What is a Complaint?

We regard a complaint as:

• Any expression of dissatisfaction about our action or lack of action, or about the standard of service provided by us or on our behalf.

If you need to complain about something, we encourage you to do so. We also understand that your complaint may involve more than one NHS body or service, or relate to both health and social care services, or it may be about someone working on our behalf. Our complaints procedure covers all of these possibilities.  Please click on the link to view our Complaints Leaflet.

You can also submit your complaint online by clicking here.

The rules for Data Protection changed as from 25th May 2018.

Text Message Reminders

The Practice will send you appointment reminders using the mobile telephone number that patients provided. Patients can opt out of this service by contacting the practice or by responding to a text reminder with the phrase ‘NO TEXT’.

Data Protection Notice

Craigshill Health Centre is compliant with the new changes.  For more information on how we respect your privacy, please click here.

Subject Access Request

To make a Subject Access Request, please complete this attached form.

Further Information

Please ask to speak to the Practice Manager.

GP Data Protection Notice

The following notice applies from 25/10/2024.

1. About Craigshill Health Centre
This practice is an independent contractor providing primary medical services by way of a
contract with NHS Lothian, made under the National Health Service (Scotland) Act 1978 (the
1978 Act). It is one of the organisations which form part of NHS Scotland (NHSS).

2. About the personal information we use
We use personal information on different groups of individuals including:
• Patients
• Staff
• Contractors
• Suppliers
• Complainants, enquirers
• Survey respondents
• Professional experts and consultants
• Individuals captured by CCTV
The personal information we use includes information that identifies you like your name, address,
date of birth and postcode.

We also use more sensitive types of personal information, including information about racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic and biometric data, health; sex life or sexual orientation.

The information we use can relate to personal and family details; education, training and employment details; financial details; lifestyle and social circumstances; goods and services; visual images; details held in the patient record; responses to surveys.

3. Our purposes for using personal information
Under the 1978 Act Craigshill Health Centre has the statutory responsibility to provide or arrange for the provision of a range of healthcare, health improvement and health protection services.  We are given these tasks so that we can help to promote the improvement of the physical and mental health of the people of NHS Lothian and assist in operating a comprehensive and integrated national health service in Scotland.

We use personal information to enable us to provide healthcare services for patients (including reminding you of appointments), data matching under the national fraud initiative; research; supporting and managing our employees; maintaining our accounts and records and the use of CCTV systems for crime prevention.

4. Our legal basis for using personal information
Craigshill Health Centre, as data controller, is required to have a legal basis when using personal information. Craigshill Health Centre considers that performance of our tasks and functions are in the public interest. So, when using personal information our legal basis is usually that its use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us. In some situations, we may rely on a different legal basis; for example, when we are using personal information to pay a supplier, our legal basis is that its use is necessary for the purposes of our legitimate interests as a buyer of goods and services. Another example would be for compliance with a legal obligation to which Craigshill Health Centre is subject to, for example under the Public Health etc (Scotland) Act 2008 we are required to notify Health Protection Scotland when someone contracts a specific disease.

When we are using more sensitive types of personal information, including health information, our legal basis is usually that the use is necessary:
• for the provision of health or social care or treatment or the management of health or social care systems and services; or
• for reasons of public interest in the area of public health; or
• for reasons of substantial public interest for aims that are proportionate and respect people’s rights; or
• for archiving purposes, scientific or historical research purposes or statistical purposes, subject to appropriate safeguards; or
• in order to protect the vital interests of an individual; or
• for the establishment, exercise, or defence of legal claims or in the case of a court order.

On rare occasions we may rely on your explicit consent as our legal basis for using your personal information. When we do this, we will explain what it means, and the rights that are available, to you. You should be aware that we will continue to ask for your consent for other things like taking part in a drug trial, or when you are having an operation.

5. Who provides the personal information
When you do not provide information directly to us, we receive it from other individuals and organisations involved in the delivery of health and care services in Scotland. These include other NHS Boards and primary care contractors such as GPs, dentists, pharmacists and opticians, other public bodies e.g. Local Authorities and suppliers of goods and services.

