Privacy notice

The Trust is committed to ensure that your personal information is processed fairly and lawfully. This notice provides our patients and visitors with information about how we collect, use, retain and disclose personal information as a Data Controller. It also explains what rights you have with respect to your information.

The Trust provides health services at two sites in North West London: Hillingdon Hospital and Mount Vernon Hospital. Services at Hillingdon Hospital include Accident and Emergency, Inpatient care, Day surgery, Outpatient clinics, Maternity & Midwifery and Community Integrated services.

Services at Mount Vernon Hospital include Day surgery in the treatment centre, Minor Injuries Unit and Outpatient clinics. The Trust also acts as a landlord to a number of other organisations that provide health services at Mount Vernon, including East and North Hertfordshire NHS Trust’s Cancer Centre.

We provide clinical services to over half a million patients a year, including over 94,000 Emergency Department attendances. As an NHS Foundation Trust, we have a 25-strong Council of Governors and over 6,000 public members. We employ over 3,500 staff making us one of Hillingdon’s largest employers.

Name and contact details
The Hillingdon Hospitals NHS Foundation Trust
Pield Heath Road
Uxbridge
UB8 3NN
Tel: 01895 238282

Mount Vernon Hospital
Rickmansworth Road
Northwood
HA6 2RN
Tel: 01923 826111

The Hillingdon Hospitals NHS Foundation Trust is registered as a Data Controller with the ICO. Our Registration number is Z2899489.

Why we need your data (purpose) and what it is used for

The Hillingdon Hospitals NHS Foundation Trust needs information about you to ensure we can provide you with the appropriate healthcare and treatment that best suits your needs..

Personal data we hold includes: Name, address, postcode, telephone numbers, NHS number, email address, date of birth and unique hospital number generated via our patient administration system.
We will use this information to contact you to inform you of your appointments /admissions.

Special category (sensitive) data we hold includes: Ethnic origin, religious beliefs, information about health conditions including information relating to disabilities, allergies, mental or sexual health/orientation where relevant. We also keep records about your health and the treatment you receive from the NHS. These records support us to provide you with the best possible care.

• We use a Patient Administration System to electronically record details of when we have seen you, such as hospital admissions, appointments and home visits
• Next of kin details of people you want us to keep informed
• We record and detail treatment and care provided to you, this includes clinical notes about your health and any treatment you receive (electronic & paper) and reports about your health
• Diagnostic test requests & results such as x-rays, blood tests (electronic & paper)
• Information from primary care colleagues, such as health professionals who may have treated you in the community, such as Social Care Teams, Community Nurses, London Ambulance Service

It is important for the Trust to have a complete up to date picture of your care, as this information assists staff involved in your care to deliver appropriate treatment and care plans, to meet your needs.

The lawful basis for the processing

We use people’s data in ways that they would reasonably expect us to. Under the General Data Protection Regulation (GDPR), the Trust relies on the lawful basis that processing is necessary for the performance of a task carried out in the public interest (GDPR Article 6(1)(e)) for most of the processing of personal data.

When we process special categories of data such as your health data, we rely on the lawful basis that it is necessary for the purposes of preventative or occupational medicine, medical diagnosis, and the provision of healthcare (Article 9(2)(h)) or for scientific research and statistical purposes (Article 9(2)(j)).

When you give our staff confidential information to enable them provide you with our services, we are governed by the common law duty of confidentiality.

Sharing your data with others

We may receive or need to share your information with other health care professionals to support direct care. A referral for treatment (electronic or paper) may be received or sent containing your personal details such as name, address, DoB, NHS number, telephone number and brief clinical details requesting advice, diagnostic testing or treatment. We may also need to share your information with organisations that provide contracted services that support your care. These can include:

• General practitioners (GP)
• Primary Care Services
• Other health professionals caring for you such as optometrists, podiatrists etc
• Dentists
• Opticians
• Private health providers/health insurance companies, at your request
• Companies that provide translation services
• Other organisations (eg Social Services) directly involved in your health care
• The NHS Central Register for England & Wales, which contains basic personal details of all patients registered with a GP. This register does not contain clinical information
• Council – notification of births & deaths
• Establish your identity and your entitlement to free NHS treatment
• Undertake statistical analysis
• Collate survey results to help improve service delivery
• Support accounts & auditing
• Provide feedback
• Monitor website usage, information is collected using cookies
• Record conversations when you contact the Appointment Booking Centre
• Support administration functions such as complaints, accidents, incidents data
• Medical insurers for the purposes of administration of a claim for payment of medical expenses
• Record images using CCTV and body cameras to support safety and building security

The information collected about you may be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• improving the quality and standards of care provided
• research into the development of new treatments
• preventing illness and diseases
• monitoring safety
• planning services

This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.

