Cranwich Road Surgery Privacy Policy
Effective Date: October 2025
Reviewed by: Practice Manager - G. Rajah
Next Review Due: October 2026
Introduction
At Cranwich Road Surgery, we are committed to protecting your privacy and the confidentiality of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect your personal data, in compliance with the Data Protection Act 2018, which incorporates the UK General Data Protection Regulation (UK GDPR).
Our primary purpose is to provide safe, high-quality care. To do this, we must collect, store, and, when necessary, share information about our patients.
Who We Are
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Data Controller: Cranwich Road Surgery
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Data Protection Officer (DPO): NHS North East London ICB
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Address: 4th Floor, Unex Tower, 5 Station Rd, London, E15 1DA
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Email: itservicedesk.nelicb@nhs.net
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Phone: 0800 917 8607
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Information We Collect
We may collect and process the following types of data:
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Personal identification: name, address, date of birth, NHS number
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Contact details: telephone number, mobile number, email
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Demographic information: gender, ethnicity, occupation, family members, carers
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Medical data: appointments, test results, diagnoses, treatment plans, referrals, prescriptions, allergies, and medical history
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Correspondence: with you and other care providers
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Lifestyle information where relevant: smoking, alcohol intake, social circumstances
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Safeguarding information (children and vulnerable adults)
All medical records are treated as special category (sensitive) data, and handled with heightened care.
Why We Process Your Data
We process your data to provide direct care. This includes:
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Diagnosing and treating health conditions
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Referring you to other services (e.g. hospitals, community care)
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Managing prescriptions
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Delivering preventative care
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Responding to emergencies
We also process anonymised or pseudonymised data to:
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Audit services and improve quality of care
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Conduct research and development
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Plan future NHS services
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Monitor safety and outcomes
Legal Basis for Processing
The legal bases under GDPR for processing your data include:
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Article 6(1)(c) – Legal obligation
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Article 6(1)(e) – Public task
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Article 9(2)(h) – Provision of health or social care
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Common Law Duty of Confidentiality – Implied consent for direct care
Who We Share Information With
Your data may be shared with:
- GPs, nurses, and admin staff at the surgery
- Hospitals and specialists
- Community services (e.g. district nurses, health visitors)
- Pharmacists
- Mental health services
- Local authorities and social care providers
- NHS England, ICBs, NHS Digital
- Emergency services
- Coroner’s services (in specific circumstances)
- Voluntary sector (e.g. social prescribing)
- Education Services
- Fire and Rescue Services
- Police & Judicial ServicesThe
- Child Health Information Service
- Substance Misuse Remote Workers
- PCN
We use EMIS Health systems and approved NHS data tools like EMIS Enterprise, Apollo, and INR Star to securely store and process your data.
We do not sell or share data for marketing purposes. We only share information with insurers with your explicit consent.
Communication with You
We may use text messages, phone calls, or emails to:
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Remind you of appointments
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Share test results
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Invite you for vaccinations or reviews
Please ensure your contact details are up-to-date. You can opt out of these communication methods at any time.
We may also use YouTube or online media for public health messaging; patients can opt out of this communication.
Summary Care Record (SCR) & Local Shared Records
All patients have an SCR unless they opt out. The SCR helps clinicians outside the surgery access essential information during emergencies or urgent care.
Locally, we share summary data via One London, a secure shared patient record initiative.
Covid-19 Pandemic and COPI Notices
During the Covid-19 pandemic, under COPI (Control of Patient Information) Notices, data was shared more extensively for:
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Managing outbreaks
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Identifying vulnerable patients
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National vaccination rollouts
These provisions end once COPI notices are withdrawn.
Automated Data Use
We may use automated tools and algorithms (e.g., risk stratification software) to identify high-risk patients, such as those likely to fall or need shielding.
Patients can opt out of automated processing after the COPI notice is withdrawn.
Research & Planning
We contribute anonymised/pseudonymised data to support NHS research and planning. Identifiable data is only used for research with your consent.
More information is available from NHS Digital:
GP Data for Planning and Research Privacy Notice
Your Rights
You have the right to:
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Access your information
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Correct inaccurate data
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Object to specific uses of your data (Article 21)
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Opt out of data being used for planning/research (via Your NHS Data Matters)
You cannot opt out of your data being used for direct care.
How Long We Keep Your Data
We retain records in line with the NHS Records Management Code of Practice. Medical records are retained for your lifetime and transferred when you move practice.
More information:
Records Management Code of Practice
How We Store Your Data
We store your data on secure systems managed by:
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EMIS Health (Cloud-based records)
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INR Star (For patients on warfarin – managed by LumiraDX)
All data is stored in UK Government-approved data centres.
Safeguarding and Caldicott Guardian
The practice has a duty to safeguard vulnerable adults and children. Where necessary, information may be shared with appropriate agencies in the patient’s best interests.
Our Caldicott Guardian (a senior GP) ensures any data sharing is proportionate and lawful. Their decisions are final.
