Fair Processing Notice

Introduction

Sentinel recognises how important data protection is and that the data we hold is protected and used in a safe and conscientious manner.

To ensure that your information is kept confidential and that our data is kept safe and secure, all our staff receive training in data protection and information governance before they start work with us. Current staff also have to undertake regular refresher training courses tailored to their individual roles.

Who we are and what we do
We are Sentinel Healthcare South West CiC – a company owned and operated by the GP practices in Plymouth, West Devon and South Hams and cover an area from Looe to Bodmin to Bude to Salcombe. Sentinel Healthcare South West CiC is the Data Controller.

Our address is:

Sentinel Healthcare South West CiC
Unit 1, 5 Research Way
Plymouth Science Park
Plymouth
PL6 8BT

Telephone: 01752 434 102
Email: shs.sentinelclinicaltreatmentservice@nhs.net

We provide interface service to the NHS, research and support to General Practice. We are a not-for-profit social enterprise.


Access to your information

Our staff will only have access to information that is necessary for them to complete the activity they are involved in. This is reflected in Caldicott Principles that access to your information should be on a need-to-know basis only. Staff access of confidential information is monitored to ensure your confidentiality is maintained.


Information we can hold about you

Your name and date of birth;

Caller/carer/next of kin and patient contact details, including full home address, telephone numbers and current location;

Details of each contact we have with you;

Records of your health and wellbeing, including reports from other organisations providing health and social care;

Details of your care and treatment, including clinical notes, assessments, examinations, test results and care you have received; and

Information shared in the public domain (e.g. online/social media), used to improve services and inform feedback, learning and training.

We may also receive relevant medical information from other professionals to support care decisions and record further information if you contact us for feedback, complaints, or concerns.


The Purpose of the Process

Direct Care is care delivered to the individual alone, mostly in our clinics. When a referral to another service is made, necessary and relevant information will be shared to enable appropriate care.


The Lawful Basis of Processing

The processing of personal data for direct care and administration is supported under the following GDPR Articles:

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 medical diagnosis, the provision of health or social care, or treatment.

We also recognise your rights under the Common Law Duty of Confidentiality.


How do we keep your records confidential and secure

We follow strict guidelines and use secure systems to protect your data. Information is only shared with third parties where necessary and recorded accordingly. All our staff are trained in data protection and are bound by confidentiality obligations.


How your records are used

Your records help to:

Guide healthcare decisions

Ensure safe, effective treatment

Support collaboration with other providers

Handle referrals

Investigate complaints or incidents

Provide healthcare statistics and research

Teach and train staff

Conduct service audits

Fulfil legal obligations


How you can access your records

You can request a copy of your records (subject access request) under the GDPR and Data Protection Act 2018. Consent is required when requesting information about someone else.


Using information for purposes other than direct healthcare

We may use anonymised or pseudonymised data for research, audits, service planning, training, and performance monitoring. We will not share identifiable information without consent unless legally required or justified in the public interest.


Third parties we share information with

We may share data with:

NHS Trusts

GPs

Ambulance and emergency services

Social Services and Local Authorities

Child and adult safeguarding teams (e.g. MASH)

NHS 111

Care Quality Commission, ICO

Public Health England

HSCIC and commissioner services

Note: Under the Health and Social Care Act 2012, HSCIC can request identifiable data without consent.


Information/data sharing agreements

We maintain formal agreements with our partners to ensure lawful and secure data sharing.


Your rights

You have the right to:

Confidentiality

Know what data we hold and who we share it with

Access your data

Object to processing under Article 21 of GDPR

Opt out of secondary uses (e.g. research/planning) under DCB3058

Correct inaccurate information

Refuse or withdraw consent for data sharing (unless required by law)

Complaints and further information
To complain, contact the Information Commissioner’s Office (ICO):
ICO Website
Helpline: 0303 123 1113 (local) or 01625 545 745 (national)