Springwell Medical Centre uses CCTV images to provide a safe and secure environment for employees and for patients/visitors to the practice.  We have a CCTV practice policy available if you wish more information.

Springwell Medical Centre has a legal duty to keep information about you confidential. We will not give any information about you to any other person, or give you any information about another person. This includes appointment times, if you are present in the surgery, test results, medication information etc. If you wish any information to be given to another person then we require written confirmation which will then be attached to your record.

DID NOT ATTEND (DNA) POLICY & INFORMATION

What is a DNA?

A DNA (Did Not Attend) is defined as a patient not attending an appointment with any member of the team without cancelling the appointment at least 20 minutes prior to the appointment.

On average there are more than 102 (as of March 2024) DNA’d appointments every month in this practice alone. This is the equivalent to 17.5 hours or 1.75 working days. By increasing awareness of this problem and enforcing our policy we aim to reduce the number of DNA’s to:

• Reduce the number of wasted appointments
• Reduce waiting times
• Provide a prompt service to those who need it
• Reduce pressures on clinical and admin staff who are unable to offer prompt appointments
• Reduce health risks to patients.

ACTION:

Stage 1 – 1^st DNA – Contact is made with the patient (text or letter) to raise awareness and share this policy.

Stage 2 – 2^nd DNA within 6 months of the last – First warning (text or letter) sent to patient along with a copy of this policy

Stage 3 – 3^rd DNA within 6 months of the second – Final letter sent to the patient and a copy of this policy.

Stage 4 – 4^th DNA within 12 months of the last – Letter sent to Lothian Health Board to have the patient removed from our practice list.

We appreciate that on occasions there are special circumstances which may result in a DNA – eg Dementia / hospital admission etc.  Please inform reception if you think this applies to you and the practice will take this into consideration but may still record the DNA but not take any action on the first instance.

Updated April 2024

The Freedom of information Act 2002 provides public access to information held by public authorities. A copy of this document can be obtained by contacting the Practice Manager.

Data Protection Notice

The following notice applies from 4th July 2022.

1. About Springwell Medical Centre
This practice is an independent contractor providing primary medical services by way of a contract with NHS Lothian, made under the National Health Service (Scotland) Act 1978 (the 1978 Act). It is one of the organisations which form part of NHS Scotland (NHSS).

2. About the personal information we use
We use personal information on different groups of individuals including:
• Patients
• Staff
• Contractors
• Suppliers
• Complainants, enquirers
• Survey respondents
• Professional experts and consultants
• Individuals captured by CCTV
The personal information we use includes information that identifies you like your name, address, date of birth and postcode.
We also use more sensitive types of personal information, including information about racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic and biometric data, health; sex life or sexual orientation.
The information we use can relate to personal and family details; education, training and employment details; financial details; lifestyle and social circumstances; goods and services; visual images; details held in the patient record; responses to surveys.

3. Our purposes for using personal information
Under the 1978 Act Springwell Medical Centre has the statutory responsibility to provide or arrange for the provision of a range of healthcare, health improvement and health protection services. We are given these tasks so that we can help to promote the improvement of the physical and mental health of the people of NHS Lothian and assist in operating a comprehensive and integrated national health service in Scotland.

We use personal information to enable us to provide healthcare services for patients (including reminding you of appointments), data matching under the national fraud initiative; research; supporting and managing our employees; maintaining our accounts and records and the use of CCTV systems for crime prevention.

4. Our legal basis for using personal information
Springwell Medical Centre as data controller, is required to have a legal basis when using personal information. Springwell Medical Centre considers that performance of our tasks and functions are in the public interest. So, when using personal information our legal basis is usually that its use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us. In some situations, we may rely on a different legal basis; for example, when we are using personal information to pay a supplier, our legal basis is that its use is necessary for the purposes of our legitimate interests as a buyer of goods and services. Another example would be for compliance with a legal obligation to which Springwell Medical Centre is subject to, for example under the Public Health etc (Scotland) Act 2008 we are required to notify Health Protection Scotland when someone contracts a specific disease.
When we are using more sensitive types of personal information, including health information, our legal basis is usually that the use is necessary:

• for the provision of health or social care or treatment or the management of health or social care systems and services; or
• for reasons of public interest in the area of public health; or
• for reasons of substantial public interest for aims that are proportionate and respect people’s rights; or
• for archiving purposes, scientific or historical research purposes or statistical purposes, subject to appropriate safeguards; or
• in order to protect the vital interests of an individual; or
• for the establishment, exercise, or defence of legal claims or in the case of a court order.
On rare occasions we may rely on your explicit consent as our legal basis for using your personal information. When we do this, we will explain what it means, and the rights that are available, to you. You should be aware that we will continue to ask for your consent for other things like taking part in a drug trial, or when you are having an operation.

5. Who provides the personal information
When you do not provide information directly to us, we receive it from other individuals and organisations involved in the delivery of health and care services in Scotland. These include other NHS Boards and primary care contractors such as GPs, dentists, pharmacists and opticians, other public bodies e.g. Local Authorities and suppliers of goods and services.

