Beard Mill Clinic is committed to protecting and respecting your privacy and policies are in place to ensure that any personal data held by the Clinic is processed correctly.
The lawful bases of processing your general personal data under Article 6 of the GDPR are Contract and Consent.
The specific purpose of the processing of your personal data is to ensure that the Clinic has sufficient information to provide you with the most accurate information about each scan and to liaise appropriately with other Health Care Professionals involved in your care, if appropriate.
The contract that you enter into with Beard Mill Clinic is to receive relevant information about your pregnancy through ultrasound scanning in exchange for a pre-specified fee. You are required to give your consent for your personal data to be shared with other health care providers when appropriate and for Clinic to use your personal data to contact you in the future if necessary.
Your data will never be shared with a third party unless it is another health care provider and sharing this information is relevant to your care.
Given the sensitive nature of the data being collected a lawful basis for processing special category data is also required under Article 9 of GPDR and that is that processing is necessary for the assessment of medical diagnosis and for the pursuant to contract with a health professional.
Personal data to be collected
The data to be collected includes your basic demographic details, a record of each scan performed at Beard Mill Clinic and the outcome of your pregnancy. Information is recorded on the Astraia database and kept in electronic form. A physical file is also created, containing your original demographic sheet and a copy of each scan report. These files are stored securely.
Consent is obtained when you fill out the demographic sheet when you first attend Clinic. On the back of the form is a section, asking you to sign to give your consent to share the scan findings with your GP and other health care professionals if relevant and to use the e-mail address that you have provided for future correspondence. This future correspondence is limited to e-mailing reports (but this isn’t usual practice and is only done if specifically requested), arranging future appointments, answering questions that you may subsequently ask and following up on the outcome of your pregnancy. Occasionally we may write to ask you if you are happy for a testimonial to be used on the website.
You are required to indicate your consent with a signature. Default consent is not assumed. If you choose not to share the scan information with the GP, this will be respected and the GP details will be left off the database.
You may withdraw your consent at any point and are simply required to tell Dr Heath, either verbally or in writing, that you do not wish your scan information to be shared.
A copy of the scan findings is given to every patient immediately after the scan and before you leave Clinic.
It is entirely up to you what you do with this information, where you choose to store it and who you choose to share it with. Occasionally patients ask to have a copy of the report or scan images sent to them electronically, and if specifically requested this will be sent by e-mail to the e-mail address that you have specified.
If all the results are not available at the time of the scan visit, a provisional report will be given to you at the time of the scan and then a new version e-mailed to you (to the e-mail address that you have specified) once the final results are available. This may include a laboratory report too if relevant.
It is normal practice for Clinic to also share details of the scan findings with your GP – both normal and abnormal findings can affect the ongoing management of the pregnancy and Dr Heath believes it is sensible and courteous to share this information. However some patients would prefer the information not to be shared. You have the opportunity to highlight this when you fill out the GP section on the form (most will choose to leave this blank if they do not want the information shared) or when signing the form that specifically indicates that the information will be shared with the GP. If patients choose to withdraw their consent at a later stage, they just need to let Dr Heath know this and she will remove the GP details from the database to avoid any GP copies being generated in error.
Patients are asked to complete and return an outcome form to feedback the outcome of the pregnancy.
This is an important part of the Clinic audit and patients are encouraged to do so, but it is entirely voluntary and patients are not required to supply the information. If the form hasn’t been returned, Dr Heath may contact you by e-mail to remind you to do so, or ask you to send the information back in a return e-mail.
The only other indication for sharing data is if an onward referral is required – to the Early Pregnancy Unit at your local hospital, a Fetal Medicine Unit, or your local Screening co-ordinator. In each case, e-mail is usually the most efficient – and preferred – way of making an onward referral and will include a summary of the reason for referral and an electronic copy of your report. This will only be done with your full permission and once a clear explanation of both the reason for referral and referral pathway has been given. There is no situation where a referral would be made without the your knowledge and verbal consent.
Keeping your data
Under the Department of Health (2006) Records management: NHS code of practice maternity records are required to be kept for 25 years after the birth of the last child.
E-mails and phone records will be deleted after three months, unless they are clinically relevant to your ongoing care. This includes the data generated by both phone and e-mail enquiries that do not subsequently result in a consultation at Beard Mill Clinic.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you
- The right to request that we correct any personal data if it is found to be inaccurate or out of date
- The right to withdraw your consent to the processing at any time
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Dr Victoria Heath. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.