Sirona (Sirona care & health C.I.C) is a Data Controller and is registered with the Information Commissioner’s Office (ICO), registration number is Z2861455. Our registered office is Sirona care & health, 2nd Floor, Kingswood Civic Centre, High Street, Kingswood, Bristol, BS15 9TR.

As an organisation, we are committed to protecting your information and respecting your privacy in accordance with the Data Protection Act 2018 (DPA18) and the UK General Data Protection Regulation (UK GDPR).

This notice explains what information we collect, why we collect it and how we keep it secure. It also explains your rights and our legal obligation. We undertake information audits to establish clear lines on what personal data we hold and what we do with it.

This notice is aimed at our patients, service users and others who may come in contact with our services. A separate privacy notice is available for staff, bank workers and volunteers.  We also have the following Privacy notices that are specific to services we provide:

Community Childrens Health Partnership (CCHP)

ChatHealth (School Nursing Service)

People’s Voice

Staff and Bank workers (Recruitment)

Notification of changes to this privacy notice 

This privacy notice was last updated in May 2023.

If we use your personal data for any new purposes, updates will be made to the policy information and changes communicated, where necessary in accordance with current legislation. For all queries relating to our privacy notice, please email: Sirona.dataprotection@nhs.net

Why we collect information about you

We aim to provide you with the highest quality care. To do this we must keep records about you, your health and the care we have provided or plan to provide to you. It is important for us to have a complete picture as this information enables us to provide the right care to meet your individual needs.

What information is collected and by whom 

The records we keep can be collected in paper form or electronically (or both) and may include:

• Personal details including name, address, date of birth, next of kin, telephone numbers, email addresses.
• We may also hold sensitive personal information including details and records of treatment and care, notes and reports about your health, including any allergies or health conditions; results of x-rays, scans, blood tests etc; contact we have had with you, such as appointments, attendances and home visits; relevant information from people who care for you and know you well, for example, health and social care professionals and relatives; we may also collect other information about you, such as your sexuality, race or ethnic origin, religious or other beliefs, and whether you have a disability or require additional support with appointments (such as an interpreter or advocate).

How do we collect your information?

Your information can be collected in a number of different ways. This might be from a referral made by your GP or another health or social care professional you have seen, or perhaps directly from you in person, over the phone or on a form you have completed.

There may also be times when information is collected from your relatives or next of kin for example, if you are unconscious or unable to communicate.

How the NHS and care services use your information? 

Your personal data and health records are used to plan your care or treatment by doctors, nurses or any other care professionals, such as social care staff, to ensure we provide you with the best possible care.

You may be asked if you would be willing to take part in an approved research project, but you do not have to agree if you do not want to.

Sirona is one of many organisations working in the health and care system to improve care for patients and the public. The information collected about you when you use these services can also be provided to other approved organisations, where there is a legal basis, to help with planning services, improving care provided, research into developing new treatments and preventing illness. All this helps to provide better care for you, your family and future generations.

Our legal basis for processing personal data 

Our business is based on statutory powers which underpin the legal bases that apply for the purposes of the UK GDPR. The legal bases for most of our processing are:

 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 vested in the controller.

 For entering into and managing contracts with the individuals concerned, for example our employees, the legal basis is:

 Article 6(1)(b) – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Where we have a specific legal obligation that requires the processing of personal data, the legal basis is:

Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject.

 Where we process special categories data, for example data including health, racial or ethnic origin, or sexual orientation, we need to meet an additional condition in the UK GDPR. Where we are processing special categories personal data for purposes related to the commissioning and provision of health services the condition is:

Article 9(2)(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 and services

Where we process special categories data for employment or safeguarding purposes the condition 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

Sirona may rely on the following legal bases when processing your personal information:

When required to comply with the law. This may be in circumstances to:

• Communicating when things go wrong: we have a duty which is set out under The Health and Social Care Act 2008 (HSC) 2008 to report incidents, set out in the HSC 2008.
• Safeguard individuals, set out in the (Safeguarding Vulnerable Groups Act 2006), Children Act 1989 & 2004.
• Notify officials of infectious diseases which present significant risk to human health and the wider public, set out in The Public Health (Control of Disease) Act 1984 and the Health Protection (Notification) Regulations 2010.
• Support other organisations with their regulatory requirements, eg Care Quality Commission (CQC), Information Commissioner’s Office (ICO).
• Support detection, investigation or to prevent a serious crime, monitor referral to treatment times and ensuring compliance with the NHS Constitution and the NHS Operating Framework, conduct audits to measure compliance with the law (e.g., Confidentiality Audits), respond to the rights of individuals requests under data protection law, share information relating to vulnerable individuals with emergency services in the event of an emergency (Civil Contingencies Act 2004).
• To support court orders requiring us to share information.

Vital interests 

To protect someone’s life. This may be in circumstances to:

• Share information to safeguard an individual and therefore prevent harm.

