What is a privacy notice?
A privacy notice is a statement published by an organisation which explains how personal and confidential information about patients, service users, staff and visitors is collected, used and shared.
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 services provide the option to communicate 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.
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 and regulatory bodies.
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.
Your records will also be shared with us if a service is transferring to us under contract. This includes: Community Children’s Health Partnership services, previously provided by Bristol Community Health, which transferred to Sirona care & health on 1 February 2020; and adult community services in Bristol (previously Bristol Community Health), adult and children’s services in North Somerset (previously North Somerset Community Partnership), and specialist children’s services in North Somerset (previously Weston Area Health NHS Trust) all transferred to Sirona on 1 April 2020.
If you have any questions regarding these changes, please contact Sirona care & health:
Telephone: 0300 124 5403
Post: Data Protection Officer, Sirona care & health, 2nd Floor, Kingswood Civic Centre, High Street, Kingswood, Bristol, BS15 9TR
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.
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
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 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 Medical Director (Kate Rush) is our 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 2016, 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 Company 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
- 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.
- You can request access to your record by 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 email@example.com
What we ask of you
- 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
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.
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.
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)
Information updated: April 2020
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 8 April 2019
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 6 April 2019.
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 mean gender pay gap is 10.5%, narrowed from 15.2% one year earlier.
• The mean gender pay gap is largely because Sirona’s highest paid employees are doctors and this is the case across the NHS. If doctors are removed from the figures, our mean gender pay gap is 3.2%.
• Our median gap is 0.6%.
• The median average figure shows the ‘typical situation’ in the middle of the organisation as it removes any distortion due to very high or very low figures.
• The ratio of women to men employed by Sirona is 9:1
• Sirona has a female chief executive and its Senior Leadership Team at the time the data was captured comprised five women and four men.
Message from Janet Rowse, Chief Executive:
“I am immensely proud to lead Sirona and proud of every single member of staff. Our commitment to the communities we serve is always to find the best person possible to provide care for those who need us.
Like many health and care providers, Sirona is also an organisation with a large proportion of female employees and we have a significant number of females in senior roles.
I am pleased to say that our gender pay gap has reduced from 15.2% last year to 10.5% this year. Our gender pay gap is caused by the difference in the pay of senior clinicians, which is consistent with other organisations providing NHS services. Within Sirona, if we remove our doctors from the figures, our gender pay gap is 3.2% and is a more accurate reflection of the huge amount of work we do to ensure equality across all levels of the organisation. This is an improvement from 4.3% one year ago.
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 report here.
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 firstname.lastname@example.org
Director of HR