6. Sharing personal information with others
Depending on the situation, where necessary we will share appropriate, relevant and proportionate personal information in compliance with the law, with the following:
• Our patients and their chosen representatives or carers
• Staff
• Current, past and potential employers
• Healthcare social and welfare organisations
• Suppliers, service providers, legal representatives
• Auditors and audit bodies
• Educators and examining bodies
• Research organisations
• People making an enquiry or complaint
• Financial organisations
• Professional bodies
• Trade Unions
• Business associates
• Police forces.
• Security organisations.
• Central and local government.
• Voluntary and charitable organisations.

7. Transferring personal information abroad
It is sometimes necessary to transfer personal health information overseas for example if you require urgent medical treatment abroad. When this is needed information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with NHSScotland Information Security Policy.

8. Retention periods of the information we hold
Within Craigshill Health Centre we keep personal information as set out in the Scottish Government Records Management Code of Practice for Health and Social Care. The Code of Practice sets out minimum retention periods for information, including personal information, held in different types of records including personal health records and administrative records. As directed by the Scottish Government in the Records Management Code of Practice, we maintain a retention schedule as part of our Records Management policy detailing the minimum retention period for the information and
procedures for the safe disposal of personal information.

9. How we protect personal information
We take care to ensure your personal information is only accessible to authorised people. Our staff have a legal and contractual duty to keep personal health information secure, and confidential. The following security measures are in place to protect personal information:
• All staff undertake mandatory training in Data Protection and IT Security
• Compliance with NHS Scotland Information Security Policy
• Organisational policy and procedures on the safe handling of personal information
• Access controls and audits of electronic systems

10. Your rights
This section contains a description of your data protection rights within Craigshill Health Centre.

The right to be informed
Craigshill Health Centre must explain how we use your personal information. We use a number of ways to communicate how personal information is used, including:
• This Data Protection Notice
• Information leaflets
• Discussions with staff providing your care

The right of access
You have the right to access your own personal information.

This right includes making you aware of what information we hold along with the opportunity to satisfy you that we are using your information fairly and legally.

You have the right to obtain:
• Confirmation that your personal information is being held or used by us
• Access to your personal information
• Additional information about how we use your personal information

Although we must provide this information free of charge, if your request is considered unfounded or excessive, or if you request the same information more than once, we may charge a reasonable fee.

If you would like to access your personal information, you can do this by submitting a written request to the Practice Manager at the following address:

Craigshill Health Centre, The Mall, Craigshill, Livingston, EH54 5DY
Telephone: 01506 432621

Once we have received your request and you have provided us with enough information for us to locate your personal information, we will respond to your request without delay, within one month (30 days). However, if your request is complex we may take longer, by up to two months, to respond. If this is the case, we will tell you and explain the reason for the delay.

The right to rectification
If the personal information we hold about you is inaccurate or incomplete you have the right to have this corrected.

If it is agreed that your personal information is inaccurate or incomplete, we will aim to amend your records accordingly, normally within one month, or within two months where the request is complex. However, we will contact you as quickly as possible to explain this further if the need to extend our timescales applies to your request. Unless there is a risk to patient safety, we can restrict access to your records to ensure that the inaccurate or incomplete information is not used until
amended.

If for any reason we have shared your information with anyone else, perhaps during a referral to another service for example, we will notify them of the changes required so that we can ensure their records are accurate.

If on consideration of your request Craigshill Health Centre does not consider the personal
information to be inaccurate then we may add a comment to your record stating your concerns
about the information. If this is case we will contact you within one month to explain our reasons for
this.

If you are unhappy about how Craigshill Health Centre has responded to your request for rectification we will provide you with information on how you can complain to the Information Commissioner’s Office, or how to take legal action.

The right to object

When Craigshill Health Centre is processing your personal information for the purpose of the performance of a task carried out in the public interest or in the exercise of official authority you have the right to object to the processing and also seek that further processing of your personal information is restricted. Provided Craigshill Health Centre can demonstrate compelling legitimate grounds for processing your personal information, for instance; patient safety or for evidence to
support legal claims, your right will not be upheld.

Other rights
There are other rights under current Data Protection Law however these rights only apply in certain circumstances. For further information on these rights please visit ico.org.uk/for-the-public.

The right to complain
Craigshill Health Centre employ a Data Protection Officer to check that we handle personal information in a way that meets data protection law. If you are unhappy with the way in which we use your personal information, please tell our Data Protection Officer using the contact details below.

