We take our governance as seriously as your care

Policies

What is a privacy notice?

A privacy notice is a statement published by an organisation which explains how personal and confidential information is handled ie why it is needed, who is it shared with and the rights of individuals. This privacy notice is aimed at our patients,  service users and others who may come in contact with our services. A separate privacy notice for staff, bank workers and volunteers  is also available.

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:

  • General Data Protection Regulations (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.

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
  • In addition to the above 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.

Use of Email:
Some of our services provide the option to correspond with patients/service users via email. Please be aware that we cannot guarantee the security of this information whilst in transit, and by requesting this service you are accepting this risk. Please discuss with a member of staff.

How is your information used?

Your record is 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.

We may also use your information to:

  • Carry out clinical audits to monitor and improve the quality of care and treatment provided
  • Train new doctors, nurses, therapists and other relevant staff
  • Undertake patient/service user satisfaction surveys
  • Investigate complaints, legal claims or incidents
  • Manage and plan services, make improvements, public health purposes your information is anonymised when used for this purpose

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.

Who will your information be shared with?

To help provide you with the best possible care, sometimes we will need to share your information with others. However, any sharing of information will always be governed by specific rules and laws. We may share your information with a range of health and social care organisations, including your GP, hospices etc.

We work with a number of NHS organisations and to support this, your information may be securely shared.

Where the sharing involves a non-NHS organisation, a specific information sharing agreement is put in place to ensure that only relevant information is shared and this is done securely in a way that complies with the law.

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 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.

Withdraw consent to the sharing of your health records:

Under the Data Protection Act 2018, we are authorised to share your health records ‘for the management of healthcare systems and services’. Your consent will only be required if we intend to share your health records beyond these purposes, as explained above (for example for research). Any consent form you will be asked to sign will give you the option to ‘refuse’ consent and will explain how you can remove any given consent at a later time. The consent form will also warn you about the possible consequences of such refusal.

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.

Your right to opt out of data sharing and processing

You have the right to refuse (or withdraw) consent to information sharing at any time. This is also referred to as ‘opting out’. There are several forms of opt-outs available at different levels:

Type 1 opt-out

If you do not want personal confidential information that identifies you to be shared outside your GP practice you can register a ‘Type 1 opt-out’ with your GP practice. This prevents your personal confidential information from being used except for your direct health care needs and in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. Patients are only able to register the opt-out at their GP practice and your records will be identified using a particular code that will stop your records from being shared outside of your GP practice.

National data opt-out

The national data opt-out was introduced on 25 May 2018 and replaces the previous ‘type 2’ opt-out. NHS Digital collects information from a range of places where people receive care, such as hospitals and community services. This programme provides a facility for individuals to opt-out from the use of their data for research or planning purposes. The national data opt-out choice can be viewed or changed at any time by using the online service at www.nhs.uk/your-nhs-data-matters.

There are some circumstances where there is a legal obligation for us to process your personal confidential information and you will not be able to opt-out. These include:

  • to protect children and vulnerable adults
  • when a formal court order has been served upon us
  • when we are lawfully required to report certain information to the appropriate authorities e.g. to prevent fraud or a serious crime
  • emergency planning reasons such as for protecting the health and safety of others
  • when permission is given by the Secretary of State or the Health Research Authority to process confidential information without the explicit consent of individuals
  • to protect children and vulnerable adults
  • when a formal court order has been served upon us
  • when we are lawfully required to report certain information to the appropriate authorities e.g. to prevent fraud or a serious crime
  • emergency planning reasons such as for protecting the health and safety of others
  • when permission is given by the Secretary of State or the Health Research Authority to process confidential information without the explicit consent of individuals

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.

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.

Our Director of Nursing (Mary Lewis) is our Acting Caldicott Guardian. She is responsible at Board level for protecting the confidentiality of your information and enabling appropriate sharing. We also have a Data Protection Officer in post to ensure processes and systems are secure (contact details below).

How long do we retain your records?

All our records are stored in accordance with the Records Management Code of Practice for Health and Social Care 2021, which sets out the appropriate length of time each type of record is retained.