You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care.

To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters. On this web page you will:

• See what is meant by confidential patient information
• Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
• Find out more about the benefits of sharing data
• Understand more about who uses the data
• Find out how your data is protected
• Be able to access the system to view, set or change your opt-out setting
• Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
• See the situations where the opt-out will not apply

You can also find out more about how patient information is used at: https://www.hra.nhs.uk/information-about-patients/ (which covers health and care research); and https://understandingpatientdata.org.uk/what-you-need-know (which covers how and why patient information is used, the safeguards and how decisions are made)

You can change your mind about your choice at any time. Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.

Health and care organisations have until 2020 to put systems and processes in place so they can be compliant with the national data opt-out and apply your choice to any confidential patient information they use or share for purposes beyond your individual care. Our organisation is compliant with the national data opt-out policy.

Sharing your data where there is a legal obligation to do so

There are occasions when we will process or share your information in order to comply with a legal obligation. This can include:

• The police, for the prevention or detection of crime
• Government and the Home Office to protect public funds. This includes verifying that patients are entitled to NHS care and implementing the overseas visitor charging regulations.
• Public Health organisation
• Other local authorities to safeguarding children & vulnerable adult teams
• Trusted system suppliers who process data on our behalf
• NHS Digital when directed by the Secretary of State for Health under the health & Social Care Act 2012
• Organisations with statutory investigative powers such as the Care Quality Commission, the General Medical Council or the Health Service Ombudsman
• Collect data and contribute anonymised data to national clinical audits
• NHS Patient Survey Programme (anonymised reports produced and used to help make service improvements)

Keeping your information & retention periods for the personal data

Everyone working for the NHS has a legal duty to keep information about you confidential in line with the NHS Confidentiality Code of Practice.
The information you provide will be held and stored securely by us and/or our data processors (manual and electronic records).
We follow the Records Management Code of Practice for Health and Social Care 2016. The Code provides guidance on managing records, based on current legal requirements and professional best practice.

Your rights

• Unless subject to an exemption, you have the following rights with respect to your personal data:
• You have the right to object or restrict your data being processed in certain circumstances
• You have the right to request a copy of the information that we hold about you
• You have the right to have inaccurate data corrected about yourself
• You have the right not to be subject to decisions made solely on the basis of automated decision-making processes
• You can discuss withdrawing consent at any time for the use of your data and sharing, for which you will not be penalised for doing so
• We will act on withdrawing consent as soon as we can
• To exercise any of these rights, please contact the Information Governance Team: thh.dataprotection@nhs.net

The right to lodge a complaint

If you have a concern about the way we handle your information: In the first instance please contact us: thh.dataprotection@nhs.net

You can also complain to the Information Commissioner’s Office (ICO) In writing: Wycliffe House, Cheshire SK9 5AF Online: ico.org.uk/global/contact-us/
Tel: 0303 123 1113.

Further information about how your data is used

The Data Protection Officer for the Trust can be contacted by email at: thh.dataprotection@nhs.net.

THH general terms of processing your personal and sensitive data

• We will only collect and use your information where we have lawful grounds and legitimate business reasons to do so
• We will be transparent in our dealings with you and will tell you about how we will collect and use your information
• If we have collected your information for a particular purpose we will not use it for anything else unless you have been informed and, where relevant, your permission obtained
• We will not ask for more information than we need for the purposes for which we are collecting it
• We will update our records when you inform us that your details have changed
• We will continue to review and assess the quality of our information
• We will observe the rights granted to you under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with
• We will train our staff on data security and privacy obligations
• We will ensure we have appropriate physical and technological security measures to protect your information regardless of where it is held
• We will ensure that when we outsource any processes we ensure the supplier has appropriate security measures in place and will contractually require them to comply with these Privacy Principles
• We will ensure that suitable safeguards are in place before any personal information is transferred to other countries if applicable
• We have no intention of sharing data with third-parties for marketing purposes