Practice Policies & Patient Information
Chaperone Policy
Castle Quay Medical practice is committed to providing a safe, comfortable environment where patients and staff can be confident that best practice is being followed at all times and the safety of everyone is of paramount importance. All patients are entitled to have a chaperone present for any consultation, examination or procedure where they feel one is required. This chaperone may be a family member or friend. On occasions you may prefer a formal chaperone to be present, i.e. a trained member of staff. Wherever possible we would ask you to make this request at the time of booking your appointment so that arrangements can be made and your appointment is not delayed. Where this is not possible we will endeavour to provide a formal chaperone at the time of request. However occasionally it may be necessary to reschedule your appointment. Your healthcare professional may also require a chaperone to be present for certain consultations in accordance with our chaperone policy. If you would like to see a copy of our Chaperone Guidelines or have any questions or comments regarding this please ask the practice manager.
Complaints Procedure
We make every effort to give the best service possible to everyone who attends our practice, and we welcome your views and comments. However, we are aware that things can go wrong resulting in a patient feeling that they have a genuine cause for complaint.
If this is so, we would wish for the matter to be settled as quickly and as amicably, as possible. We hope that you will raise any concerns with any member of our team at the time they occur.
Alternatively to pursue a complaint please contact the practice manager Mrs Merissa Kenny who will deal with your concerns appropriately. Alternatively, Dr Nick Connell is our lead GP for complaints.
Data Protection
Data Protection and Patient Privacy Policy – Patient Information
Who we are?
Castle Quay Medical Practice employs more than 34 staff and operates from Castle Quay.
Our Practice is registered with the Office of the Information Commissioner (OICJ) to process personal and special categories of information under the Data Protection (Jersey) Law 2018 and our registration number is 19736.
Why we collect personal information about you?
Our clinical and administration team caring for you will need to collect and maintain information about your health, treatment and care, so that you can be given the best possible healthcare from us. This personal information may be held in a variety of formats, including paper records, electronically on computer systems, in pictures, video or audio files.
What is our legal basis for processing your personal information?
Any personal information we hold about you is processed for the purposes of ‘Employment and Social Fields’ (Article 8) ‘Medical Purposes’ (Article 15) and ‘Public Health’ (Article 16) of the Data Protection (Jersey) Law 2018.
For further information on this legislation please visit: oicjersey.org/data-protection-new-law/
What personal information do we need to collect about you and how do we obtain it?
Personal information about you is collected in a number of ways. This can be from registration forms, referral details from our clinical or administration team, other third party healthcare providers or hospitals, directly from you or your authorised representative.
We will likely hold the following basic personal information about you: your name, address (including correspondence), telephone numbers, date of birth, emergency contact and next of kin contacts, etc. We might also hold your email address, marital status, occupation, residency status, place of birth and preferred name or previous name(s).
In addition to the above, we may hold sensitive personal information about you which may include:
- Notes and reports about your health, treatment and care, including:
- your medical conditions
- results of investigations, such as x-rays and laboratory tests
- future care you may need
- personal information from people who care for and know you, such as relatives and health or social care professionals
- other personal information such as smoking status, alcohol intake and any disabilities
- Your religion and ethnic origin
- Your identified gender or sexual orientation
- Whether or not you are subject to any protection orders regarding your health, wellbeing and human rights (Safeguarding status).
It is important for us to have a complete picture of you as this will assist staff to deliver appropriate treatment and care plans in accordance with your needs.
What do we do with your personal information?
Your records are used to directly, manage and deliver healthcare to you to ensure that:
- The staff involved in your care have accurate and up to date information to assess and advise on the most appropriate care for you.
- Staff have the information they need to be able to assess and improve the quality and type of care you receive.
- Appropriate information is available if you see another healthcare professional, or are referred to a specialist or another part of the Jersey Health Service, social care or other health provider in Jersey, UK or elsewhere.
What we may do with your personal information?
The personal information we collect about you may also be used to:
- Remind you about your appointments and send you relevant correspondence.
