Privacy Statement

This notice sets out the basis on which any personal data we hold and process on your behalf will be handled. It outlines the type of personal data we collect and explains how and why this personal data is used.

This notice sets out the legal basis we have for processing this data and the rights and choices you have about your personal data and how you can contact us.

Most of the time we rely on your implied or explicit consent for us to process your information in order to provide you with appropriate health care.

There are however other legal provisions we rely on under the Data Protection Act (General Data Protection Regulation).

We have a legal basis to use and share your information under Article 6(a) ‘the data subject has been given consent’, Article 6(e) ‘processing is in the public interest’ and Article 9(h) ‘processing is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services’.

How we use your personal information

The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in clinic, etc.). These records help to provide you with the best possible healthcare.

NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which this GP Practice hold about you may include the following information;

  • Details about you, such as your address, carer, legal representative, emergency contact details
  • Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
  • Notes and reports about your health
  • Details about your treatment and care
  • Results of investigations such as laboratory tests, x-rays, etc.
  • Relevant information from other health professionals, relatives or those who care for you

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP practice for clinical audit to monitor the quality of the service provided.

Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose.

How will my Personal Data be Used?

The information will include information about your health care.

The information will be combined and anything that can identify you (like your name or NHS Number) will be removed and replaced with a code.

This means that the people working with the data will only see the code and cannot see which patient the information relates to.

If we see that an individual might benefit from some additional care or support, we will send the information back to your GP or hospital provider and they will use the code to identify you and offer you services.

The information will be used for a number of healthcare related activities such as;

  • improving the quality and standards of care provided
  • research into the development of new treatments
  • preventing illness and diseases
  • monitoring safety
  • planning services

Who will my Personal Data be shared with?

Your GP and other care providers will send the information they hold on their systems to the South Central and West Commissioning Support Unit, who are part of NHS England. 

This information will be processed and any identifiable data will be removed before it is shared with Bristol, North Somerset and South Gloucestershire Clinical Commissioning Group (CCG). They will link all the information together in order to review and make decisions about the whole population or particular patients that might need support. 

Both the Commissioning Support Unit and the CCG are required to protect your information and maintain confidentiality in the same way that your doctor or hospital provider is.

NHS Digital

We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patients care, leading to improvements in both care and outcomes.
GP Connect is not used for any purpose other than direct care.

Authorised Clinicians such as GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS Digital service called GP connect. 

The NHS 111 service (and other services determined locally e.g. Other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services. 

Legal basis for sharing this data

In order for your Personal Data to be shared or processed, an appropriate “legal basis” needs to be in place and recorded. The legal bases for direct care via GP Connect is the same as the legal bases for the care you would receive from your own GP, or another healthcare provider:

  • for the processing of personal data: Article 6.1 (e) of the UK GDPR: “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”.
  • for the processing of “Special Category Data” (which includes your medical information): Article 9.2 (h) of the UK GDPR:  “processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services”.

Your rights

Because the legal bases used for your care using GP Connect are the same as used in other direct care situations, the legal rights you have over this data under UK GDPR will also be the same- these are listed elsewhere in our privacy notice.

Find out more about GP Connect.

This practice is supporting vital health care planning and research by sharing your data with NHS Digital. NHS Digital is replacing the General Practice Extraction Service (GPES) with the General Practice Data for Planning and Research data collection, GPDPR, and have consulted British Medical Association (BMA), Royal College of GPs (RCGP) and the National Data Guardian (NDG) to ensure safeguards are in place for patients and practices. Data will only be made available to organisations with a clear legal basis to do so for health and care purposes, and are approved following independent scrutiny by our Independent Group Advising on the Release of Data.

Patient data collected from general practice is already used to support research and analysis to help run and improve health and care services. In addition to replacing GPES, the General Practice Data for Planning and Research service (GPDPR) will help to support the planning and commissioning of services, the development of policy, public health monitoring and interventions (including coronavirus) and enable many different areas of research.

Data from the GP medical records will be shared from 1st September 2021.   Data may be shared about:

  • any living patient registered at a GP practice in England when the collection started - this includes children and adults
  • any patient who died after 1st September 2021, and was previously registered at a GP practice in England when the data collection started

Names and addresses are not collected. Any data that could directly identify patients (such as NHS Number, date of birth, full postcode) is replaced with unique codes produced by de-identification software before the data is shared, a process called pseudonymisation.

Structured and coded data from patient medical records including data on:

  • diagnoses, symptoms, observations, test results, medications, allergies, immunisations, referrals, recalls and appointments, including information about physical, mental and sexual health
  • sex, ethnicity and sexual orientation

For more information about this, and how to opt out, please see General Practice Data for Planning and Research: GP Practice Privacy Notice - NHS Digital

Risk Stratification

Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information using software managed by EMIS, and is only provided back to your GP as data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way.

