2018 GDPR)

Data Protection (Updated for 2019 GDPR)

In line with the new General Data Protection Regulation, please see below for our Data Protection Privacy Notice for Patients, information is also available below regarding our Primary Care Network (Bolton Central) and how we share your information. For a leaflet explaining how we use your information please scroll down to the bottom of the page.

Locked blue folder

Privacy and Confidentiality Statement

Great Lever One

Data Protection Privacy Notice for Patients



This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you.

This privacy notice applies to personal information processed by or on behalf of the practice.

This Notice explains

  • Who we are, how we use your information and information about our Data Protection Officer?
  • What kinds of personal information about you do we process?
  • What are the legal grounds for our processing of your personal information (including when we share it with others)?
  • What should you do if your personal information changes?
  • For how long your personal information is retained by us?
  • What are your rights under data protection laws?

The General Data Protection Regulation (GDPR) and the Data Protection Act 2018 became law on 25th May 2018. The GDPR is a single EU-wide regulation on the protection of confidential and sensitive information, the DPA 2018 deals with elements of UK law that differ from the European Regulation. These came into force in the UK on the 25th May 2018, repealing the previous Data Protection Act (1998).

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), and the Data Protection Act 2018 the practice responsible for your personal data is Great Lever One.

This Notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights

How we use your information and the law.

Great Lever One will be what’s known as the ‘Controller’ of the personal data you provide to us.

We collect basic personal data about you which does include special types of information and location-based information. This does include name, address, medical conditions, contact details such as email and mobile number etc.

We will collect sensitive confidential data known as “special category personal data”, in the form of health information, religious belief (if required in a healthcare setting) ethnicity, and sex during the services we provide to you and or linked to your healthcare through other health providers or third parties.

 Why do we need your information?

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which the Practice hold about you may include the following information;

  • Details about you, such as your address, carer, legal representative, emergency contact details
  • Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
  • Notes and reports about your health
  • Details about your treatment and care
  • Results of investigations such as laboratory tests, x-rays etc
  • Relevant information from other health professionals, relatives or those who care for you
  • Contact details (including email address, mobile telephone number and home telephone number)

To ensure you receive the best possible care, your records are used to facilitate the care you receive, including contacting you. Information held about you may be used to help protect the health of the public and to help us manage the NHS and the services we provide. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.

How do we lawfully use your data?

We need to know your personal, sensitive and confidential data in order to provide you with Healthcare services as a General Practice, under the General Data Protection Regulation we will be lawfully using your information in accordance with: -

Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;”

Article 9, (h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems

This Privacy Notice applies to the personal data of our patients and the data you have given us about your carers/family members.

Risk Stratification

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from several sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information is only provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way.

Medicines Management

The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost-effective treatments.

Patient Communication

The Practice will use like to use your name, contact details and email address to inform you of NHS services, or provide inform about your health/information to manage your healthcare or information about the management of the NHS service. There may be occasions were authorised research facilities would like you to take part in research in regard to your particular health issues, to try improve your health, your contact details may be used to invite you to receive further information about such research opportunities.


The Practice is dedicated to ensuring that the principles and duties of safeguarding adults and children are holistically, consistently and conscientiously applied with the wellbeing of all, at the heart of what we do. 

Our legal basis for processing For the General Data Protection Regulation (GDPR) purposes is: -

Article 6(1)(e) ‘…exercise of official authority…’.

For the processing of special categories data, the basis is: -

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



Clinical Practice Research Datalink (CPRD) collects de-identified patient data from a network of GP practices across the UK. Primary care data are linked to a range of other health related data to provide a longitudinal, representative UK population health dataset. You can opt out of your information being used for research purposes at any time (see below), full details can be found here: -


The legal bases for processing this information

CPRD do not hold or process personal data on patients; however, NHS Digital (formally the Health and Social Care Centre) may process ‘personal data’ for us as an accredited ‘safe haven’ or ‘trusted third-party’ within the NHS when linking GP data with data from other sources. The legal bases for processing this data are:

  • Medicines and medical device monitoring: Article 6(e) and Article 9(2)(i) - public interest in the area of public health
  • Medical research and statistics: Article 6(e) and Article 9(2)(j) - public interest and scientific research purposes

Any data CPRD hold or pass on to bona fide researchers, except for clinical research studies, will have been anonymised in accordance with the Information Commissioner’s Office Anonymisation Code of Practice. We will hold data indefinitely for the benefit of future research, but studies will normally only hold the data we release to them for twelve months.