- Review the care we provide to ensure it is of the highest standard and quality, e.g. through audit or service improvement;
- Support the funding of your care, e.g. with commissioning organisations;
- Prepare statistics on Primary Care performance to meet the needs of the population or for the Health Department and or other regulatory bodies;
- Help to train and educate healthcare professionals;
- Report and investigate complaints, claims and untoward incidents;
- Report events to the appropriate authorities when we are required to do so by law;
- Contact you with regards to patient satisfaction surveys relating to services you have used within our organisation so as to further improve our services to patients
Where possible, we will always look to anonymise/pseudonymise your personal information so as to protect patient confidentiality, unless there is a legal basis that permits us to use it and we will only use/share the minimum information necessary.
Who do we share your personal information with and why?
We may need to share relevant personal information with other healthcare organisations. For example, we may share your information for healthcare purposes with health authorities such as Jersey Health Department, Social Security Department, NHS UK, Out of Hours Service, other general practitioners (GPs), ambulance services, private consultants, primary or secondary care service providers, etc. We will also share information with other parts of the Jersey Health Department and those contracted to provide services to the Health Department in order to support your healthcare needs. We may need to share information from your health records with other non-Health Department organisations from which you elect to or are also receiving care from, such as Social Services, private consultants, secondary care providers or private care homes. However, we will not disclose any health information to third parties without your explicit consent unless there are circumstances, such as when the health or safety of others is at risk or where current legislation permits or requires it. There are occasions where the Practice may be required by law to share information provided to us with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud. There may also be situations where we are under a duty to share your information, due to a legal requirement. This includes, but is not limited to, disclosure under a court order, sharing with the Jersey Primary Care Governance Team for inspection purposes, the police for the prevention or detection of crime or where there is an overriding public interest to prevent abuse or serious harm to others and other public bodies (e.g. Social Security for the misuse of public funds in order to prevent and detect fraud).
For any request to transfer your data internationally outside Jersey or the UK/EU, we will make sure that an adequate level of protection is satisfied before the transfer.
The Practice is required to protect your personal information, inform you of how your personal information will be used, and allow you to decide if and how your personal information can be shared. Personal information you provide to the Practice in confidence will only be used for the purposes explained to you and to which you have consented. Unless, there are exceptional circumstances, such as when the health or safety of others is at risk, where the law requires it or there is an overriding public interest to do so. Where there is cause to do this, the Practice will always do its best to notify you of this sharing.
How we maintain your records?
Your personal information is held in both paper and electronic forms for specified periods of time as set out in the Information Government Alliance Records Management Code of Practice for Health and Social Care. Whilst this is UK legislation for NHS Providers, it is used in Jersey as a ‘Best Practice Solution’ in the void of our own similar procedures.
We hold and process your information in accordance with the Data Protection (Jersey) Law 2018 and where appropriate the General Data Protection Regulation. In addition, everyone working for our Practice must comply with the Contractual Duty of Confidentiality and various national and professional standards and requirements.
We have a duty to:
- maintain full and accurate records of the care we provide to you;
- keep records about you confidential and secure;
- provide information in a format that is accessible to you.
Use of Email/SMS Text/Other Electronic Communications: Some services in the Practice provide the option to communicate with patients via email, SMS text or other electronic communications. Please be aware that the Practice cannot guarantee the security of this information whilst in transit, and by requesting this service you accepting this risk.
What are your rights?
If we need to use your personal information for any reasons beyond those stated above, we will discuss this with you and ask for your explicit consent. The Data Protection (Jersey) Law 2018 gives you certain rights, including the right to:
- Request access to the personal data we hold about you, e.g. in health records. The way in which you can access your own health records is further explained in our “patient access to medical records policy and request form” which is on our website: castlequaymp.co.uk
- Request the correction of inaccurate or incomplete information recorded in our health records, subject to certain safeguards.
