GDPR & the Hampshire Health Record/CHIE

Dr Neil Bhatia made this Freedom of Information request to Solent NHS Trust

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was successful.

Dear Solent NHS Trust,

I would like to make a request under the FOI Act.

For the purposes of the Act, please take the date of your receipt of this request as Wednesday 25th April 2018.

I remain interested in how Solent NHS Trust is planning to comply with the EU GDPR requirements for the data that it processes (extracts & uploads) to the Hampshire Health Record (HHR/CHIE).

My understanding remains that you extract and upload data to the HHR purely for direct care purposes (i.e. you do not permit secondary uses).

You have previously responded to a FOI request of mine:

https://www.whatdotheyknow.com/request/4...

"A review of all systems and practices is currently being undertaken in readiness for GDPR and a review of HHR/CHIE is part of this."

I trust that review has now been completed, given the proximity to 25th May.

I am requesting the following information:

1) Please could you tell me which lawful basis, as set out in Article 6 of the GDPR, will *your* organisation be relying upon to enable processing of personal data in this way?

2) Please could you provide me with the procedure that patients must follow in order to express their right to object to such processing (as is their right under Article 21).
Please could you provide me with:

a) the form that they must fill in, or a description of the information that you require from them in order to process their objection

b) to whom they must send their objection (e.g. department, address or email address)

c) confirmation that patients will not simply be told to "go and see your GP" when expressing their right to object (i.e. that *you*, as the data controller, will deal with their objection as per Article 21 and Recital 69)

d) confirmation that any upheld objection will ensure that no data about the patient will be extracted and uploaded to the HHR by Solent NHS Trust, yet still allowing the patient to have a HHR consisting of records derived from the other contributing organisations (including their GP practice)

e) any such policy that you have that, in part or whole, details how HHR "right to object" expressions will be managed by *your* organisation

I would be grateful if you would be kind enough to send me the requested information promptly and in any event not later than the twentieth working day following the date of receipt of my request - that is, by the end of May 24th.

I would be grateful if you would kindly acknowledge receipt of this request as recommended by the ICO (“It would be good practice to acknowledge receipt of requests and to refer to the 20 working day time limit, so that applicants know their request is being dealt with”).

Thank you once again.

Yours faithfully,

Dr Neil Bhatia

Solent FOI, Solent NHS Trust

This is an automated response.

 

Thank you for submitting a request for information under the Freedom of
Information Act 2000.

 

Please note: The start date of your request will be the next working day.
A working day is considered Monday – Friday, 9am – 5pm.

 

You will receive a formal acknowledgement letter and reference number
within two working days.

 

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Solent FOI, Solent NHS Trust

This is an automated response.

 

Thank you for submitting a request for information under the Freedom of
Information Act 2000.

 

Please note: The start date of your request will be the next working day.
A working day is considered Monday – Friday, 9am – 5pm.

 

You will receive a formal acknowledgment letter and reference number
within two working days.

 

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Information Governance Team, Solent NHS Trust

2 Attachments

Dear Dr. Neil,

 

Our Ref: FOI 27 18/19_IGT

 

Thank you for your enquiry dated 26^th April 2018 where you requested
information regarding updated GDPR information.

 

Your request is being dealt with under the terms of the Freedom of
Information Act 2000 and will be answered within twenty working days.

 

If you have any queries about this request do not hesitate to contact me.
Please remember to quote the reference number above in any future
communications.

 

For frequently asked questions and previously released FOI’s please see
our website:
[1]http://www.solent.nhs.uk/page.asp?fldAre...

 

  Information Governance Team

   

  Team: 0300 123 3919

Solent NHS Trust  

Trust Headquarters Email : [2][email address]

Highpoint Venue Email : [3][email address]

Burseldon Rd  

Southampton [4]Description: Description: Description: Description:
Combined
Hampshire
 
SO19 8BR

 

 

[5]Description: Description: Description: Description:
https://www.solent.nhs.uk/../images/sole...

 

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Bell Sadie - Data Protection Officer and Head of Information Governance & Security, Solent NHS Trust

3 Attachments

Dear Dr Bhatia

 

Thank you for your enquiry requesting information under the Freedom of
Information Act 2000.

 

Please find our response to your request attached.

 

If you have a few moments to spare, please complete and return the
attached questionnaire as your feedback will ensure the Trust continues to
provide a good service or make improvements where necessary. Thank you in
advance for your assistance.

 

The information supplied to you continues to be protected by copyright.
You are free to use it for your own purposes, including for private study
and non-commercial research, and for any other purpose authorised by an
exception in current copyright law. Documents (except photographs) can be
also used in the UK without requiring permission for the purposes of news
reporting. Any other reuse, for example commercial publication, would
require the permission of the copyright holder.

 

If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review. Internal review requests should be
submitted within two months of the date of receipt of the response to your
original letter and should be addressed to: Sadie Bell, Head of
Information Governance, Solent NHS Trust Headquarters, Highpoint Venue,
Bursledon Road, Southampton, SO19 8BR, or
[1][email address]

 

Please remember to quote the reference number above in any future
communications.

 

  Sadie Bell

  Data Protection Officer and Head of Information
Governance & Security
Solent NHS Trust
Information Governance Team
Trust Headquarters
 
Highpoint Venue
Tel: 023 8103 2122
Burseldon Rd
E-mail: [2][email address]
Southampton
           [3][email address]
Hampshire
Team E-mail: [4][email address]
SO19 8BR
[5][email address]
 
 
 
[6]Description: Description: Corporate Feedback logo
small - Andrea Hewittv2

 

 

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Dear Bell Sadie - Data Protection Officer and Head of Information Governance & Security,

Thank you very much for your response.

Kind regards,

Dr Neil Bhatia

Dr Neil Bhatia left an annotation ()

More information about NHS data sharing, including:

• The Summary Care Record,
• The Hampshire Health Record (CHIE)
• The Berkshire Health Record (Share Your Care)
• The Manchester Care Record
• The Stockport Health and Care Record
• The Salford Integrated Record
• The West Cheshire Care Record
• The North Staffs and Stoke-on-Trent Shared Record
• The Sutton Integrated Digital Care Record
• The Wirral Care Record
• The Dorset Care Record
• The Bolton Care Record

• Secondary uses of your information
• Local data streaming initiatives
• Remote consultations
• Secure online access to your GP record

can be found at:

www.nhsdatasharing.info