Public task 

When carrying out statutory, governmental or statutory functions. This may be in circumstances to:

• Deliver patient care, when responding to complaints or concerns relating to the delivery of care, when monitoring patient pathways, to share information about a patient for their direct care (subject to both the common law duty of confidence, data protection legislation), and statutory duty under section 251B of the Health and Social Care Act 2012, to manage waiting lists, performance against national targets, activity monitoring e.g. number of referrals, when undertaking local clinical audits, commission funding for treatment and/or equipment.

Legitimate interests 

This may be in circumstances to:

• Support business functions, e.g. raising system level tickets, arranging access to system, take photos of service users to publish on twitter and interests’ websites, for general website enquiries, store next of kin data in the event of a medical emergency record of CCTV.

Other legal obligations 

We recognise the importance of protecting personal and confidential information in all that we do, and take great care to meet our legal and other duties, including compliance with the following:

• UK General Data Protection Regulation (GDPR) and Data Protection Act 2018
• Human Rights Act 1998
• Access to Health Records Act 1990
• Health and Social Care Act 2012, 2015
• Public Records Act 1958
• Copyright Design and Patents Act 1988
• Re-Use of Public Sector Information Regs 2004
• Computer Misuse Act 1990
• Common Law Duty of Confidentiality
• NHS Care Records Guarantee for England
• Social Care Records Guarantee for England
• International information Security Standards
• Information Security Code of Practice
• Records Management Code of Practice for Health & Social Care 2016
• Accessible Information Standard

Any personal information we hold about you is processed for the purposes of ‘provision of health or social care or treatment or the management of health or social care systems’ and services under chapter 2, section 9 of the Data Protection Act 2018.

How we share your information 

In circumstances where we need to share your personal data; we will always ensure this is conducted lawfully and account the justifications for doing so.

When sharing data external to our organisation, Sirona will always assess the potential benefits and risks to you and others, we will weigh the proportionality for the purpose and what we are trying to achieve by this activity. We will also consider if the objective be achieved without sharing personal data and have measures to ensure adequate security is in place to protect the data when sharing this.

Unless there are exceptional circumstances (such as likely risk to the health and safety of others) or a valid reason permitted by law, we will not disclose any information to third parties which can be used to identify you without your consent.

Sometimes we are required by law to disclose or report certain information that may include details that identify you. However, this is only done after formal authority by the courts or by a qualified health professional. This may include reporting a serious crime or identification of an infectious disease that may endanger the safety of others as stated above

 

Overseas transfers  

Your information will not normally be sent outside of the United Kingdom (UK). For any request to transfer your data outside of the UK, we will make sure that an adequate level of protection is guaranteed before the transfer happens.

Retention of records

Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for the specific purposes. All NHS patient records are kept in line with the NHS Records Management Code of Practice 2021 and the Retention Schedule.

Sirona will regularly review the length of time we keep your personal data and securely delete information that is no longer needed for the purposes it was originally intended. This process will enable clear and accurate data, keeping it up to date, available and confidential.

National data opt out 

Whenever you use a health or care service, such as attending Accident & Emergency or using community care services, 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.

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 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care.

Protecting your information

Everyone working for, or with Sirona, has a legal duty to keep your information secure and confidential at all times. Staff are trained on requirements of keeping data secure and the Common Law of Confidentiality.  We are committed to protecting your privacy and will only process data in accordance with legislation.

Strict principles govern our use of your information and our duty to ensure that it is kept safe and secure. Your information may be stored within electronic or paper records, or a combination of both. All our records are restricted so that only those individuals who have a need to know the information, can get access. This might be through the use of technology or other environmental safeguards.

What are your data protection rights?  

Right of access
We have a duty to provide you with rights of access to your data when requested.

Under Data Protection Legislation, patients have the right to obtain a copy of their personal records held by us; this is called a Subject Access Request (SAR).

To obtain a copy of your health records, please submit your request to the Sirona Subject Access Request Team.

Mail: Sirona care & health, 2nd Floor, Kingswood Civic Centre, High Street, Kingswood, Bristol, BS15 9TR.

Email: Sirona.dataprotection@nhs.net

You will need to provide your information (e.g. full name, address, date of birth, Hospital/NHS number) and forms of identification.  You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

If you wish for another person to process your request on your behalf, they will need to obtain your written permission to do so before we can provide copies of health records. This ensures we are providing confidential information to authorised persons(s).

An individual may choose to nominate a representative (such as a solicitor or relative) to make a request on their behalf, however when this happens the request must be explicitly authorised by the person (e.g., evidenced by a signed letter of consent).

Those who hold Lasting Power of Attorney for Health and Welfare for an individual can apply for that individual’s records.

You can also apply on behalf of your child, with your child’s consent. If the child is unable to understand, you can see the records providing the doctor in charge of the case decides it is in the child’s best interests.

You cannot make a request to access records of a deceased individual under the Data Protection Act 2018/ UK GDPR.  To see the records of a patient/service user who has died you must be acting as their personal representative or if you have a claim relating to their death. Requests are processed under the Access to Health Records Act 1990.