6. Sharing personal information with others
Depending on the situation, where necessary we will share appropriate, relevant and proportionate personal information in compliance with the law, with the following:
• Our patients and their chosen representatives or carers
• Staff
• Current, past and potential employers
• Healthcare social and welfare organisations
• Suppliers, service providers, legal representatives
• Auditors and audit bodies
• Educators and examining bodies
• Research organisations
• People making an enquiry or complaint
• Financial organisations
• Professional bodies
• Trade Unions
• Business associates
• Police forces.
• Security organisations.
• Central and local government.
• Voluntary and charitable organisations.

7. Transferring personal information abroad
It is sometimes necessary to transfer personal health information overseas for example if you require urgent medical treatment abroad. When this is needed information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with NHSScotland Information Security Policy.

8. Retention periods of the information we hold

Within Springwell Medical Centre we keep personal information as set out in the Scottish Government Records Management: HEALTH AND SOCIAL CARE CODE OF PRACTICE (SCOTLAND) 2020. The Code of Practice sets out minimum retention periods for information, including personal information, held in different types of records including personal health records and administrative records. As directed by the Scottish Government in the Records Management Code of Practice, we maintain a retention schedule as part of our Records Management policy detailing the minimum retention period for the information and procedures for the safe disposal of personal information.

9. How we protect personal information
We take care to ensure your personal information is only accessible to authorised people. Our staff have a legal and contractual duty to keep personal health information secure, and confidential. The following security measures are in place to protect personal information:
• All staff undertake mandatory training in Data Protection and IT Security
• Compliance with NHS Scotland Information Security Policy
• Organisational policy and procedures on the safe handling of personal information
• Access controls and audits of electronic systems

10. Your rights
This section contains a description of your data protection rights within Springwell Medical Centre
The right to be informed
[Name of Practice] must explain how we use your personal information. We use a number of ways to communicate how personal information is used, including:
• This Data Protection Notice
• Information leaflets
• Discussions with staff providing your care
The right of access
You have the right to access your own personal information.
This right includes making you aware of what information we hold along with the opportunity to satisfy you that we are using your information fairly and legally.
You have the right to obtain:
• Confirmation that your personal information is being held or used by us
• Access to your personal information
• Additional information about how we use your personal information
Although we must provide this information free of charge, if your request is considered unfounded or excessive, or if you request the same information more than once, we may charge a reasonable fee.
If you would like to access your personal information, you can do this by submitting a written request to the Practice Manager at the following address:

39 Ardmillan Terrace, Edinburgh, EH11 2JL

0131 347 1860

Please note, emails from your private email address may not be secure.
Once we have received your request and you have provided us with enough information for us to locate your personal information, we will respond to your request without delay, within one month (30 days). However, if your request is complex we may take longer, by up to two months, to respond. If this is the case, we will tell you and explain the reason for the delay.
The right to rectification
If the personal information we hold about you is inaccurate or incomplete you have the right to have this corrected.
If it is agreed that your personal information is inaccurate or incomplete, we will aim to amend your records accordingly, normally within one month, or within two months where the request is complex. However, we will contact you as quickly as possible to explain this further if the need to extend our timescales applies to your request. Unless there is a risk to patient safety, we can restrict access to your records to ensure that the inaccurate or incomplete information is not used until amended.
If for any reason we have shared your information with anyone else, perhaps during a referral to another service for example, we will notify them of the changes required so that we can ensure their records are accurate.
If on consideration of your request Springwell Medical Centre does not consider the personal information to be inaccurate then we may add a comment to your record stating your concerns about the information. If this is case we will contact you within one month to explain our reasons for this.
If you are unhappy about how Springwell Medical Centre has responded to your request for rectification we will provide you with information on how you can complain to the Information Commissioner’s Office, or how to take legal action.
The right to object
When Springwell Medical Centre is processing your personal information for the purpose of the performance of a task carried out in the public interest or in the exercise of official authority you have the right to object to the processing and also seek that further processing of your personal information is restricted. Provided Springwell Medical Centre can demonstrate compelling legitimate grounds for processing your personal information, for instance; patient safety or for evidence to support legal claims, your right will not be upheld.
Other rights
There are other rights under current Data Protection Law however these rights only apply in certain circumstances. For further information on these rights please visit ico.org.uk/for-the-public.

The right to complain
Springwell Medical Centre employ a Data Protection Officer to check that we handle personal information in a way that meets data protection law. If you are unhappy with the way in which we use your personal information, please tell our Data Protection Officer using the contact details below.

