Detailed privacy notices

To meet our stated purpose, we must collect information about you. We will not always collect all the categories of data, but only what is relevant to your care and treatment with us. 

This could include:

• who you are
• where you live
• your occupation
• your family, your friends, your employers
• your habits
• your problems and diagnoses
• the reasons you seek help
• your appointments
• where and when you are seen; who by
• referrals to specialists and other healthcare providers
• tests carried out here and in other health settings
• investigations and scans, treatments and outcomes of treatments
• your treatment history
• the observations and opinions of other healthcare workers, within and without the NHS, as well as comments and notes reasonably made by healthcare professionals in the trust who are appropriately involved in your healthcare

We receive this information securely from your GP or other healthcare providers when you are referred to us. Only those that are involved in your direct care would have access to this information. 

Where you give us permission, we will access the Health Information Exchange (HIE). 

HIE integrates data from those multiple electronic health and care systems to provide a real-time and read-only summary of that data to a health or social care professional when required for the purpose of your direct care. 

If you are unable to give us permission because, for example, you are unconscious, we will assess whether under the circumstances it is reasonable and in your best interest to access your HIE record.

Where you are brought in by ambulance we will receive information from the ambulance trust about their observation and treatment of you. 

We share a summary of your treatment with you GP, unless you ask us not to. When you ask us not to share information with your GP, we will consider whether there is a significant risk to you or others before deciding whether to agree. 

Other times we may share your information are: 

• Where you agree to be referred to other healthcare providers, we will share only the necessary and relevant information with that healthcare provider in order for them to treat you. 
• We may share some limited information with patient transport services where we are arranging for you to get to appointments or your home. 
• We may share information with your local authority to support you in arranging social care support. 
• Further specific details of who we share your personal data with, for example because of a specific legal obligation, are detailed in this privacy notice.  

Your information is shared with the HIE unless you have opted out. 

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. 

We do not allow our processors to use your information for their own purposes or allow them to link this to other personal data they may. 

The category of our processors are organisations who: 

• provide our IT systems
• provide some of our medical devices 
• dispose of confidential waste (paper records, laptops or other IT equipment
• provide some of our clinical service under contract with us

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule. 

We do not collect any additional personal data for this purpose, but may share any or all of the information we have collected as part of the routine direct care and emergency direct care privacy notices on this website.

For our stated purpose, we will share information with the CQC

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.  

Where you have agreed to the use of your information in a particular research project, the participant information leaflet would have been given to you as part of the process. 

This document will tell you what types of personal information we will use in connection with the specific research study or project you are taking part in and (where applicable) its sources. 

We will often get the necessary information directly from you. In other cases, we might already hold the required information due to the healthcare we provide to you. For information we are likely to already hold about you due to the care we provide, please refer to our main privacy notice for direct care. 

In situations where it has been impracticable to obtain your agreement, we will have sought approval from the secretary of state via the Confidentiality Advisory Group under section 251 of the National Health Service Act 2006 (‘CAG approval’). The Confidentiality Advisory Group provides independent advice on specific research projects which will use confidential medical information. 

Certain research studies also have to be approved by the Research Ethics Committees, which is another independent group that ensures all our research is ethical. 

In some instances, we will apply to the Health Research Authority who may approve that we can use pseudonymised information for research. 

Pseudonymised information is personal data which has had the identifiers removed, for example your name replaced with a research number and your data of birth changed to an age. 

Where there are other fields which will be able to identify you, these will also be appropriately pseudonymised.

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. 

We do not allow our processors to use your information for their own purposes or allow them to link this to other personal data they may hold. 

The category of our processors are organisations who: 

• provide our IT systems 
• provide some of our medical devices
• dispose of confidential waste (paper records, laptops or other IT equipment)
• provide some of our clinical services under contract with us 

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.  

Please see our direct care privacy notice for details of the information we collect. 

We may use or share any of this information where it is reasonable and necessary to safeguard a child or adult. 

We may share information with other NHS organisations, the local authority, police, or London-wide safeguarding teams where necessary

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. 

We do not allow our processors to use your information for their own purposes or allow them to link this to other personal data they may hold. 

We have no additional processors from those detailed in our direct care privacy notice for this purpose. 

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.  

Images of you, where you are, what you do, and who you are with. Audio of what you say. 

In order to legally be able to process your personal data, we must have a lawful basis under the United Kingdom General Data Protection Regulation (GDRP). 

Our lawful basis for the purpose of processing data in our stated purpose, under UK GDPR, is: 

Data Protection Act 2018 Schedule 1: 

(10) Preventing or detecting unlawful acts. 

(11) Protecting the public against dishonesty etc. 

(12) Regulatory requirements relating to unlawful acts and dishonesty etc. 

Article 6 (1)(e) processing is necessary for the performance of a task carried out in the public interest. 

Relevant law enforcement bodies and organisations. 