Data Protection Officer
Information Governance
Woodlands House
74 Canaan Lane
Edinburgh
EH9 2TB
Phone – 0131 465 5444
Email: Loth.DPO@nhs.scot 

Please note emails from your private email address may not be secure.
You also have the right to complain about how we use your personal information to the Information Commissioner’s Office (ICO). Details about this are on their website at www.ico.org.uk
Please note emails from your private email address may not be secure.
You also have the right to complain about how we use your personal information to the Information Commissioner’s Office (ICO). Details about this are on their website at https://ico.org.uk/your-datamatters/how-to-make-a-data-protection-complaint/

Our ICO registration number is Z5950117

11. Translation Service/ Accessibility
If you require a translation service, please find details to enquire below.

Interpretation and Translation Service
NHS Lothian Staff Bank
Comely Bank Centre
13 Crewe Road South
Edinburgh,
EH4 2LD
Telephone: 0131 536 2020 option 5 option 5
Email: loth.staffbankits@nhs.scot

12. DataLoch
For further information regarding NHS Lothian DataLoch Programme please go to https://dataloch.org/

13. Invitation to take part in research
Research is essential for progress within the NHS. Craigshill Health Centre may invite you to take part in a research study. Craigshill Health Centre do this with the support of specialist NHS staff who identify eligible patients from their medical record.

No data is provided to researchers without specific consent from patients.

Patients have the right to opt out of being contacted about research studies. Please let the reception staff, practice manager or your GP know if you wish to opt out

17/04/2024

There is an important update to Public Health Scotland’s General Practice data collection following the retirement of the SPIRE system in August 2023. Public Health Scotland (PHS) have been working with our NSS digital partners to confirm a new technical solution that will provide aggregate data extracts. This solution has been developed in tandem with our new national GP data extraction and analytical service, named the Primary Care Intelligence Service for Scotland (PCIS).

Data extracts previously captured via SPIRE are now scheduled to be undertaken by the new PHS Primary Care Intelligence Service (PCIS).

The permissions associated with the new service are the same as those previously agreed for SPIRE, so no changes are made to the practice’s privacy notice at this stage.

11/07/2022

This GP practice has agreed to take part in the DataLoch research programme. Both your GP practice and NHS Lothian are the data controller for the DataLoch programme (Data is only hosted within NHS Lothian), and are working in partnership with the University of Edinburgh. The aims of the DataLoch programme are to support research for the benefit of local residents in the South-East Scotland region. A Data Sharing Agreement is in place that covers the sharing of patient data with DataLoch, and all approved research is anonymous.
In line with data protection legislation, the legal basis that permits processing of patient data is:
• 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.
• 9(2)(j) – Processing is necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes in accordance with Article 89(1)

The DataLoch website covers the researcher data, public enquiries, and newsletter subscriptions for which the University of Edinburgh is the Data Controller: https://dataloch.org/privacy-notice

The Patient Rights (Scotland) Act 2011 was passed by the Parliament in February 2011 and gained Royal Assent in March 2011.

The Act aims to improve patients’ experiences of using health services and to support people to become more involved in their health and health care.

The Act, gives all patients:

• The right that the health care they receive should consider their needs, consider what would be of optimum benefit to them, encourage them to take part in decisions about their health and wellbeing, and provide information and support for them to do so.
• It also provides a right to give feedback (both positive and negative) or comments, or raise concerns or complaints about the health care they have received. The Act also requires that Health Boards encourage, monitor and learn from the feedback and complaints they receive. Good Practice Guidance has been issued to NHS Boards setting out what is required and giving advice on how to handle and learn from feedback and complaints.
• It also establishes and provides access for patients and members of the public to the independent Patient Advice and Support Service (PASS) which will provide information and help raise awareness and understanding their rights and responsibilities when using health services. PASS will also be able to help and support patients to give feedback about their healthcare and direct them to other types of support, such as advocacy or communication support services.

(Taken from the Scottish Government Website)

Your Information & Data Protection

To best provide you with adequate healthcare we hold all our patients information on computer and in files and are well on our way to becoming a paperless practice. The data contained on computer is encrypted, routinely backed up and held securely. We will, on occasion, have to share information with other NHS departments and professionals. For example, if your doctor refers you to the hospital we will have to provide information to the consultant and they, in turn, will share information with us after your visit. We will also have to share information with NHS programmes such as the Cervical Screening or the Breast Screening Programmes. Any information passed on to them will only be relevant to the programme and may be as simple as your contact information only.