Categories of personal data

The data collected by Practice staff in the event of a safeguarding situation will be as much personal information as is necessary or possible to obtain in order to handle the situation. In addition to some basic demographic and contact details, we will also process details of what the safeguarding concern is. This is likely to be special category information (such as health information).

Sources of the data

The Practice will either receive or collect information when someone contacts the organisation with safeguarding concerns, or we believe there may be safeguarding concerns and make enquiries to relevant providers.

Recipients of personal data

The information is used by the Practice when handling a safeguarding incident or concern. We may share information accordingly to ensure duty of care and investigation as required with other partners such as local authorities, the police or healthcare professionals (i.e. their GP or mental health team).

Third party processors

In order to deliver the best possible service, the practice will share data (where required) with other NHS bodies such as other GP practices and hospitals. In addition, the practice will use carefully selected third party service providers. When we use a third party service provider to process data on our behalf then we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions and that they are operating appropriately. Examples of functions that may be carried out by third parties includes:

  • Companies that provide IT services & support, including our core clinical systems; systems which manage patient facing services (such as our website and service accessible through the same); data hosting service providers; systems which facilitate appointment bookings or electronic prescription services; document management services etc.
  • Delivery services (for example if we were to arrange for delivery of any medicines to you).
  • Payment providers (if for example you were paying for a prescription or a service such as travel vaccinations).

Further details regarding specific third-party processors can be supplied on request.


How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

  • Data Protection Act 2018
  • The General Data Protection Regulations 2016
  • Human Rights Act 1998
  • Common Law Duty of Confidentiality
  • Health and Social Care Act 2012
  • NHS Codes of Confidentiality, Information Security and Records Management
  • Information: To Share or Not to Share Review


Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.

We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” 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.

Our practice policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements. Our policy is to ensure all personal data related to our patients will be protected.


All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. The practice will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a sub-contractor acts as a data processor for Great Lever One an appropriate contract (art 24-28) will be established for the processing of your information.


In Certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent. If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.

Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose in an identifiable format.  In some circumstances you can Opt-out of the surgery sharing any of your information for research purposes. 

With your consent we would also like to use your information

There are times that we may want to use your information to contact you or offer you services, not directly about your healthcare, in these instances we will always gain your consent to contact you. We would however like to use your name, contact details and email address to inform you of other services that may benefit you, we will only do this with your consent. There may be occasions were authorised research facilities would like you to take part on innovations, research, improving services or identifying trends, you will be asked to opt in to such programmes.

At any stage where we would like to use your data for anything other than the specified purposes and where there is no lawful requirement for us to share or process your data, we will ensure that you have the ability to consent and opt out prior to any data processing taking place. This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the practice DPO as below.

 National Opt-Out Facility

You can choose whether your confidential patient information is used for research and planning.

Who can use your confidential patient information for research and planning?

It is used by the NHS, local authorities, university and hospital researchers, medical colleges and pharmaceutical companies researching new treatments.

Making your data opt-out choice

You can choose to opt out of sharing your confidential patient information for research and planning. There may still be times when your confidential patient information is used: for example, during an epidemic where there might be a risk to you or to other people’s health. You can also still consent to take part in a specific research project.

Will choosing this opt-out affect your care and treatment?

No, your confidential patient information will still be used for your individual care. Choosing to opt out will not affect your care and treatment. You will still be invited for screening services, such as screenings for bowel cancer.

What should you do next?

You do not need to do anything if you are happy about how your confidential patient information is used.