All records are appropriately reviewed once their retention period has been met, and the  Organisation will decide whether the record still requires retention or should be confidentially destroyed.

How can you access information we have about you?

Under the terms of the General Data Protection Regulation (GDPR) and Data Protection Act 2018, you have the right to request access to the information we hold about you. 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
  • To see the records of a patient/service user who has died if you are acting as their personal representative or if you have a claim relating to their death (for records of the deceased, requests are processed under the Access to Health Records 1990)
  • On behalf of someone who is not capable of giving their permission because of age or illness for example. You would have to be appointed by a court to do this.
  • Requests for access to records should be made in writing (inc email) to our Data Protection Officer at the following address: Sirona care & health, Kingswood Civic Centre (2nd floor), High Street, Kingswood, South Gloucestershire, BS15 9TR or emailing Sirona.dataprotection@nhs.net. We may ask for additional ID as proof of identity.

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.

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. Alternatively, you can contact our Customer Care Team (Tel: 0300 124 5400).

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.

The Information Commissioner’s Office
Wycliffe House, 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 mind find links to third party websites on our website. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies 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 Policy 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 Policy on your first use of the website following the alterations.

Covid-19 and your information

The health and social care system is facing significant pressures due to the Covid-19 outbreak. Health and care information is essential to deliver care to individuals, to support health and social care services and to protect public health. Information will also be vital for researching, monitoring, tracking and managing the outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations. Existing law which allows confidential patient information to be used and shared appropriately and lawfully in a public health emergency is being used during this outbreak. Using this law the Secretary of State has required health organisations and GPs to share confidential patient information to respond to the Covid-19 outbreak. During this period we may offer you a consultation via telephone or video conferencing. By accepting this invitation and entering the consultation you are consenting to this.

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

Information updated: November 2021

Privacy notice for ChatHealth

What is a privacy notice?

We are the Community Children’s Health Partnership (that is part of Sirona care & health) and we provide healthcare services to children and young people. We collect information from you in order to care for you in the best way. This document is called a privacy notice and it tells you why we collect information about you, how we use that information, how we keep it safe and who we sometimes share it with.

About ChatHealth

ChatHealth is a safe and secure messaging platform which helps you get confidential help and advice from the school nursing team that are employed by us. Your privacy and the safety of your personal information is extremely important to us.

Your confidentiality

Our school nursing team that use ChatHealth messaging usually offer the opportunity for you to ask for help and advice anonymously, without giving your name. Your conversation is also confidential. Except for in some exceptional circumstances, a school nurse will not normally inform anyone that you have been in touch or tell them what you have been speaking about.

Information that is seen when you send text messages

When you send SMS text messages to speak with a school nurse through ChatHealth, the person you are speaking with will only be able to see your mobile phone number, unless you give any further personal details, such as your name or date of birth, as part of the conversation.

Opting out

You can end a messaging conversation at any time by sending the word STOP in a message. This would normally prevent a school nurse from sending any further messages to you.

Supporting you in exceptional circumstances

In some exceptional circumstances, like if something you tell your school nurse gives them reason to believe your safety or someone else’s safety is at significant risk, their duty of care requires further action to be taken. For example, they might notify other healthcare, welfare or emergency services which can help to ensure you are safe and well. If they do need to tell someone else about something you have said, they will usually try to speak with you first.

In exceptional circumstances, information relating to your mobile phone number may be used to try to locate you. If you have sent a STOP message, the school nurse you are speaking with may ask us to over-ride it so they can try and check that you are safe from harm.

Information that is recorded and who can see it

When you speak with a school nurse using ChatHealth messaging, they will keep a copy of the conversation as an electronic record that may be seen by other healthcare staff who follow the same confidentiality rules. The record will include your phone number and any other details you mentioned in your conversation, plus other information, like times that messages were sent and any additional notes made by the school nurse during the conversation. Alternatively, the conversation may be recorded onto an electronic patient record system that we use that can also be seen by your family doctor (GP). However, this will only be the case, if you have given us personal details such as your name or date of birth as part of the conversation.

