Whilst NAViGO is continuing to provide services in the current coronavirus pandemic, some requests for personal data or requests under Freedom of Information may be delayed. Your personal data remains protected as usual.

NAViGO already holds data regarding service users, employees and stakeholders. You may have provided this information for a specific reason and normally we would seek to inform you that the data provided would be used for a different purpose. Due to the changing situation this will not always be possible. If we already hold information regarding vulnerability, as defined in the current guidance from the Government and Public Health England, we may share this for emergency planning purposes or to protect your vital interests by sharing with services both inside and outside NAViGO, this may be with other public authorities, emergency services, and other stakeholders as necessary and proportionate to do.

We may, in this current crisis need to ask you for personal information including sensitive personal information for example your age or if you have any underlying illnesses or are vulnerable, that you have not already supplied. This is so NAViGO can assist and prioritise its services.

During this time, NAViGO will be adapting the way it communicates and offers services to you. This will be in order to protect persons coming into contact with the COVID-19 virus and to limit personal contact, unless absolutely necessary. We may offer you telephone or video contact instead of face to face in the current circumstances. This will be in line with NHS guidance and we will ensure relevant security is in place, to continue to protect your personal data. Our staff will be advised on the best way to contact you and you will be given information as necessary. We do not need you to consent to these alternative methods of communication, other than to accept the invitation to communicate by telephone or video conference. As a Healthcare Provider, we are allowed to send you necessary updates on health information, as these are not considered to be marketing.

NAViGO Health and Social Care Community Interest Company take your confidentiality and privacy rights very seriously. NAViGO is a data controller and this notice explains how we use your personal information and is part of your right to be informed about your personal data under the General Data Protection Regulation (GDPR).

Health data is what is called ‘special category data’ and as it is very personal it requires special protection. NAViGO processes your data under Article 6(1)(e) as part of our Public Task and also under Article 9(2)(h) for medical diagnosis and treatment. All this means is that we have lawful reasons to process your data and only use it for these purposes and other purposes allowed by law.

Consent

NAViGO have received direction from Dame Fiona Caldicott (National Data Guardian) that our clinicians have been given permission to look at mental health records of service user’s, even if they are not part of the care team. This has only be granted for a period of 3 months, commencing on 30 March 2020 and will only be done in absolute emergency during the COVID-19 outbreak and clinicians will have to document why they have accessed the notes. Monthly audits will be conducted to ensure that staff have followed appropriate guidelines.

Mental health and social care professionals working with you – such as doctors, nurses, support workers, psychologists, occupational therapists, social workers and other staff involved in your care – keep records about your health and any care and treatment you receive.

This may include:

  • Basic details such as name, address, date of birth, phone number, and email address – where you have provided it to enable us to communicate with you by email
  • Your next of kin and contact details
  • Notes and reports about your physical or mental health and any treatment, care or support you need and receive
  • Results of your tests and diagnosis
  • Relevant information from other professionals, relatives or those who care for you or know you well
  • Any contacts you have with us such as home visits or outpatient appointments
  • Information on medicines, side effects and allergies
  • Patient experience feedback and treatment outcome information you provide

Most of your records are electronic and are held on a computer system and secure IT network. We may receive information about you from other people e.g. from your GP practice, a friend or relative or another health or care professional.

Your information is used to provide you with health and care services and is necessary for us to:

  • have all the information necessary for assessing your needs and for making decisions with you about your care
  • have details of our contact with you, such as referrals and appointments and can see the services you have received
  • can assess the quality of care we give you
  • can properly investigate if you and your family have a concern or a complaint about your healthcare

Professionals involved in your care will also have accurate and up-to-date information and this accurate information about you is also available if you:

  • Move to another area
  • Need to use another service
  • See a different healthcare professional

Mental Health and Social Care Professionals: Your information will be shared with the team who are caring for you and are providing treatment to you. As part of health & safety, our staff may carry a works mobile phone or a lone working device which may store location data when activated.

However, the NHS and other agencies, including social services and private healthcare organisations work together, so we may need to share information about you, with other professionals and services involved in your care.

We do this in order to provide the most appropriate treatment and support for you, and your carers, or when the welfare of other people is involved. We will only share your information in this way if we have your consent and it is considered necessary.

You have the right to refuse/withdraw your consent to information sharing at any time. Please discuss this with your relevant mental health care professional, as this could have implications in how you receive further care, including delays in you receiving care.

We may also use your personal information if you make a complaint or are involved in an incident whilst receiving care or treatment from us. This will be in order for us to investigate your complaint or the incident.

If translation services are required then they will be performed by HE WORDS and your personal data will be sent to them by secure email for translation. More details on their privacy policy can be found on their website.