If you do not want your confidential patient information to be used for research and planning, you can choose to opt out securely online or through a telephone service.

You can change your choice at any time. To find out more or to make your choice visit or call 0300 303 5678

Where do we store your information Electronically?

All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintenance this information may be located on servers within the European Union.

No 3rd parties have access to your personal data unless the law allows them to do so and appropriate safeguards have been put in place Such as a Data Processor as above). We have a Data Protection regime in place to oversee the effective and secure processing of your personal and or special category (sensitive, confidential) data.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;

  • NHS Trusts / Foundation Trusts
  • GP’s
  • Primary Care Network
  • NHS Commissioning Support Units
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Clinical Commissioning Groups
  • Social Care Services
  • NHS England (NHSE) and NHS Digital (NHSD)
  • Multi Agency Safeguarding Hub (MASH)
  • Local Authorities
  • Education Services
  • Fire and Rescue Services
  • Police & Judicial Services
  • Voluntary Sector Providers
  • Private Sector Providers
  • Other ‘data processors’ which you will be informed of

You will be informed who your data will be shared with and in some cases asked for consent for this to happen when this is required.

Computer System This practice operates a Clinical Computer System on which NHS Staff record information securely. This information can then be shared with other clinicians so that everyone caring for you is fully informed about your medical history, including allergies and medication.

To provide around the clock safe care, unless you have asked us not to, we will make information available to trusted organisations. Wherever possible, their staff will ask your consent before your information is viewed.

We consider patient consent as being the key factor in dealing with your health information.

Shared Care Records

To support your care and improve the sharing of relevant information to our partner organisations when they are involved in looking after you, we will share information to other systems. The general principle is that information is passed to these systems unless you request this does not happen, but that system users should ask for your consent before viewing your record.  

We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure. All employees and sub-contractors engaged by our practice are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor for Great Lever One an appropriate contract (art 24-28) will be established for the processing of your information.

Sharing your information without consent

We will normally ask you for your consent, but there are times when we may be required by law to share your information without your consent, for example:

  • where there is a serious risk of harm or abuse to you or other people;
  • where a serious crime, such as assault, is being investigated or where it could be prevented;
  • notification of new births;
  • where we encounter infectious diseases that may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS);
  • where a formal court order has been issued;
  • where there is a legal requirement, for example if you had committed a Road Traffic Offence.

How long will we store your information?

We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of practice for health and social care and national archives requirements.

More information on records retention can be found online at (

How can you access, amend move the personal data that you have given to us?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.

Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this with a GP to GP data transfer and transfer of your hard copy notes.

Primary Care Network

The objective of primary care networks is for group practices together to create more collaborative workforces which ease the pressure of GP’s, leaving them better able to focus on patient care. The aim is that by July 2019, all areas within England will be covered by a PCN.

Primary care networks form a key building block of the NHS long-term plan. Bringing general practices together to work at scale has been a policy priority for some years for a range of reasons, including improving the ability of practices to recruit and retain staff; to manage financial and estates pressures; to provide a wider range of services to patients and to more easily integrate with the wider health and care system. 

All GP practices are expected to come together in geographical networks covering populations of approximately 30–50,000 patients by June 2019 if they are to take advantage of additional funding attached to the GP contract. This size is consistent with the size of the primary care homes, which exist in many places in the country, but much smaller than most GP Federations. 


This means the practice may share your information with other practices within the PCN to provide you with your care and treatment.


Access to your personal information

Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. To request this, you need to do the following:

  • Your request should be made to the Practice – for information from the hospital you should write direct to them
  • There is no charge to have a copy of the information held about you
  • We are required to respond to you within one month
  • You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified, and your records located information we hold about you at any time.

What should you do if your personal information changes?

You should tell us so that we can update our records please contact the Practice Manager as soon as any of your details change, this is especially important for changes of address or contact details (such as your mobile phone number), the practice will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.