Population Health Management

This work is aimed at improving the health of an entire population. 

It is about improving the physical and mental health outcomes and wellbeing of people and making sure that access to services is fair and equal. It helps to reduce the occurrence of ill-health and looks at all the wider factors that affect health and care.

The project requires health care organisations to work together with communities and partner agencies. The organisations will share information with each other in order to get a view of health and services for the population in a particular area.

In your area, a population health management programme has been introduced. The programme will combine information from GP practices, community service providers, hospitals and other health and care providers.

Medicines Management

The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. This service performs a review of prescribed medications to ensure patients receive the most appropriate, up to date and cost effective treatments. This service is provided to practices within Bristol through BNSSG Clinical Commissioning Group.

Is Using My Information in This Way Lawful?

Health Care Providers are permitted by data protection law to use information where it is ‘necessary for medical purposes’. This includes caring for you directly as well as management of health services more generally.

Some of the work that happens at a national level with your information is required by other parts of the law. For more information, speak to our Data Protection Officer.

Sharing and using your information in this way helps to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law and in the majority of cases, anonymised data is used so that you cannot be identified.

Can I Object?

You have a right to object to information being used in this way.

To find out more or to register your choice to opt out, please visit

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

  • Data Protection Act 2018
  • GDPR Act 2018
  •  Human Rights Act 1998
  • Common Law Duty of Confidentiality
  • Health and Social Care Act 2012
  • NHS Codes of Confidentiality, Information Security and Records Management

Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.

We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and / or in accordance with the new information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.” This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. They should be supported by the policies of their employers, regulators and professional bodies.

Our practice Caldicott Guardian is: Dr Simon Clausen GP Partner

Our practice Information Governance Lead is: Kate Francis Practice Manager

Our practice Data Protection Officer is the DPO at NHS South, Central and West Commissioning Support Unit. They can be contacted via the Practice Manger.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations;

  • NHS Trusts / Foundation Trusts
  • GP’s
  • NHS Commissioning Support Units
  • Independent Contractors such as dentists, opticians, pharmacists
  • Private Sector Providers
  • Voluntary Sector Providers
  • Ambulance Trusts
  • Clinical Commissioning Groups
  • Social Care Services
  • Health and Social Care Information Centre (HSCIC)
  • Local Authorities
  • Education Services
  • Fire and Rescue Services
  • Police & Judicial Services
  • Voluntary Sector Providers
  • Other ‘data processors’ which you will be informed of 

You will be informed who your data will be shared with and in some cases asked for explicit consent for this to happen when this is required.

We may also use external companies to process personal information, such as for mailing to invite you for recall purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure.

Access to personal information

You have a right under the Data Protection Act 2018 to request access to view or to obtain copies of what information the surgery holds about you and to have it amended should it be inaccurate. This is called a Subject Access Request. In order to request this, you need to do the following:

  • Your request must be made in writing to the practice – for information from the hospital you should write direct to them
  • There may be a charge to have a printed copy of the information held about you if this is considered to excessive
  • We are required to respond to you within 1 calendar month
  • You will need to give adequate information (for example full name, address, date of birth, NHS number and details of your request) so that your identity can be verified and your records located
  • You will need to provide ID unless you have already provided this to the practice

Your Rights.

  • You have the right to be provided with a copy of your data free of charge. You will need to make a formal Subject Access Request following the completion of identity checks we will provide your data within 1 calendar month.  (Some exemptions apply)
  • If you feel the information we hold about you is incorrect you have the right to request your information is rectified or erased.  We may not always be able to comply but we can agree to record your objection
  • You have the right to request that we do not process or share your records with other.  We may not always be able to comply as there may be a statutory obligation for us to do so.

Objections / Complaints

Should you have any concerns about how your information is managed at the GP practice, please contact the Practice Manager. If you are still unhappy following a review by the GP practice, you can then complain to the Information Commissioners Office (ICO) via their website (

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything. If you have any concerns about how your data is shared then please contact the practice.

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details such as date of birth is incorrect in order for this to be amended. You have a responsibility to inform us of any changes so our records are accurate and up to date for you.


The Data Protection Act 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

This information is publicly available on the Information Commissioners Office website

The practice is registered with the Information Commissioners Office (ICO).

Who is the Data Controller?

The Data Controller, responsible for keeping your information secure and confidential is:

Air Balloon Surgery


Should you have any concerns about how your information is managed by the Practice please contact the Practice Manager at the following address:

Air Balloon surgery

Kenn Rd

St George



If you are still unhappy following a review by the Practice you can then complain to the Information Commissioners Office (ICO)., , telephone: 0303 123 1113 (local rate) or 01625 545 745.

Kate Francis- Practice Manager

25th May 2018

Reviewed March 2021

Reviewed June 2022

Reviewed 29th June 2022