- Refuse/withdraw consent to the sharing of your health records: Under the Data Protection (Jersey) Law 2018, we are authorised for the purposes of ‘Employment and Social Fields’ (Article 8) ‘Medical Purposes’ (Article 15) and ‘Public Health’ (Article 16). Your consent will only be required if we intend to share your health records beyond these purposes, as explained above (e.g. research). Any consent form you will be asked to sign will give you the option to ‘refuse’ consent and will explain how you can ‘withdraw’ any given consent at a later time. The consent form will also warn you about the possible consequences of such refusal/withdrawal.
- Request your personal information to be transferred to other providers on certain occasions.
- Object to the use of your personal information: In certain circumstances you may also have the right to ‘object’ to the processing (i.e. sharing) of your information where the sharing would be for a purpose beyond your care and treatment (e.g. as part of a local data sharing initiative).
- We will always try to keep your information confidential and only share information when absolutely necessary.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter and respond to you accordingly where appropriate.
Who is the Practice Information Governance Lead?
Please Contact:
Dr Nigel Minihane Senior Partner Email:[email protected]
Castle Quay Medical Practice, La Rue De L’Etau
St Helier, JE2 3EH
Who is the Data Protection Officer?
Please Contact:
Michelle Le Verdier, Practice Manager,
Castle Quay Medical Practice,
La Rue De L’Etau,
St Helier,
JE2 3EH
Email: [email protected]
Telephone: 01534 833 833
How to contact the Information Commissioners Office
The Office of the Information Commissioner Jersey (OICJ) is the body that regulates the Practice under Data Protection and Freedom of Information legislation. oicjersey.org/. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the OIC at:
Office of the Information Commissioner
Brunel House, Old Street
St Helier, Jersey
JE2 3RG
Email: Email: [email protected] Telephone: 01534716530
Transferring to another practice
If you decide at any time and for whatever reason to transfer to another practice we will transfer your medical records to your new doctor on receipt of your signed consent from your new doctor.
We hope this information has explained any issues that might arise. If you have any questions please speak to your doctor, any member of the administration team or alternatively ask to speak to the practice manager Michelle Le Verdier.
Data Protection and Patient Privacy Policy – Patient Information
Who we are?
Castlequay Medical Practice employs more than 36 staff and operates from Le Capelin House, Rue de L’Etau, St Helier, JE2 3EH
Our Practice is registered with the Jersey Office of the Information Commissioner (JOIC) to process personal and special category information under the Data Protection (Jersey) Law 2018 and our registration number is 19736.
Why we collect personal information about you?
Our clinical and administration team caring for you will need to collect and maintain information about your health, treatment and care, so that you can be given the best possible healthcare from us. This personal information may be held in a variety of formats, including paper records, electronically on computer systems, in pictures, and video or audio files.
What is our legal basis for processing your personal information?
Any personal information we hold about you is processed for the purposes of ‘Employment and Social Fields’ (Article 8) ‘Medical Purposes’ (Article 15) and ‘Public Health’ (Article 16) of the Data Protection (Jersey) Law 2018.
What personal information do we need to collect about you and how do we obtain it?
Personal information about you is collected in a number of ways. This can be from registration forms, referral details from our clinical or administration team, other third party healthcare providers or hospitals, directly from you or your authorised representative.
We will likely hold the following basic personal information about you:
- name, former names and preferred names
- address
- telephone number
- email address
- bank account details (where charges apply)
- social security number and other unique identifiers
- date of birth
- non-binary or gender expression
- medical history and diagnoses
- observation charts and test results
- next of kin information
- correspondence and communication, via email, telephone calls and letters
- family, lifestyle and social circumstance or safeguarding status
- physical or mental health condition
- racial or ethnic origin
- religious or other beliefs of a similar nature
- sexual life
It is important for us to have a complete picture of you as this will assist staff to deliver appropriate treatment and care plans in accordance with your needs.
What do we do with your personal information?
Your records are used to directly, manage and deliver healthcare to you to ensure that:
- the staff involved in your care have accurate and up to date information to assess and advise on the most appropriate care for you.