Objections / Complaints

Should you have any concerns about how your information is managed at the GP, please contact the GP Practice Manager or the Data Protection Officer as above. If you are still unhappy following a review by the GP practice, you have a right to lodge a complaint with a supervisory authority: You have a right to complain to the UK supervisory Authority as below.


Information Commissioner:

Wycliffe house

Water Lane





Tel:       01625 545745


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 the Practice Data Protection Officer.

If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Data Protection Officer as below.

Data Protection Officer:


The Practice Data Protection Officer is Paul Couldrey of PCIG Consulting Limited. Any queries regarding Data Protection issues should be addressed to him at: -


Postal: PCIG Consulting Limited

                        7 Westacre Drive

                        Quarry Bank


                        West Midlands

                        DY5 2EE



It is important to point out that we may amend this Privacy Notice from time to time. If you are dissatisfied with any aspect of our Privacy Notice, please contact the Practice Data Protection Officer.


Primary Care Network (Bolton Central)  Information on Sharing                                                                

This sharing agreement for the Bolton Central Primary Care Network is to provide guidance in regard to data sharing only, and it to be read in conjunction with the NHS England Network Contract Directed Enhanced Service Mandatory Network Agreement (First published: April 2019 Updated version published: May 2019).

The objective of primary care networks is for group practices together to create more collaborative workforces which ease the pressure of GP’s, leaving them better able to focus on patient care. The aim is that by July 2019, all areas within England will be covered by a PCN.

Primary care networks form a key building block of the NHS long-term plan. Bringing general practices together to work at scale has been a policy priority for some years for a range of reasons, including improving the ability of practices to recruit and retain staff; to manage financial and estates pressures; to provide a wider range of services to patients and to more easily integrate with the wider health and care system. 

All GP practices are expected to come together in geographical networks covering populations of approximately 30–50,000 patients by June 2019 if they are to take advantage of additional funding attached to the GP contract. This size is consistent with the size of the primary care homes, which exist in many places in the country, but much smaller than most GP Federations. 

To establish this Agreement for the appropriate and lawful sharing of patient information, it is necessary for all co-signees of this Agreement to understand the underlying purposes, the approaches and processes and the mechanisms for its execution. It is critical that sufficient checks are in place to ensure patient data remains protected from inappropriate access, misuse and unintended breaches, wherever possible.

The central basis for the Agreement is to ensure that at a minimum, the practices can effectively operate as a single, seamless data-sharing body, enabling patients to benefit from timely data sharing to support provision of care and informed clinical decision making. This ranges from viewing records in remote and specialist clinics, enabling the advancement of care through integrating 3rd party patient data sources as well as supporting key directives such as Extended Hours.

The Agreement, by its definition, will also give the PCN Practices the ability to undertake detailed population health investigations and research at scale, which could be used to determine trends in treatment and outcomes, inform the location and provision of services and contribute to developing and promoting patient information that is regionally relevant and contextualized.

About Bolton Central Primary Care Network Practices

The practices which are covered by Bolton Central PCN are:

Practice Name

Population list

The Olive Family Practice


Dr Murthi


Orient House


Dr Loomba & Partner


Dr Sidda – Great Lever One


Beehive Surgery


Al-Fal Medical Group


Dr Zarrouk


3D Medical Centre


Bolton Medical Centre


Bolton General Practice


Dr Selvarajan



Information Governance Requirements

All sharing of Personal data is governed by the General Data Protection Regulation 2016, the UK Data Protection Act 2018, The NHS Caldicott Principles and NHS codes of practice for confidentiality and data sharing.

The following definitions are used in this Agreement:

  • Patient Confidential information - health or care records relating to an identifiable individual (i.e. the patient).
  • DPA18 - the Data Protection Act 2018.
  • GDPR- the General Data Protection Regulation 2016
  • Staff - all persons working for or on behalf of any Party (whether permanent, agency, honorary, contractor or volunteer) who access or otherwise use the patient identifiable information as part of their role.
  • Healthcare purposes - the use of patient identifiable information to support the provision of Healthcare to an individual patient, or the management of healthcare service and system.