Data Processors
We may use approved third-party processors to deliver services, including:
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EMIS Health
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LumiraDX (INR Star)
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Other NHS-contracted IT and clinical service providers
All data processors are under strict confidentiality and security obligations.
Complaints and Queries
If you have a question or concern about how your data is handled:
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Contact the Practice Manager
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Or, contact our Data Protection Officer at:
NHS NEL GP DPO Service
NHS North East London
9th Floor
20 Churchill Place
London
E14 5HJ
DPO Email: nel.gpdpoig@nhs.net
For advice and guidance on data breaches, directly email the DPO at nel.gpdpoig@nhs.net.
If you are not satisfied, you can escalate the issue to the:
Information Commissioner's Office (ICO)
Website: www.ico.org.uk
Helpline: 0303 123 1113
Address: Wycliffe House, Water Ln, Wilmslow SK9 5AF
National Data Opt-Out
To manage your NHS data preferences for planning and research:
Visit: www.nhs.uk/your-nhs-data-matters
Changes to This Policy
We review this policy annually or when there are significant changes in law or practice.
- Cranwich Road Surgery
62 Cranwich Road, N16 5JF - 020 8802 2002
This document reflects our commitment to transparency, patient privacy, and high-quality care. If you have any concerns, please contact the surgery and speak to the Practice Manager
COVID-19 Vaccination Programme (PCN Delivery)
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Article 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; and
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Article 9(2)(h) – processing is necessary for the management of health and care systems and services, and the provision of health or social care.
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Be informed about how their information is used.
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Access their information (Subject Access Request).
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Object to or restrict certain types of processing (where applicable).
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Request correction of inaccurate information.
NHS NEL GP DPO Service
NHS North East London
9th Floor
20 Churchill Place
London
E14 5HJ
DPO Email: nel.gpdpoig@nhs.net
Learning Disability Register Reconciliation Project
Spring Hill Practice is participating in a Learning Disability Register Reconciliation Project with Springfield Park Primary Care Network (PCN) and local NHS and health and care partners. The purpose of this project is to improve the accuracy of our Learning Disability Register and help ensure that patients receive appropriate care, support, and reasonable adjustments.
Why We Use Your Information
We may review information held within your GP record to identify patients who:
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Have a learning disability but are not currently recorded on the GP Learning Disability Register.
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May have inaccurate, incomplete, or outdated coding relating to a learning disability.
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May be eligible for an NHS Annual Learning Disability Health Check.
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Require reasonable adjustments to support access to healthcare services.
Accurate recording helps ensure patients receive the right care, support, communication, and access to services.
What Information We May Use
We will only use the minimum information necessary for this project, which may include:
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NHS number
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Name
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Date of birth
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GP practice details
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Learning disability-related clinical codes
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Learning Disability Register status
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Limited demographic information where necessary to support identification and reconciliation
This information is already held within your GP record.
How We Use Your Information
Authorised staff may review patient-level information to determine whether patients are correctly included on the Learning Disability Register.
This may involve comparing information held within the GP record with information provided by authorised NHS and local authority partners where there is a lawful basis for doing so.
Where a discrepancy is identified, the Practice may review and update the patient's clinical record where clinically appropriate.
No automated decision-making or profiling is used as part of this project. Any amendments to patient records will be reviewed and completed by appropriately authorised staff members.
Who We May Share Information With
For the purposes of this project, information may be shared, where necessary and proportionate, with:
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Homerton Healthcare NHS Foundation Trust Learning Disability and Autism Services
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Other authorised health and care professionals involved in the Learning Disability Register Reconciliation Project
Information will only be shared where necessary to support direct care, improve the accuracy of GP records, and ensure eligible patients receive appropriate services.
Information will never be sold or used for marketing purposes.
Lawful Basis for Processing
Processing of personal data for this project is carried out under:
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Article 6(1)(e) UK GDPR – Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
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Article 9(2)(h) UK GDPR – Processing is necessary for the provision or management of health and social care services.
The common law duty of confidentiality is satisfied through the use of information for direct care purposes and the management of health and care services.
How We Keep Your Information Safe
We protect your information through:
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Secure NHS-approved systems
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Role-based access controls
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NHS Smartcards or approved secure authentication
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Access restricted to authorised staff
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Audit logging and monitoring
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Secure NHS communication systems
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Staff confidentiality obligations
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Mandatory Information Governance and Data Protection training
How Long We Keep Information
Patient information forms part of the GP record and is retained in accordance with the NHS Records Management Code of Practice.
Any temporary reconciliation files created for the project will only be retained for as long as necessary to complete the work and will then be securely deleted.
Where project reporting is required, information will be anonymised or aggregated wherever possible.
Your Rights
You have the right to:
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Be informed about how your information is used.
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Access your personal information.
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Request correction of inaccurate information.
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Object to certain types of processing.
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Request restriction of processing in certain circumstances.
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Raise concerns about how your information is being used.
Further information about your data protection rights can be found within this Privacy Notice or by contacting the Practice Manager or the Practice Data Protection Officer.
Reviewed it by M O’Garro in June 2026.
Next review due in June 2027.