- staff have the information they need to be able to assess and improve the quality and type of care you receive.
- appropriate information is available if you see another healthcare professional, or are referred to a specialist or Health and Community Services, or other health provider in Jersey, UK or elsewhere.
What we may do with your personal information?
The personal information we collect about you may also be used to:
- Remind you about your appointments and send you relevant correspondence
- Review the care we provide to ensure it is of the highest standard and quality, e.g. through audit or service improvement
- Refer you to a secondary care provider, such as Health and Community Services
- Request tests and receive results from external testing providers, such as HCS Pathology and Radiology
- Support the funding of your care, e.g. with commissioning organisations;
- Prepare statistics on Primary Care performance to meet the needs of the population or for Health and Community Services and or other regulatory bodies, such as the Jersey Care Commission;
- Help to train and educate healthcare professionals;
- Report and investigate complaints, claims and untoward incidents, in collaboration with the Primary Care Governance Team and Responsible Officer;
- Report events to the appropriate authorities, such as the GMC, when we are required to do so by code of practice, or by law;
- Contact you with regards to patient satisfaction surveys relating to services you have used within our organisation so as to further improve our services to patients
Where possible, we will always look to anonymise/pseudonymise your personal information so as to protect patient confidentiality, unless there is a legal basis that permits us to use it. and we will only use/share the minimum information necessary.
The manner in which Primary Care use and share health and social care data is informed by the Caldicott Principles, a framework for determining ethical and appropriate processing.
When making decisions about how and why we use and share data, we consider whether:
- the purpose of the processing can be justified; is the requirement clearly defined and documented?
- it is necessary to use the data: do we need to identify individuals?
- we are using the minimum necessary information to fulfil the purpose
- do the people processing the data ‘need to know’?
- everyone involved is aware of their responsibilities and obligations
- the processing of the data complies with relevant privacy legislation
- the duty to share for care and treatment is as important as the duty to protect patient confidentiality
- we are adequately informing patients about how their data is used and the reasons why
More information about the Caldicott Principles can be found here
Who do we share your personal information with and why?
We may share relevant personal and special category information with other health and social care organisations and external organisations. For example, we may share your information for healthcare purposes with Health and Community Services (HCS), Customer and Local Services (CLS), and Children. Young People, Education and Skills (CYPES), , NHS UK, the Out of Hours Service (JDOC), other general practitioners (GPs), ambulance services, private consultants, or external secondary or tertiary care providers, etc.
Health and Community Services
Information is shared regularly with Health and Community Services and other Government departments in order to deliver services and collaboratively care and treat islanders, for example:
- We refer patients to secondary services where we believe you will benefit from further investigation and care, including mental health services and specialists, such as orthopaedic or the diabetes centre.
- We request services and receive results from HCS in relation to pathology and radiology testing and imaging in order to review your needs and determine further treatment, where necessary
- We receive discharge summaries and responses to referrals in order that we are aware of interaction between services and can deliver good outcomes to patients. This includes primary care receiving medicine discharge records following admissions so that safe medication regimes can be maintained across service providers.
- We are provided with vaccination and test events so that we can maintain a record of illness and your immunisations and to ensure that you are appropriately protected from illness. This includes the sharing of Covid test and Covid-19 and seasonal flu data with us.
- We provide to HCS Safeguarding Teams information in order to ensure that they can adequately deliver care to vulnerable people in the community.
- We provide a view of limited data to acute services in HCS, in the form of the Summary Care Record:
The Summary Care Record
- In acute areas of HCS, such as hospital pharmacy and the Emergency Department, healthcare professionals have access to the GP Summary Care Record. This provides a limited view of primary care interaction, medicine administration and demographic, as well as known allergies held within your primary care record.
- The purpose of this share is to ensure that healthcare professionals are able to make decisions based on a holistic view of the patient and improve outcomes. It reduces significantly delays to care due to manual information sharing processes, such as telephone calls and reduces the risks associated with medicine administration across numerous providers.