Every GP Practice is identified as a “Data Controller” and each employee who has access to patient information is identified as having a responsibility for assuring data protection. In addition, each GP Practice has a nominated Caldicott Guardian who, as a senior member of staff, is responsible for protecting the confidentiality of patient and service-user information and enabling appropriate information sharing.

Under new GDPR legislation, Practices have identified a Data Protection Officer (DPO), who is an expert in data protection and provides independent advice on all matters relating to data protection.

Paul Couldrey


NBV Enterprise Centre

6 David Lane





0115 838 6770

This Agreement will be delivered locally by Practice Managers and Caldicott Guardians (where they are separate individuals) DPO managing oversight of all matters, processes, procedures and issues relating to it.

The Legal Basis

The Legal Basis ensures that all data sharing across the Bolton Central PCN Practices geographical footprint is handled lawfully, fairly and in a transparent manner. The Legal Basis, using guidance provided by the ICO*, incorporates the following:


  • Consent: that patients have provided consent for their personal information to be accessed for clinical purposes that support their care or contribute to research activities which benefit general practice
  • Contract: which supports the ability of Health Care Professionals to provide ongoing care and support outside of clinical appointments as required
  • Legal obligation: as guardians for patient information on behalf of the Secretary of State, patient information is shared to support safe and effective clinical care as required by clinical care pathways and processes
  • Vital interests: where the patient information may be required in an Out of Hours Clinic to provide urgent care to a patient
  • Public tasks: where the information is shared for the purpose of conducting necessary day-to-day general practice activities, such as remote booking of appointments

Appropriate patient details attending the PCN practices and additional information can be shared if certain criteria is met and this will be considered on a case by case basis, as appropriate. This agreement covers the exchange of personal data as defined under Article 4 of the General Data Protection Regulation (GDPR 2016). However, it is anticipated the same conditions will be followed before sharing de-personalised data.

This agreement has been developed bearing in mind the Data Protection Act 2018, GDPR 2016 and applied data protection legislation, the Human Rights Act 1998 and the Freedom of Information Act 2000.

Purpose of sharing

  • Patient identifiable information is shared for the direct care of individual patients to whom each Party has a legitimate relationship (i.e. the sharing is healthcare purposes).
  • Processing for non-healthcare purposes is under the requirements to perform public task in the public interest.This Information Sharing Agreement is entered for the purpose of the parties sharing information as required or permitted under the data protection legislation and any other relevant legislation which shall include (but not limited to):

Data Protection Act 2018 (DPA)            

General Data Protection Regulation 2016           

Freedom of Information Act 2000                      

Human Rights Act 1998

Mental Health Act 1983

Health and Social Care Act 2012

Health and Social Care (Safety and Quality) Act 2015

Mental Capacity Act 2005

HSCIC Guide to Confidentiality

Information Governance/Caldicott 2 Review: To Share or Not to Share

Records Management NHS Code of Practice

NHS England Safe haven Procedure

NHS Constitution

Information Security Management: Code of Practice

Data Sharing Code of Practice

Privacy Notices Code of Practice

Any other relevant legislation, standards or guidance




The Parties acknowledge and agree that they will not be bound by the terms of this Information Sharing Agreement in the event either or both of them are prohibited to share information by any legislation.

Powers to share

Under the Health and Social Care (Safety and Quality) Act 2015, the Parties have a legal duty to share information with each other for the care of a patient. This means that unless an individual object, patient identifiable information must be shared between health or adult social care commissioners or providers in order to provide health services or social care that are in an individual's best interests.


For Healthcare Purposes

GDPR 2016 Article 9 Processing of special categories of personal data states that processing of personal data revealing racial or ethnic origin. religious beliefs, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation shall be prohibited unless: -

(2h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards

Sharing patient identifiable information supports the health and care services for which PCN Practices is authorised as a provider of healthcare services to NHS patients.

By signing this Agreement, each Party asserts that it also has a lawful basis to obtain patient identifiable information in relation to the provision of health and care services.