The trust uses the following processor: 

• CCTV and BWV supplier (who provide the actual camera) 
• external security company (who provide on-site security) 

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.  

We do not collect any additional personal data for this purpose, but may share any or all of the information we have collected as part of the routine direct care and emergency direct care privacy notices on this website.

Relevant law enforcement bodies and organisations. 

The trust does not use additional processors for the sharing of this information. 

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.  

In order to meet our purpose above, we need to process information from you. 

This processing happens within a secure system and no human is able to link any of the information below to you as an individual:

• gender — for equality monitoring
• date of birth — to ensure you are over 18
• mobile phone number — to send you a text message
• emergency department as the location for treatment — to ensure only emergency department patients receive a text message
• the feedback you provide — to allow us to monitor and improve services.

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. 

We do not allow our processors to use your information for their own purposes or allow them to link this to other personal data they may have.

The category of our processors are organisations who:

• provide our IT systems

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.

To meet our stated purpose, we must collect information about you. We will not always collect all the categories of data, but only what is relevant to your care and treatment as a private patient. 

This could include:

• who you are
• where you live
• your occupation
• your family, your friends, your employers
• your habits
• your problems and diagnoses
• the reasons you seek help
• your appointments
• where and when you are seen; who by
• referrals to specialists and other healthcare providers
• tests carried out here and in other health settings
• investigations and scans, treatments and outcomes of treatments
• your treatment history
• the observations and opinions of other healthcare workers, within and without the NHS, as well as comments and notes reasonably made by healthcare professionals in the trust who are appropriately involved in your healthcare

We may also collect financial information relating to cost of treatment, health insurance, and banking information for payment purposes.  

Where you give us permission, we will access the Health Information Exchange (HIE). HIE integrates data from those multiple electronic health and care systems to provide a real-time and read-only summary of that data to a health or social care professional when required for the purpose of your direct care. If you are unable to give us permission because for example you are unconscious, we will assess whether under the circumstances it is reasonable and in your best interest to access your HIE record.  

Where you are brought in by ambulance we will receive information from the ambulance trust about their observation and treatment of you.  

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. 

We do not allow our processors to use your information for their own purposes or allow them to link this to other personal data they may.  

The category of our processors are organisations who:  

• provide our IT systems 
• provide some of our medical devices
• dispose of confidential waste (paper records, laptops or other IT equipment)
• provide some of our clinical services under contract with us

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.   

In order to meet our purpose above and to protect your fundamental rights as an employee, we need to collect information from you. 

We ask you for your personal details, including name and contact details. We will also ask you about previous experience, education, referees, health and for answers to questions relevant to the role. 

Our recruitment team will have access to all this information. The recruiting manager and interview panel will also have access to this information, however, during the early stages of your application, this will exclude your name. 

You will also be asked to provide equal opportunities information. This is not mandatory ¬¬— if you do not provide it, it will not affect your application. 

We will not make the information available to any staff outside our recruitment team, including hiring managers, in a way that can identify you. Any information you provide will be used to produce and monitor equal opportunities statistics. 

We may ask you to take part in assessment days, complete tests or occupational personality profile questionnaires, attend an interview, or a combination of these. 

Information will be generated by you and by us. For example, you might complete a written test, or we might take interview notes. This information is held by us in line with our records retention schedule. 

If you are unsuccessful after assessment for the role, we may ask if you would like your details retained in our talent pool. If you say yes, we would proactively contact you should any further suitable vacancies arise. 

If we make a conditional offer of employment, we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. 

We must confirm the identity of our staff and their right to work in the United Kingdom, and seek assurance as to their trustworthiness, integrity and reliability. 

You must therefore provide: 

• Proof of your identity — you may be asked to attend our office with original documents, where we will take copies, or submit your documents via our secure digital platform. 
• Proof of your qualifications — you may be asked to attend our office with original documents, where we will take copies.
• A criminal records declaration to declare any unspent convictions. 
• Criminal record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions. 
• We will contact your referees, using the details you provide in your application, directly to obtain references. 
• We will also ask you to complete a questionnaire about your health to establish your fitness to work. 
• We will also ask you about any reasonable adjustments you may require under the Equality Act 2010. This information will be shared with relevant trust staff to ensure these are in place for when you start your employment.  

If we make a final offer, we will also ask you for the following: 

• bank details — to process salary payments 
• emergency contact details, so we know who to contact in case you have an emergency at work 
• any membership of a pension scheme 

If you are coming from another NHS organisation, we will request further information from your current NHS employer via the ESR interface. This information is your mandatory training record and vaccine status. 

Our code of conduct requires all staff to declare if they have any potential conflicts of interest — this includes any secondary employment. Depending on the conflict and your seniority within the trust, this may be published on the trust website in line with NHS guidance. 

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. 

We do not allow our processors to use your information for their own purposes or allow them to link this to other personal data they may have.  