Some personal information will be used in an administrative way as we are required by law to provide auditing information to the Common Services Agency (part of the Scottish Health Service). By providing this information it allows us to provide a number of services within the health centre, such as contraceptive checks and minor surgery.

All our data and data handling activities comply with the Data Protection Act and we will not supply your information to any parties not involved with your healthcare unless specified by yourself (for example, private medical insurance.

Complaints

Please let us know sooner rather than later if you have any complaints. We take these seriously and all are discussed at length with doctors and staff. To complain, please ask to speak to the practice manager in the first instance.

If your complaint is of a serious nature it is better to put it in writing. You will receive a reply within seven days and will normally be offered an appointment for a meeting to discuss your complaint. If your complaint is of a complex nature it may take a little longer, but we will keep you informed of all progress. You may bring a friend or relative to the meeting with you. During the meeting we will try to address your concerns and give you a full explanation and discuss any action required. If, at the end of the meeting, you are still not satisfied and wish to continue with your complaint, we will direct you to the relevant department. You can download the NHS Complaints leaflet here.

Access to Health Records

You can ask to see your health records. If you require this service, please ask at reception for a copy of the leaflet – alternatively, you can download the form here –  “How to see your Health Records”, published by NHS Scotland. Please refer to the leaflet for an explanation of any charges which may apply.

Patients’ Rights and Responsibilities

Please note that Craigshill Health Centre operates a ZERO TOLERANCE policy in dealing with aggressive or violent patients. Parents/guardians are reminded that they are responsible for the conduct of any child they bring into the health centre. It is a patient’s responsibility to keep their appointments or cancel them with enough notice being given for the appointment to be offered to another patient.

Whilst we undertake to provide the best possible service to our patients, we realise that occasionally situations can become difficult and you might be unhappy with the service provided.

If you are unhappy with a situation please remain calm and ask to speak the Practice Manager who will help try and resolve the problem for you. Any patients who react in a verbally or physically violent manner will be asked to leave the health centre and may be removed from the registration list, meaning they will have to register elsewhere. Patients may also be removed from the practice list if they constantly fail to attend appointments without a reasonable excuse. If the health centre staff feel that they, or other patients, are under threat, the police will be called to have the patient removed in those circumstances.

We are Involved in the Training of General Practitioners.

The doctors are in Foundation Year 2 (FY2) or in 1st, 2nd or 3rd year of Specialist Training (ST1 to ST3). They are fully qualified doctors often with extensive hospital experience who are now training in the speciality of General Practice. These are the same grades of doctors you will encounter in hospitals, either in outpatient clinics, on the ward or in A & E

ST3s work in the Practice for periods of 6 – 12 months and ST1s work in the Practice for 6 months. It is hoped that both GPs and patients benefit from the ST3 and ST1s’ fresh and enthusiastic approach and preceding hospital experience. They will have a limited clinical commitment and their work will be closely monitored by the more senior doctors in the practice.

Occasionally we use a video camera to record consultations with the Registrar. This would not be done without your full consent and the video would only be the conversation between you and the doctor.

No intimate examination will be done in front of the camera. If you are asked to participate in the use of the video and agree to do so, you will be asked to sign a consent form and the doctor will explain this to you in more detail.

The practice District Nurse and Health Visitor also supervise more junior nurses and teach students of nursing. In addition the Practice provides work placements for senior school students and prospective medical and nursing students.

You will always be asked for permission in allowing these students to sit in through consultations.

Video Consultations

Clinicians working in the practice and who are under training, might make video consultations with patients to help them improve their consultation skills as well as their ability to talk to patients.

The recording will only be used for teaching and training purposes, usually within the practice building between training and trainee, although sometimes teaching sessions may be held outside the practice in a group setting where the recording may be viewed by other trainers and trainees.

Your consent will always be requested by the receptionist before your consultation is recorded. You will need to sign that consent form again afterwards to say that you are still happy. You can withdraw your consent at any time following this, either verbally or in writing. The recording will focus on the communication between the doctor and patient and will not record examinations where your body clothings needs to be removed.

If you would rather that your consultation is not recorded, please tell the receptionsist.  This is entirely your choice and will not affect your health care in any way.

We are very grateful to those patients who allow video taping of consultations, since this helps us to train hospital doctors and Specialist Trainees and to improve our service to our patients.