Use case allowances and data

In order for the DPO, Practice Managers, Caldicott Guardians and other senior staff to have assurances of the valid and appropriate application of this Agreement within Bolton Central PCN as well as with external providers and care organisations, a set of pre-determined scenarios when data sharing is likely to occur have be considered. These are defined below and present the scope of the sharing agreement.

It should be noted that whilst this agreement need only be reviewed in its entirety on an annual basis, preferably in sync with annual practice Data Security and Protections Toolkit reviews.

For each use case presented below, it is important for each practice to identify and confirm which patient data will be made available for sharing purposes. Thus, the tables below provide the framework for the use cases and the datasets available for sharing; the Caldicott Guardian sign-off pages, provided within this document, will have been personalised by each site Guardian at the time of signing.


Information sharing scenarios

Use Case description

Access term

Remote electronic consultation

When a patient requests a remote electronic consultation, the clinician-on-call will access the patient record from within their local PAS

For duration of the appointment booking

Extended clinic appointment

A patient attending an early morning/late evening appointment when their own Practice is closed; the clinician can see their medical history and add a new journal entry resulting from the appointment.

For duration of the appointment booking

Inter-site appointment booking

When a clinic is being run at another Practice, receptionist can book patient appointment slots remotely

Duration of the Agreement

Clinical project monitoring

Database search queries to check the quality and consistency of data being collected in patient records for patients involved in a clinical study

Duration of the project

Multi-disciplinary meetings

Collective, remote review of patient records to enable expert clinical review and decision making

For duration of the appointment booking

Specialist, ad hoc clinic

Conducting regional, specialist clinics, e.g. immunisation, where records from multiple practices will be accessed and updated

For duration of the appointment booking

MIU access

Accessing and then updating patient records with observations and outcomes following an MIU episode

For duration of the appointment booking

Remote care sites

Accessing and then updating patient records where they are based in a hospice or care home

For duration of the appointment booking

Digital health products

Appending information collected through peripheral devices (digital cameras) to a patient’s record

For duration of the appointment booking

3rd party referrals

Sharing relevant data between a practice and an approved service provider, e.g. Allied Healthcare Professional (AHP) podiatry service

Duration of the Agreement

Research studies

Conducting regional queries to generate report-level datasets for clinical research to enable intrinsic service provision improvements as well as support academic study

Case-by-case basis





Roles and responsibilities


Every member of staff should understand what “shared access of records” means, for their duties, for supporting colleagues as well as for discussing with patients and carers. Some staff members will have specific areas of responsibility and ownership. The proposed breakdown is as follows:


For each role, the Agreement identifies across a range of key aspects, whether that role has direct responsibility or accountability and whether they should be engaged in any decisions, or simply kept informed.


GDPR and National Data Opt Out (NDOO)


On May 25th 2018, GDPR was launched across the UK. In association with this NHS Digital will launch a service for the public to register their desire to limit the use of their data for medical care only.


The national Opt out program and access to it is referred in all PCN practices Privacy Notices.



Privacy Notice


The sharing agreement for the PCN is referred in all PCN practices Privacy Notice which is displayed on their individual websites.


Data Protection Impact Assessment


PCN Practices DPIA provides an assessment of the data handling responsibilities of all the PCN Practices Data Controllers. The Assessment has been conducted in line with the Data Protection Act Principles and as an associated document to be reviewed alongside this Agreement.


Incident reporting


Where any Party identifies a security event related to patient identifiable information, it shall be reported to PCN Practices and to any other relevant Parties as needed.


Incidents graded at severity level 2 shall be reported to the Information Commissioner, the Department of Health and NHS England by the Party responsible for the breach using the IG Incident Reporting Tool, available on the IG Toolkit website.