Further guidance and assistance can be obtained from the Subject Access Request Team.

Under data protection legislation, you also have a right to: 

Be informed 

Be informed about the collection and use of your personal data. This communication is achieved through this privacy notice.

Object and restrict 

The legislation gives individuals the right to object to the processing of their personal data in some circumstances. This will depend on the legal basis (as described above) for processing your information. In order to formally object, you will need to do so verbally or in writing to Sirona.dataprotection@nhs.net

Request the restriction of your personal data, however this will only apply when/if you contest the accuracy of the personal data, the data has been unlawfully processed and/if you oppose erasure and requests. You can make a request for restriction verbally or in writing to Sirona.dataprotection@nhs.net

Rectification and erasure 

Have inaccurate personal data rectified or completed if it is incomplete.

The legislation states that ‘personal data is inaccurate if it is incorrect or misleading as to any matter of fact.’ You can make a request for rectification verbally or in writing to Sirona.dataprotection@nhs.net

Consent 

When you are providing consent for the purpose of processing your personal data and activity, you will always have the freely given right to actively accept and withdraw.

Sirona manages consent when processing data in the following ways:

• Regularly reviewing consent to check that the relationship with the individual and the purpose for processing information has not changed.
• By having appropriate processes in place to refresh consent at appropriate intervals, including any parental consents.
• Acting on withdrawals of consent as soon as reasonably possible.

What we ask of you

Please:

• Let us know when you change address or name
• Tell us if any information in your record is incorrect
• Tell us if you change your mind about how we share the information in your record.

Contact information and further advice

If you would like to know more about how we use your information, require information in any accessible format or language or if (for any reason) you do not wish to have your information used in any of the ways described, please contact:

Data Protection Officer
Sirona care & health
Kingswood Civic Centre (2nd Floor)
High Street
Kingswood
South Gloucestershire
BS15 9TR
Email: Sirona.dataprotection@nhs.net

How can you make a complaint?

You have the right to make a complaint if you feel unhappy about how we hold, use or share your information. We would recommend contacting our Data Protection Officer (contact details above) in the first instance to talk through any concerns that you have.

If you remain dissatisfied following the outcome of your complaint, you may then wish to contact the Information Commissioner’s Office. Please note that the Information Commissioner will not normally consider an appeal until you have exhausted your right of complaint to us directly.

Mail: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113 (local rate) or 01625 545 745
Email: casework@ico.org.uk
Website: www.ico.org.uk

Our website and your information

We take the handling of your information extremely seriously. This includes any information provided via this website. We will retain any information submitted online, in digital and/or hard copy form, in order to respond or deal with any request, enquiry, feedback or other submission you may have made.

While we take every precaution to protect the information supplied to us, we cannot guarantee the safety of emails sent in. All information sent via this website or email is done so at the owner’s risk, therefore you may wish to call us if you need to pass on sensitive or confidential information. Any personal information submitted in the form of a job application will be used only for the purpose of processing that application. You might find links to third party websites on our website. These websites should have their own privacy notices which you should check. We do not accept any responsibility or liability for their notices whatsoever as we have no control over them.

Cookies

By using this website, you may receive certain third-party cookies on your computer. Third party cookies may be used on this website for improvement of our products or services. These cookies are not integral to the services provided by the website. All cookies used by this website are used in accordance with current UK and EU Cookie Law. Certain features of the website may depend upon cookies to function. UK and EU Cookie Law deems these cookies to be strictly necessary. This website uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how users use the website. This, in turn, enables us to improve the website and the products services offered through it. Whilst our use of them does not pose any risk to your privacy or your safe use of the website, it does enable us to continually improve our business.

You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept cookies, but this can be changed. For further details, please consult the help menu in your internet browser. You can choose to delete cookies at any time however you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings.

Changes to this policy

We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law. When such changes occur, we will revise the last updated date as documented in the version control (below).

We reserve the right to change this notice as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website, and you are deemed to have accepted the terms of the notice on your first use of the website following the alterations.

Connecting Care

Connecting Care is a digital care record system for sharing information in Bristol, North Somerset and South Gloucestershire. It allows instant, secure access to your health and social care records for the professionals involved in your care. Relevant information from your digital records is shared with people who look after you. This gives them up-to-date information making your care safer and more efficient.

Further information about ‘Connecting Care’ can be found using the web link below. This includes details about how you can ‘opt out’ of having your information being accessed by appropriate staff.

https://www.connectingcarebnssg.co.uk/

Your contact with local Connecting Care NHS Partner Organisations may result in them seeking your consent to participate in a research study. Where you have consented to participate in such a study, the research team may access the information held by GPs and hospital Trusts through Connecting Care to ensure that your participation (or those that you are responsible for) will not put you at risk of increased harm and is suitable for the aims of the study. If you later choose to withdraw from the study, the research team will discuss the use of your information with you. As part of the consent process, the research team will inform you of the information they would seek access to.

Information updated: May 2023