Privacy Notice - Call Recording

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Hulme Hall Medical Practice has the ability to record telephone calls to protect patients and staff and other health workers. Patients are protected by our having a record of our conversations with you, staff and other health workers are protected from potential abuse. We also occasionally use recordings for staff training and quality control. When you register with us we will make this clear to you and we will also make this clear to you each time you contact us and via our web site and other sources of information Calls that contain only administrative information, such as enquiries about appointments, are only retained for 4 weeks and are then will be routinely deleted. Calls, or transcripts of calls, audio or audio-visual recordings or elements of the discussion you have with the clinicians that contain clinical information may be added to your medical records, but this will be clarified with you at the time. The recordings are stored on the surgery telephone system

1) Data Controller contact details: Hulme Hall Medical Group Smithy Green Cheadle Hulme Cheshire SK8 6LU

2) Data Protection Officer contact details: Umar Sabat Umar.sabat@ig-health.co.uk

3) Purpose of the processing: To facilitate your access to care and in the case of telephone or other audio visual consultations for your direct care.

4) Lawful basis for processing: The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the GDPR: Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’. Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services...” We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality” *

5) Recipient or categories of recipients of the shared data: Necessary data will be shared with Health and care professionals and support staff in this surgery. Clinical data or records of consultations may be transcribed or appended to the records we hold on you and may thence be shared at hospitals, diagnostic and treatment centres who contribute to your personal care. Actual recordings will not be shared with anyone outside the practice. Please see our Privacy Notice for Direct Care. The actual recordings are stored on the telephone system and after a designated period of time will be either deleted or saved, onto the surgery Shared Drive if it is deemed necessary. You will be informed if the recording is to be stored for longer than is set out in this Privacy Notice and you will informed the reasons.

6) Rights to object: You have the right to object to some or all your information being processed (shared) under current data protection legislation (Article 21 the General Data Protection Regulations 2016, and the Data Protection Act 2018).

7) Right to access and correct: Access You have the right to see the data that is being shared about you. This is known as ‘the right of subject access’. You can make a request for this information from a provider. If your health or care provider holds information about you, and you make a subject access request they will:
· Give you a description of it
· Tell you why it is being held
· Tell you who it could be shared with
· Let you have a copy of the information in an intelligible form.
To make a Subject Access Request , you will need to contact your health or care provider’s Data Protection Officer in writing. The contact details for the DPO for each organisation can be found in section 2 of this Privacy Notice as displayed by each individual organisation, or on their website.
Rectification: You have the right to have inaccurate personal data rectified, and in some circumstances removed. Requests to amend or delete data should be made to the individual Data Controller via the DPO, as per the contact information in section 2 of this Privacy Notice. Under current data protection legislation, all data controllers have a responsibility to ensure the information held about you is correct and up to date and must take all reasonable steps to correct or erase incorrect information as soon as possible. All requests to amend or remove information will be addressed on an individual basis by each Data Controller, however, it should be noted that, for example, information recorded by a health or care professional that is believed to be correct at the time of documentation, even when subsequently updated, is unlikely to be removed. There is no right to have accurate medical records deleted except when ordered by a Court of Law

8) Retention period: We will keep recordings up to 4 weeks. Clinical data transcribed from your telephone or other electronic consultations may become part of your clinical record and is retained according to relevant rules and regulations, see Privacy Notice on Direct Care.

9) Right to Complain: You have the right to complain to the Information Commissioner’s Office, you can use this link https://ico.org.uk/global/contact-us/ or calling their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website)

Please note the National Data Opt Out does not apply to this sharing of information. For further information please see: https://www.nhs.uk/your-nhs-data-matters/

Date created: 21.03.2023