College Health Service Privacy Statement
College Health Service
Practice Phone Number
01 896 1556 or 01 896 1591
Dr. David McGrath
Lead for Data Protection
College Health Service Privacy Statement:
The College Health Service wants to ensure the highest standard of medical care for our patients. We understand that the College Health Service is a trusted community governed by an ethic of privacy and confidentiality. Our approach is consistent with the Medical Council guidelines and the privacy principles of the Data Protection Regulations. It is not possible to undertake medical care without collecting and processing personal data and data concerning health. In fact, to do so would be in breach of the Medical Council’s ‘Guide to Professional Conduct and Ethics for Doctors’. This document is about advising you of our policies and practices on dealing with your medical information.
Legal Basis for Processing Your Data:
The College Health Service has voluntarily signed up for the ICGP Data Protection Guideline for GPs. The processing of personal data in the College Health Service is necessary in order to protect the vital interests of the patient and for the provision of health care and public health. You can access the Guideline at http://www.icgp.ie/data. In most circumstances we hold your data after you leave Trinity College. There are exceptions to this rule and these are described in the Guideline referenced above.
Managing Your Information:
In order to provide for your care here we need to collect and keep information about you and your health on our records.
- We retain your information securely.
- We will only ask for and keep information that is necessary.
- We will attempt to keep it as accurate and up to-date as possible.
- We will explain the need for any information we ask for if you are not sure why it is needed.
- You should inform us about any relevant changes that you feel we should know about. This would include such things as any new treatments or investigations being carried out that you feel we should be made aware of.
- Please also inform us of change of address and phone numbers. Please ensure that these are accurate and updated by yourself with a College Health staff member at reception.
- All persons in the College Health Service (not already covered by a professional confidentiality code) sign a confidentiality agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty.
- Access to patient records is regulated to ensure that they are used only to the extent necessary to enable the secretary or manager to perform their tasks for the proper functioning of the College Health Service. In this regard, patients should understand that College Health Service staff may have access to their records for:
- Identifying and printing repeat prescriptions for patients. These are then reviewed and signed by the Clinician concerned.
- Generating a sickness certificate for the patient. This is then checked and signed by the Clinician concerned.
- Typing referral letters to hospital consultants or allied health professionals such as physiotherapists, occupational therapists, psychologists and dieticians.
- Opening letters from hospitals and consultants. The letters could be appended to a patient’s paper file or scanned into their electronic patient record.
- Scanning clinical letters, radiology reports and any other documents not available in electronic format.
- Downloading laboratory results and Out of Hours Doctor reports and performing integration of these results into the electronic patient record.
- Photocopying or printing documents for referral to consultants, attendance at an antenatal clinic or when a patient is changing GP.
- Checking for a patient if a hospital or consultant letter is back or if a laboratory or radiology result is back, in order to schedule a conversation with the Clinician concerned.
- When a patient makes contact with the College Health Service, checking if they are due for any preventative services, such as vaccination, ante natal visit, contraceptive pill check, cervical smear test, etc.
- Handling, printing, photocopying and postage of medico legal and life assurance reports, and of associated documents.
- Sending and receiving information via Healthmail, secure clinical email.
- And other activities related to the support of medical care appropriate for the College Health Service support staff.
Disclosure of Information to Other Health and Social Care Professionals
We may need to pass some of this information to other health and social care professionals in order to provide you with the treatment and services you need. Only the relevant part of your record will be released. These other professionals are also legally bound to treat your information with the same duty of care and confidentiality that we do.
Disclosures Required or Permitted Under Law
The law provides that in certain instances personal information (including health information) can be disclosed, for example, in the case of infectious diseases.
Disclosure of information to the University or other third party’s such as, Insurance Companies and Solicitors:
• In general, University or work related Medical Certificates from the College Health Service will only provide a confirmation that you are unfit for University/Work with an indication of when you will be fit for University/Work with an indication of when you will be fit to resume to University/Work. Where it is considered necessary to provide additional information we will discuss that with you. However, Department of Social Protection sickness certs for Work must include the medical reason you are unfit to work.