Data Protection Officer
IT Governance
Woodlands House
74 Canaan Lane
Edinburgh
EH9 2TB
Phone – 0131 465 5444
Email: Lothian.DPO@nhslothian.scot.nhs.uk
Please note emails from your private email address may not be secure.
You also have the right to complain about how we use your personal information to the Information Commissioner’s Office (ICO). Details about this are on their website at www.ico.org.uk

11. DataLoch
This GP practice has agreed to take part in the DataLoch research programme. Both your GP practice and NHS Lothian are the data controller for the DataLoch programme (Data is only hosted within NHS Lothian), and are working in partnership with the University of Edinburgh. The aims of the DataLoch programme are to support research for the benefit of local residents in the South-East Scotland region. A Data Sharing Agreement is in place that covers the sharing of patient data with DataLoch, and all approved research is anonymous.
In line with data protection legislation, the legal basis that permits processing of patient data is:
• 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.
• 9(2)(j) – Processing is necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes in accordance with Article 89(1)

The DataLoch website covers the researcher data, public enquiries, and newsletter subscriptions for which the University of Edinburgh is the Data Controller: https://dataloch.org/privacy-notice

Springwell Medical Centre Complaints Procedure

If you have a complaint or concern about the service you have received from the any of the staff working in this practice, please let us know. We take complaints seriously and operate a practice complaints procedure as part of the NHS system for dealing with complaints. Our complaints system meets national criteria.

How to Complain

We hope that most problems can be sorted out easily and quickly, often at the time they arise and with the person concerned.

If your problem cannot be sorted out in this way and you wish to make a complaint, we would like you to let us know as quickly as possible – ideally within a matter of days or at most a few weeks – because this will enable us to establish what happened more easily. If it is not possible to do that, please let us have the details of your complaint:

• Within 6 months of the incident that caused the problem, or
• Within 6 months of discovering that you have a problem, provided this is within 12 months of the incident

Complaints should be addressed in writing, to Ms Ali Parrott, Practice Manager. She will explain the complaints procedure to you and will make sure that your concerns are dealt with as soon as possible. It will be a great help if you are as specific as possible about your complaint. If possible if your letter could include

• Who or what you are complaining about
• Date of the event/s
• What you would like from the complaint (eg apology, explanation, further information)

Alternatively you may ask to arrange an appointment in order to discuss your concerns

What we shall do

We shall acknowledge your complaint within 3 working days and aim to have looked into your complaint within 20 working days of the date when you raised it with us. We shall then be in a position to give you an explanation, or offer a meeting with those involved. In investigating your complaint we shall aim to:

• Find out what happened and what went wrong;
• Enable you to discuss the problem with those concerned, if you would like
this
• Identify what we can do to make sure the problem doesn’t happen again.

Complaining of behalf of someone else

Please note that we keep strictly to the rules of medical confidentiality. If you are complaining of behalf of someone else, we need consent of that person in writing (unless the patients illness or incapacity prevents this) this includes consent to the sharing of their medical information

We hope that we will be able to resolve your complaint internally. However, In addition, if you remain dissatisfied with the outcome of your complaint, you have the option of contacting the Scottish Public Services Ombudsman (SPSO).

The SPSO cannot normally look at:

 a complaint that has not completed our complaints procedure
 events that happened, or that you became aware of, more than 12 months ago
 a matter that has been or is being considered in court.

The SPSO’s contact details are:

SPSO
Bridgeside House
99 McDonald Road
Edinburgh
EH7 4NS SPSO
Freepost EH641
Edinburgh
EH3 0BR Freephone: 0800 377 7330
Online contact: www.spso.org.uk/contact-us
Website: www.spso.org.uk
Mobile site: http://m.spso.org.uk

Reviewed April 2022

Details of Primary Care Medical Services in the area can be obtained from: NHS Lothian, Waverley Gate, 2-4 Waterloo Place, Edinburgh, EH1 3EG.

Your Rights:

• Receive treatment from a general practitioner
• Receive information about health services
• Have your treatment explained to you
• Refuse treatment in front of medical students or be involved in medical trials
• Have a friend or relative with you
• Have access to an interpreter or signer
• Confidentiality
• Have access to emergency medical care
• Complain without discrimination
• Have access to contraceptive or maternity services
• Receive treatment regardless of race, gender, age, social class, religion, sexual orientation, appearance, disability or medical condition.

Your Responsibilities:

• Be on time for appointments
• Tell the surgery if you cannot keep appointments
• Tell your GP if you move house or change telephone number
• Use the emergency services responsibly
• Treat Healthcare staff politely
• Take care of all medication
• Inform any healthcare professional of any other treatment you may be receiving or medication you may be taking that may influence your care
• Comply with your treatment to the best of your ability.

The information recorded about you may be used for reasons other than your personal care, for example, to help protect the health of the general public, to plan for future, to train staff and to carry out medical and other health research. We are involved in research studies which require access to anonymous information (name, address, postcode, full date of birth) are removed. Individual patient’s records are added into a much larger anonymous database from many patients across the UK which is used by researchers outside the practice. This data may be anonymously linked to other data, such as hospital data. If you would like to opt out of this data collection scheme, please let your doctor know and your records will not be collected for use in the anonymous research database. This will not affect your care in any way. If anything to do with the research would require that you provide additional information about yourself, you will be contacted by your GP to see if you are willing to take part; you will not be identified in any published results. If you would like to know more about the data collection scheme, you can speak to the Practice Manager.

We have a zero tolerance policy towards aggression at the practice. Whilst we fully understand the fact that a visit to the doctors may be upsetting or stressful and that some patients are under more stress than others, we will not tolerate any verbal or physical aggression to any member of the practice team or our patients. Any such behaviour will result in the person being removed from the practice list without further warning.