Our Doctors use an app called S.12 solutions in order to arrange appointments with patients at various locations, which may include a hospital setting if you are an inpatient. Your name, address, NHS Number, GP Practice name and location (e.g. Hospital name and address) will be held on the app in order for the Doctor or other professional to be allocated to you for your care or assessment at a particular date and time. No medical data about you is held by S.12 solutions or on the app.

 

Electronic Palliative Care Co-ordination System (EPaCCS): The health and care providers, who are involved in the care of a service user at the end of their life, will be able to share / access information, as part of the Humber Coast and Vale wider project. More details on their privacy notice can be found here.

 

Confidentiality: A person’s right to confidentiality is not absolute and there may be other circumstances when we must share information from your patient record with other agencies. In these rare circumstances we are not required to have your consent. Examples of this are:

  • If there is a concern that you are putting yourself or another person at risk of serious harm
  • If we have been instructed to do so by a Court
  • If the information is essential for the investigation of a serious crime
  • If you are subject to the Mental Health Act (1983), there are circumstances in which your ‘nearest relative’ must receive information even if you object
  • If your information falls within a category that needs to be notified for public health or other legal reasons, such as certain infectious diseases

We will not share your data for Insurance or Marketing purposes.

NHS Patient Survey Programme (NPSP) is part of the government’s commitment to ensure patient feedback is used to inform the improvement and development of NHS services. We may share your contact information with an NHS approved contractor to be used for the purpose of the NPSP.

Further information: If you need further information, you can email our Data Protection Officer on NAViGO.DPO@nhs.net

To help us monitor our performance, evaluate and develop the services we provide, it is necessary to review and share minimal information, for example with the NHS Clinical Commissioning Groups.

The information we share would be anonymous so you cannot be identified and all access to and use of this information is strictly controlled.

In order to ensure that we have accurate and up-to-date patient records, we carry out a programme of clinical audits. Access to your patient records for this purpose is monitored and only anonymous information is used in any reports that are shared internally within NAViGO.

NHS Digital, on behalf of NHS England assess the effectiveness of the care provided by publicly• funded services – we have to share information from your patient record such as referrals, assessments, diagnoses, activities (e.g. taking a blood pressure test) and in some cases, your answers to questionnaires, on a regular basis to meet our NHS contract obligations.

Most of the time, NHS digital use anonymised data for planning. So your confidential patient information isn’t always needed.

However, you do have a choice about whether you want your confidential patient information to be used.

To read further details about the wider use of your confidential patient information and to register your choice to opt out of it being used for the planning and improvement of health and care services in England, please click here. If you are happy with the use of your information for planning and research purposes you do not need to do anything. However, you can change your choice at any time.

For more information about how NHS Digital use your data please visit:

NHS - Mental Health Services Data Set

NHS - How We Look After Your Health and Care Information

 

Care Quality Commission (CQC) and Accessing Data

As part of their role as the Regulator of Health and Social Care Services in England, the CQC may access care records and other personal data we hold on you. For further details, please see CQC privacy notice.

NAViGO actively promotes research to provide better health and care for you, your family and future generations. Researchers can improve how physical and mental health can be treated and prevented.

As a data controller NAViGO rely upon

  • Article 6(1)(e) ‘…a task carried out in the public interest or in the exercise of official authority vested in the controller’
  • Article 9(2)(j) ‘…scientific or historical research purposes’

as our lawful basis for processing your information under the General Data Protection Regulation. This means we do not rely upon your consent for our Researchers to access information we have collected about you.

However, we do rely upon your consent for you to actively take part in a research study.

We would never publish the outcome of our research studies in a way that would personally identify you.

Whilst actively taking part in a research study you would have the right to withdraw your consent at any point but you would not have the right to the information already collected as part of the research study to be erased.

If you are happy for your personal confidential information to be used for your individual care and treatment and also be used for research and planning you do not need to do anything.

However, if you do not want your personal confidential information used in this way you have the right to object/Opt out to your information being used for research and planning by registering your choice via Your NHS Data Matters.

If you do choose to opt out you can still consent to your data being used for specific individual research and or planning purposes.

For further details on how your information is used in research please visit the NAViGO Website or you can contact our Research and Development (R&D) Department.

Professor Zaffer Iqbal – Head of Psychology

Telephone: (01472) 808503

Email: z.iqbal1@nhs.net

Information about our current research studies and sponsor details can be found on our Research web page.

 

As a healthcare provider we use and store large volumes of personal information every day and have appropriate technical and organisational measures in place to protect your information whether it is in paper or electronic format.