- We provide data to HCS in order to help administer vaccination and screening programmes, more details about which can be found below:
Use of your information for screening programme purposes
- Screening is a way of finding out if people have a higher chance of having a health problem, so that early treatment can be offered or information given to help them make informed decisions.
- HCS will contact you directly should you be eligible for screening programmes.
- We will use automated data processing in the form of data extraction tools and coded searches to identify individuals who are eligible for screening tests and referrals.
- We will provide information to HCS so that they can accurately identify those that are diagnosed with diabetes. This enables us to contact individuals directly to offer tests to identify diabetic retinopathy, which can cause sight loss if not detected early.
- In all cases, you will have the ability to opt out of programmes when contacted by the HCS screening teams. However, as we consider screening a vital element of preventative healthcare, HCS reserves the right to contact you again after a period of time in order to secure your participation. You may also contact the programmes directly should you change your mind.
Use of your information for immunisation or preventative programme purposes
- Immunisations, such as the Covid-19 vaccination programme, are often delivered in phases, ensuring that those most vulnerable to the effect of diseases are offered the opportunity to protect themselves as a priority. Eligibility is often determined based on diagnoses, conditions, or age and as such, it is vital that the most accurate and up to data sets are used.
- Where required, HCS request demographic data from us based on the eligibility criteria. The data shared is limited to the demographic details of the patient, and does not state the reason for their eligibility. For example, HCS may ask for data relating to those that have a particular type of cancer, have received radiotherapy in the last 6 months, or have a severe liver condition. We provide the names and contact details but not the specific reason as to why the individual is eligible.
- The data is shared securely to those that are administering the programme, and used only for that purpose. Individuals are under no obligation to opt-in to a vaccination or preventative programme.
Digital Health
The 2017 Digital Health Strategy outlined collaborative strategies that would be implemented in order to improve the effectiveness of data sharing and improve the outcomes for patients.
HCS and the Primary Care Body are currently working with other government departments and care providers to deliver the Jersey Health Demographic Service and the Jersey Care Record.
In discovery phase currently, both projects will see data shared to those that ‘need to know’ in order to deliver platforms and databases designed to support your care and treatment. More information about how your data will be processed and shared for these purposes will be found here, once completed.
Other data sharing
We will not disclose any health information to third parties who are not enabling care and treatment, without your explicit consent, unless there are circumstances, such as when the health or safety of others is at risk or where current legislation permits or requires it.
There are occasions where the Practice may be required by law to share information provided to us with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud.
This includes, but is not limited to, disclosure under a court order, sharing with the Jersey Primary Care Governance Team for inspection purposes i.e. to support the role of the Responsible Officer, the police for the prevention or detection of crime or where there is an overriding public interest to prevent abuse or serious harm to others and other public bodies (e.g. Customer and Local Services for the misuse of public funds in order to prevent and detect fraud).
Transferring information to countries within the European Economic Area (EEA) is seen as relatively safe because these countries have strong data protection laws in place. There is a list of countries outside of the EEA that are also deemed safe. If we need to transfer your information outside of the EEA or to a country which is not on the list of safe countries, we will take extra steps to keep your information safe.
The Practice is required to protect your personal information, inform you of how your personal information will be used.
How we maintain your records?
Your personal information is held in both paper and electronic forms for specified periods of time as set out in the Information Government Alliance Records Management Code of Practice for Health and Social Care. Whilst this is UK legislation for NHS Providers, it is used in Jersey as a ‘Best Practice Solution’ in the void of our own similar procedures.
We hold and process your information in accordance with the Data Protection (Jersey) Law 2018 and where appropriate the General Data Protection Regulation. In addition, everyone working for our Practice must comply with the Contractual Duty of Confidentiality and various national and professional standards and requirements.
We have a duty to:
- maintain full and accurate records of the care we provide to you;
- keep records about you confidential and secure;
- provide information in a format that is accessible to you.