• In the case of disclosures to insurance companies or requests made by solicitors for your records we will only release the information with your signed consent and when photo id confirming your identity as the requestor/data subject has been confirmed.
Use of Information for Training, Teaching and Quality Assurance
It is usual for the College Health Service to discuss patient case histories as part of their continuing medical education. In these situations, the identity of the patient concerned will not be revealed.
In other situations, however, it may be beneficial for other clinicians within the College Health Service to be aware of patients with particular conditions and in such cases the College Health Service would only communicate the information necessary to provide the highest level of care to the patient.
Use of Information for Clinical Audit
It is usual for patient information to be used for clinical audit in order to improve services and standards of the College Health Service. GPs on the specialist register of the Medical Council are required to perform yearly clinical audits. Information used for such purposes is done in an anonymised or pseudonymised manner with all personal identifying information removed.
If it were proposed to use your information in a way where it would not be anonymous or the College Health Service was involved in external research we would discuss this further with you before we proceeded and seek your written informed consent. Please remember that the quality of the patient service provided can only be maintained and improved by training, teaching, audit and research.
Your Right of Access to Your Health Information
You have the right of access to all the personal information held about you by the College Health Service. If you wish to see your records, in most cases the quickest way is to discuss this with the Clinician concerned, who will review the information in the record with you. You can make a formal written access request to the College Health Service and receive a copy of your medical records. These will be provided to you within thirty days, without cost.
Transferring to Another Practice
If you decide at any time and for whatever reason to transfer to another practice, we will facilitate that decision by making available to your new doctor a copy of your records on receipt of your signed consent from your new doctor. For medico-legal reasons we will also retain a copy of your records in this practice for an appropriate period of time which may exceed eight years. Please see below the link to the form to be filled and dropped in at reception. https://www.tcd.ie/collegehealth/service/other.php
You have other rights under data protection regulations in relation to transfer of data to a third country, the right to rectification or erasure, restriction of processing, objection to processing and data portability. Further information on these rights in the context of general practice is described in the Guideline available at http://www.icgp.ie/data.
Right of Access
You have the right to request a copy of the personal data we are processing about you and to exercise that right easily and at reasonable intervals.
You have the right to withdraw your consent where that is the legal basis of our processing.
You have the right to have inaccuracies in personal data that we hold about you rectified.
You have the right to have your personal data deleted where we no longer have any justification for retaining it subject to exemptions such as the use of pseudonymised data for scientific research.
You have the right to object to processing your personal data if:
- We have processed your data based on a legitimate interest or for the exercise of the public tasks of the University if you believe the processing to be disproportionate or unfair to you.
- The personal data was processed for the purposes of direct marketing or profiling related to direct marketing.
- We have processed the personal data for scientific or historical research purposes or statistical purposes unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You have the right to restrict the processing of your personal data if:
- You are contesting the accuracy of the personal data;
- The personal data was processed unlawfully;
- You need to prevent the erasure of the personal data in order to comply with legal obligations;
- You have objected to the processing of the personal data and wish to restrict the processing until a legal basis for continued processing has been verified.
Where it is technically feasible you have the right to have a readily accessible machine readable copy of your data transferred or moved to another data controller where we are processing your data based on your consent and if that processing is carried out by automated means.
If you have any queries relating to the processing of your personal data for the purposes outlined above or you wish to make a request in relation to your rights, you can contact the Director of the College Health Service at +353 1 896 1591 or +353 1 896 1556.elephone
If you wish to make a complaint or escalate an issue relating to your rights, you can contact the Data Protection Officer at firstname.lastname@example.org .
Finally, if you are not satisfied with the information we have provided to you in relation to the processing of your data, you can also make a complaint to the Data Protection Commissioner via the link in their website Making a Complaint to the DPC.