13. Keeping information secure

The following security measures will be in place:


  • All paper documents will be held in locked cabinets when not in use
  • Fax only to be sent to safe havens
  • All staff to follow safe haven processes
  • Email confidential information should be sent by NHS email to NHS email
  • All information to be encrypted if NHS email is not available, confidential information must be attached to the email as password documents and passwords to follow by text or phone
  • Electronic patient records will be accessed by smart card
  • Each smartcard is unique to the user for audit purposes
  • The information shared between the Parties must not be disclosed to any third party
  • Each Party shall ensure that access to information provided by the other Party under this Information Sharing Agreement will only be granted to those staff who ‘need to know’ the information
  • Any services provided by PCN Practices will have arrangements for recording and investigating serious untoward incidents and near misses, and the processes they have in place for learning from these incidents in collaboration with the GP practice. Each practice will use their local investigation methods and with this agreement share any findings with York North Locality Practices.
  • The Parties shall comply with the requirements of the current Information Governance Toolkit in handling the shared information securely

Responsibility for data exchanging and ensuring data accuracy

  • Caldicott Guardians within each practice who have signed the Information Sharing Agreement as having overall responsibility within their own organisation have the duty for ensuring the organisation has the necessary powers to share the information requested
  • Any information shared must only be used for the purpose as requested
  • The Parties in discharging their obligations under this Information Sharing Agreement shall comply with the eight Data Protection Principles
  • The Parties shall ensure that the information shared is relevant and proportionate to the purpose for which it is shared and comply with the Data Protection Principles
  • Information will not be passed to any third party other than allowed by law
  • Retention for the intelligence purposes shall be allowed but only in line with the Data Protection Principles. All Parties involved have agreed that the service users (data subjects) need to be informed of the following:
  • What information is going to be shared
  • In what format is the data going to be exchanged
  • Who the information is going to be shared with
  • For what purposes it will be usedUnless by doing so would risk harm to self or others or hinder any investigation or legal proceedings. It is the responsibility of each Data controller (GP Practice) to inform their patients about the information listed above.Each Party must appoint a single point of contact who must work together to ensure the processes of the agreement are fully adhered to.

Breach of Confidentiality

Any information breaches e.g. theft, loss, damage or inappropriate disclosure of information must be reported in accordance with PCN Practices Information Security Policy.           

No data should be stored on the hard drive and if so, it should be securely removed and transferred as soon as possible.           





In the following section the Agreement sign-off sheets for your practice is provided. Please fill in the use case table for your practice, signing it as appropriate and sending a scanned copy of the page to the Agreement Manager.


Practice Name

Great Lever One

Practice ID


Practice Manager

Brian Smith

Caldicott Guardian

Dr N Sidda

As Caldicott Guardian for the above referenced Practice, I authorise the sharing of our patient information for the purpose of medical care provided by ourselves as well as other Practices in the Primary Care Collaborative. In addition, information may be shared with approved 3rd party entities to whom care referrals are made for the provision of specialist care services.


As Caldicott Guardian for the above referenced Practice, and along with/as the Practice Manager, we will uphold the guidance set out in this Agreement, ensuring PAS configuration settings enables appropriate data sharing, that all staff and patients are adequately informed on the breadth of the Agreement’s application and that information governance diligence is applied to monitor data sharing and mitigate the risk of data breaches and/or inappropriate access and misuse.


As Caldicott Guardian for the above referenced Practice, I agree to the principle of sharing patient information for the purposes of research either to directly support and benefit patients registered at this practice, but also to support the aims of the Bolton Central PCN and the CCG to provide the best quality and appropriate care. In addition, if access is requested for research to support other purposes, these will be individually assessed and reviewed by all Caldicott Guardians, PCN Practices the Data Protection Officer prior to any permission being provided.

As Caldicott Guardian for the above referenced practice, I permit the sharing of the following data types for the associated purposes. This table is to be completed by the Caldicott Guardian at the time of signing.


Information sharing use case

Demographic data

Personal Identification

Patient-sensitive data

Remote consultation arranged online




Extended clinic appointment




Inter-site appointment booking




Clinical project monitoring




Multi-disciplinary meetings




Specialist, ad hoc clinic




MIU access




Remote care sites




Digital health products




3rd party referrals




Research studies




Signed Brian Smith

Date 10/06/2019