Use of Email/SMS Text/Other Electronic Communications
Some services in the Practice provide the option to communicate with patients via email, SMS text or other electronic communications. Please be aware that the Practice cannot guarantee the security of this information whilst in transit, and by requesting this service you are accepting this risk.
What are your rights?
If we need to use your personal information for any reasons beyond those stated above, we will discuss this with you and ask for your explicit consent. The Data Protection (Jersey) Law 2018 gives you certain rights, including the right to:
Right to Access
Request access to the personal data we hold about you, e.g. in health records. The way in which you can access your own health records is further explained in our “patient access to medical records policy and request form” which is on our website:
Right to Accuracy
Request the correction of inaccurate or incomplete information recorded in our health records, subject to certain safeguards.
Right to Restrict
You have the right to request that we restrict the processing of your personal information. You can exercise this right in instances where you believe the information being processed is inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request but we may be required to continue to process your information in order to comply with a legal requirement, to deliver medical care, and fulfil the function of social services and social care.
Right to Withdraw Consent
Where you have been asked to give your consent to process your information, you have the right to withdraw your consent to the further processing of your personal data. However, this may cause delays or prevent us delivering a service to you. We will always seek to comply with your request but we may be required to hold or process your information in order to comply with a legal requirement, to deliver medical care and treatment, and fulfil the function of social services and social care.
Under the Data Protection (Jersey) Law 2018, we are authorised to process data for the purposes of ‘Employment and Social Fields’ (Article 8) ‘Medical Purposes’ (Article 15) and ‘Public Health’ (Article 16).
Your consent will only be required if we intend to share your health records beyond these purposes, as explained above (e.g. research). Any consent form you will be asked to sign will give you the option to ‘refuse’ consent and will explain how you can ‘withdraw’ any given consent at a later time. The consent form will also warn you about the possible consequences of such refusal/withdrawal.
Right to Portability
You can request your personal information to be transferred to other providers
Right to Object
You have the right to object to us processing your data, preventing us from using it. However, this right applies only when we are processing your data for a task carried out in the public interest, an exercise of official authority, our legitimate interests, scientific research or for statistical purposes or for direct marketing purposes.
Right to Complain
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter and respond to you accordingly where appropriate.
Who is the Practice Information Governance Lead?
Please Contact:
Merissa Kenny – Practice Manager
[email protected]
Castlequay Medical Practice
Le Capelain House,
Rue De L’Etau,
St Helier,
JE2 3EH
Who is the Data Protection Officer?
Please Contact: As above 01534 833833
How to contact the Jersey Office of the Information Commissioner
The Jersey Office of the Information Commissioner (JOIC) is the body that regulates the Practice under Data Protection legislation. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the JOIC at:
Jersey Office of the Information Commissioner
2nd Floor
5 Castle Street
St Helier
JE2 3BT
Email: Email: [email protected]
Telephone: 01534 716530
Transferring to another practice
If you decide at any time and for whatever reason to transfer to another practice we will transfer your medical records to your new doctor on receipt of your signed consent from your new doctor.
We hope this information has explained any issues that might arise. If you have any questions please speak to your doctor, any member of the administration team or alternatively ask to speak to the practice manager Merissa Kenny.
Terms & Conditons
Disclaimer
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Whilst every effort is made to ensure the accuracy of the information contained within this website, nothing contained is intended to constitute advice of any sort, whether legal or otherwise and the basis on which you acquire or make use of any information is that the information is suitable for use by you in conjunction with proper advice as to its application and adaptation for your particular requirements.
We will not have any liability to you at all if you use any information without obtaining appropriate advice. By using the Website you agree that in no circumstance shall Castle Quay Medical be liable for any indirect, incidental, special or consequential damages, including, but not limited to, loss of business or profits or any other financial loss, arising out of or in any way connected with the use of the Website or its information, under any law or on any basis whatsoever whether contractual or otherwise.
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Alteration of Terms and Conditions
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Entire Agreement
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Severance
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General
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Jurisdiction
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