NAViGO is registered to the Information Commissioner’s Office; registration number ICO:04800000737

All of the Information Systems used by NAViGO, including CCTV and call recording at our inpatient units, which are hosted by F4 IT, are implemented with robust information security safeguards to protect the confidentiality, integrity and availability of your personal information. The security controls adopted by NAViGO are influenced by a number of sources including the 10 National Data Guardian Standards and guidelines produced by NHS Digital and other Government standards.

F4 IT is accredited to Industry Standard IS027001 which is an internationally recognised information security framework; registration number IMS UK/01/0715403363

All employees and our partner organisations are legally bound to respect your confidentiality and all staff must comply with our security operating procedures. Any breach of these is treated seriously, and could result in disciplinary action, including dismissal.

If any of your personal information is to be processed overseas (i.e. outside the EU) a full risk assessment would be undertaken to ensure the security of the information.

If you need further information, you can email our Data Protection Officer NAViGO.DPO@nhs.net

We are legally required to keep your health records for certain periods and all records held by the NHS are subject to the Records Management Code of Practice for Health and Social Care Act 2016 (the Code).

The Code sets out best practice guidance on how long we should keep your patient information before we are able to review and securely dispose of it.

You have a right to see the information we hold about you, both on paper or electronic, except for information that:

  • Has been provided about you by someone else if they haven’t given permission for you to see it
  • Relates to criminal offences
  • Is being used to detect or prevent crime
  • Could cause physical or mental harm to you or someone else

Your request must be made either in writing, through email or via phone call and we will request proof of identity before we can disclose personal information.

Access To Records Lead

Telephone: (01472) 583040

Email: NAViGO.PALS@nhs.net

You also have the right to have inaccurate information corrected but this usually only applies to factual information about you and not to the medical opinions or diagnoses of professionals, even if you disagree with them.

To get further advice or report a concern directly to the UK’s independent authority you can do this by making contacting with: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone: 0303 123 1113. Website: https://ico.org.uk/concerns/handling/

NAViGO is a Data Controller and can be contacted at: NAViGO Health & Social Care CIC, NAViGO House, 3-7 Brighowgate, Grimsby, DN32 0SW or on telephone number 01472 583000. The Data Protection Officer can be emailed on NAViGO.DPO@nhs.net

We are collecting your personal data in order to process your membership of our group. Our lawful basis for collecting your personal information and contact details is legitimate interests for both NAViGO in providing a wider service to you and for yourself in engaging in the group. This means that we can use your data for running the group and contacting you about it.

Your data will not be shared with anyone outside of NAViGO but we may be permitted to use your data for some other purposes, such as to prevent or detect crime, to protect public funds or where we are required or permitted to share data under other legislation. If we do this, we will not need your consent, as we will rely on an exemption in the data protection legislation. We will not sell your data to any third parties.

We will keep your data for as long as you are a member of the group or whilst you are on the waiting list. If you wish to be taken off the waiting list please let us know and we will delete your information.

You have the right to access your data and to rectify mistakes, erase, restrict, object or move your data in certain circumstances. Please contact the Data Protection Officer for further information or go to our website where your rights are explained in more detail. If you would like to receive an explanation of your rights in paper format please contact the Data Protection Officer.

Any complaints regarding your data should be addressed to the Data Protection Officer in the first instance. If the matter is not resolved, you can contact the Information Commissioner’s Office at: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF on tel: 0303 123 1113.

Using our website

This privacy policy sets out how NAViGO uses and protects any information that you give NAViGO when you use this website.

NAViGO is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

NAViGO’s telephone calls may be recorded for training and monitoring purposes. NAViGO may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 01/01/2019.

We may collect the following information:

  • name and job title
  • contact information including email address
  • demographic information such as postcode, preferences and interests
  • other information relevant to customer surveys and/or offers

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Internal record keeping.
  • We may use the information to improve our products and services.

We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Our website may contain links to other websites of interest.

However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement.

You should exercise caution and look at the privacy statement applicable to the website in question.

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at comms@nhs.net.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 2018.

If you would like a copy of the information held on you please write to NAViGO.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

The Data Controller

NAViGO Health and Social Care CIC

Telephone: (01472) 583000

 

Caldicott Guardian

Dr Aamer Sajjad – Medical Director/Consultant Psychiatrist

Telephone: (01472) 252366 ext. 14319

Email: aamer.sajjad1@nhs.net

 

Data Protection Officer

Email: NAViGO.DPO@nhs.net

 

Senior Information Risk Officer

Simon Beeton – Director of Finance

Telephone: (01472) 583063

Email: simon.beeton@nhs.net