How records of conversations are used

Keeping records of conversations also enables the school nursing team to fulfil their responsibilities. It makes it possible for us to provide you with the best possible healthcare and advice, including keeping you safe from harm and making decisions with you, about you.

How long information is kept for

Once your school nurse has taken a copy of a messaging conversation, it can be kept for a substantial period of time by Sirona care & health (specifically if you have given use your personal details); for children, this can be until they are well into adulthood. You can ask your school nurse for more information on how your records are managed during a conversation.

We work in partnership with Leicestershire Partnership NHS Trust – who provide the ChatHealth application to us. No information is kept long term by this organisation. Within a few days of your messaging conversation being concluded, it will no longer be seen by staff using ChatHealth. It will be deleted from servers within a month. In the long term, staff only save anonymous statistical information relating to conversations.

Information security

Our technical systems and partners are subject to the same strict information security regulations that apply to all NHS systems and organisations. All information we handle is encrypted whilst being transmitted and whilst being stored. All data storage facilities, including cloud services in the EU and physical data centres in the UK, meet up to the very highest information security standards. All ChatHealth technical staff and partners are bound by strict confidentiality rules which prevent them from sharing, disclosing or onwardly processing information about you.

How you can help

When you send messages to speak with a school nurse through ChatHealth, it is important that you consider the security of the device you send the message from.
Remember to lock your smartphone and any other linked devices if you do not want other people to be able to be able to see your confidential messaging conversations. Please also remember that, when you send SMS text messages to speak with a school nurse through ChatHealth, your chosen mobile network provider also has to act responsibly to ensure the safety of your personal information.

Your feedback

At the end of a conversation with a school nurse, you may be asked for feedback about your experience along the lines of: “Has this conversation helped you today? Please reply back YES or NO with any comments you may have.” Any feedback you give will be collected anonymously and used for reporting purposes and it may be also be used for marketing purposes, for example at a conference, in a journal paper, on our websites or in promotional materials. Please indicate if you would like to be opted out of your feedback being used in this way in your reply.

Your rights

Data protection law gives you rights in relation to the way your personal information is being used. These include the right to access any information which is held about you, the right to change or restrict any information which is being held about you if you think that something is factually incorrect and the right to contact us formally and object to us processing or storing data.

You have a right to erasure, in other words, a right to “be forgotten”, but this does not apply to your use of ChatHealth because we have to store information to ensure we can provide you with safe healthcare.

There are also other rights which aren’t relevant to your use of ChatHealth, such as those relating to ‘data portability’ and ‘automated processing’. See contact details of our Data Protection Officer who can provide further information about your rights.

Legal basis for processing and keeping information

Under the terms of current data protection legislation, we are required to notify you of the legal reasons we are handling your information.

Healthcare

Personal data provided for the purpose of healthcare delivery, management and treatment

6(1)(e) Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Special Category Personal Data provided for the purpose of healthcare delivery, management and treatment:

9(2)(h) Necessary for the reasons of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional.

School nurses using ChatHealth will normally speak with you about how they are using your personal data. Because they have a statutory duty to care for you, there is no legal requirement for them to ask your permission before making a record of the messaging conversations you have with them. Similarly, when speaking with children and young people, school nursing staff using ChatHealth, do not need to ask permission from a parent or guardian. This even applies when they are messaging with younger children, under the age of 13. The UK data privacy laws make this possible so that school nurses can fulfil their responsibilities. There are particular special provisions in law for digital services like ChatHealth which prevent ill-health or offer counselling.

Further questions or comments

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

Privacy policy reviewed and updated March 2022

Who are we?

Sirona care & health is a social enterprise which means we are driven by wanting to make a positive difference to people; we are a not-for-profit organisation which means any profit we do make is reinvested into services or communities so that together we can transform the ways we work for the benefit of all.

Our services span across all age ranges from birth through to end-of-life and include people who may require short term support, those with long term conditions or people with a learning difficulty.

What is our approach?

As part of our wider social responsibility, our commitment to those who use our services and to our community is ensuring we publish a statement outlining any steps we have taken to ensure that slavery and human trafficking is not taking place.

Elimination of slavery and trafficking from our supply chains and our business is important to us as we recognise the significant role that we and others providing health and care services have to play to combat this form of abuse. We are as committed to this as we are in supporting and caring for victims of this 21st century crime.

What do we do?

All new employees have their identity and their right to work in the United Kingdom checked before they are able to start their role and our policies and procedures enable all staff to raise concerns about poor working practices.

We have a clear Raising Concerns policy ‘often referred to as whistleblowing’ which is in place to ensure that staff, volunteers or contractors working for or with us have a clear and open way of raising any concerns they may have and that they are confident to do so.

We will continue to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in our supply chains by using our routine contract management meetings with our providers to address any issues around modern slavery and requesting evidence of supplier’s plans and arrangements to prevent slavery in their activities and their supply chain.

We ensure all staff have access to training on modern slavery and human trafficking and this is delivered within our safeguarding training.

Signed on behalf of Sirona’s Board by Sarah Margetts, Director of HR and Organisational Development, on 9 April 2021

We are required under the Equality Act 2010 to report on our Gender Pay Gap to show how large the pay gap was between our male and female employees each year. Our latest analysis is based on pay on 31 March 2021.

The gender pay gap is the difference in average (or mean) hourly earnings between men and women. This is different to pay inequality, which compares the wages of men and women doing the same job or a job of equivalent value.

Our headlines:-

  • Our Mean gender pay gap is 9.4% which has decreased marginally from one year earlier (10.2%)
  • Our Median gender pay gap is 3% which is significantly lower than the previous year.
  • The Median is looking at the median of women and men pay and then calculating the percentage difference. In 2020 our difference was £1.64 (10.4%) and in 2021 it dropped to £0.48 (3%)]
  • The reason for the decrease in our Median percentage reflects changes in our size, structure and service offer of our organisation. Part of the business was transferred out and these employees were primarily female and were paid in the Lower Quartile.
  • The ratio of women to men employed by Sirona stays the same at approx.. 10:1
  • Sirona has a female Chief Executive and it’s Senior Leadership Team at the time the data was captured comprised of 7 women and 2 men.

Message from Janet Rowse, Chief Executive:

“I am immensely proud to lead Sirona and proud of every colleague who has been working so hard throughout this year, particularly with the challenges brought by the pandemic which has impacted people across our organisation as well as the communities we serve.

“We are committed to ensuring that our workforce has better representation of colleagues from all under-represented groups, and as part of this we will continue to take steps to ensure that we attract more male colleagues into lower banded roles to create greater gender balance.”

“I am pleased to say that our gender pay gap has reduced further from 10.2% last year to 9.4% this year. Our gender pay gap is due to the disproportionate balance of male and female staff groups. We are committed to reducing the gap for our female colleagues to enable them to be in the upper quartile by increasing our development and career progression opportunities.”

“The decrease in our Median average figure is reflected by the changes in our size, structure and service offer of our organisation. Part of the business was transferred out and these employees were primarily female and were paid in the Lower Quartile.”

“However, it is important that we are not complacent and working to further reduce the gender pay gap is an important aspect of being a good employer and as part of our commitment to equality and inclusion we will keep this under review.”

You can read the full gender pay gap report for more information. You can also read the 2019 & 2020 gender pay gap reports.

At Sirona, we want everyone who comes into contact with us to feel welcome – whether you are a team member, someone who uses our services, a family member or a carer, we will respect you as an individual and value your unique experience, ability and contribution.

In our annual Equality, Diversity and Inclusion report you can read how we are working towards a fairer and more inclusive society.

The report shares stories from our staff and service users, tells you about who lives in our communities, and shows the composition and experiences of our workforce, all from a perspective of inclusion. As you will read, we have received awards for our work to support inclusion but we still have more progress to make. So, the final page of the report lists our priorities for next year. You can read the full report by clicking here. You can read our Equality, Diversity and Inclusion Strategy here and our Equality, Diversity and Inclusion Plan here. You can also read our NHS Workforce Race Equality Standard report and action plan here. 

I hope you enjoy reading both of these and we’d love to hear your feedback at sirona.communications@nhs.net

Sarah Margetts

Director of HR