The category of our processors are organisations who: 

• provide our IT systems
• provide the platforms which process your application 
• dispose of confidential waste (paper records, laptops or other IT equipment)
• provide some of our recruitment services
• provide identity checking service

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule. 

Health and care professionals have shared information on paper for many years — we are now able to do this using digital technology.

When you visit one of our hospitals or your GP, your healthcare worker will have all the information to hand to treat you effectively and efficiently. 

You will not need to relay the full story of your symptoms, what happened or the medicines you were prescribed, as this will be already accessible from your notes.

Information will be available in real time — or in some cases within 24 hours — and will ensure your health and care teams have the most up to date information about your care. 

Under the General Data Protection Regulation, information will only be shared and accessed on a strictly need to know basis by health and care professionals across the five boroughs of Barnet, Camden, Enfield, Haringey and Islington and only for the purposes of direct care. Data will always be securely held.

In order to legally be able to process your personal data, we must have a lawful basis under the United Kingdom General Data Protection Regulation (GDPR).

Our lawful basis for the purpose of processing data in our stated purpose, under UK GDPR, is:

Data Protection Act 2018 Schedule 1 (2) Health or social care purposes. 

For people using health and care services, there are many advantages to having joined-up records, including:

• Everyone involved in your direct care will have the whole picture.
• When you visit somewhere different for care or meet a new care professional, they will have access to your health and care information and you will not need to repeat your story.
• The results of common tests (for example, blood tests) will be available to everyone involved in your care, regardless of where the test took place, reducing the need to repeat them or obtain printed results.

For us and other health and social care professionals, advantages include:

• We will have up-to-date information to plan and improve your care and make more informed decisions.
• We will have to spend less time finding out relevant information from different health and social care organisations and IT systems, and will not have to spend time recording duplicate information across records. 
• We can work as a team across north central London to identify opportunities for improvement, such as seeing if there needs to be more focus on providing physical health checks for people with learning disabilities.

More information on the benefits and what is means for you is available on the NCL ICS website
 

Other health and care organisations in North Central London’s Sustainability and Transformation Partnership, such as GP practices and other hospitals/providers across the boroughs of Barnet, Camden, Enfield, Haringey and Enfield. 

Read more about this on the NCL ICS website.

You can also read the Royal Free London's privacy notice.

The NLPSS occupational health (OH) shared services is delivered by the Royal Free London NHS Foundation Trust (RFL) to the trusts within NLPSS, including an internal OH service to RFL employees. As RFL (the trust) is the hosting partner of NLPSS OH services, it must meet its contractual, statutory and administrative obligations. We are committed to ensuring that the personal data of NLPSS and RFL employees is handled in accordance with the United Kingdom General Data Protection Regulation, and Data Protection Act 2018. 

This privacy notice tells you what to expect when the trust collects personal information about you. It applies to all NLPSS staff using the shared NLPSS OH services. However, the information we will process about you will vary depending on your specific personal circumstances. 

The trust is a sole controller of own employee data and a joint controller for the OH shared services, unless it is processing legacy data (staff member no longer employed) for another trust within NLPSS, in which case, RFL is a processor. This notice should be read in conjunction with our patient privacy notice for staff and our other corporate policies and procedures. When appropriate we will provide a ‘just in time’ notice to cover any additional processing activities not mentioned in this document. 

As a public authority we must appoint a Data Protection Officer (DPO). The DPO’s tasks are defined in law and include:  

• to inform and advise the trust and its employees about obligations to comply with the UK GDPR and other data protection laws;  

• to monitor the trust’s compliance with the UK GDPR and other data protection laws, and data protection polices, including managing internal data protection activities; raising awareness of data protection issues, training staff and conducting internal audits;  

• to advise on, and to monitor, data protection impact assessments;  

• to cooperate with the Information Commissioner’s Office (ICO); and  

• to be the first point of contact for the ICO and for individuals whose data is processed (employees, patients etc).  

Our Data Protection Officer is Kevin Winter – Associate Director of Information Governance. You can contact the Data Protection Officer on rf-tr.rfldpo@nhs.net  

We use the following information to carry out the following functions; 

1. Occupational Health NLPSS undertake in employment health consultations to address health impairments affecting or affected by work and advise on fitness for work. 

2. Preemployment Health Checks:  

   1. review of applicant health declarations, 

   2. blood tests (screening) for blood borne viruses in healthcare workers carrying out exposure prone procedures, 

   3. pre-employment health monitoring (e.g. night workers), 

   4. pre-employment baseline health surveillance (e.g. lung function tests, hearing tests, blood tests for blood borne viruses), 

   5. pre-employment assessment of declared health impairments requiring reasonable adjustment. 

3. Physiotherapy advice services – where a referral is made by either an employee self-referral or Occupational Health Advisory Services, self-management physiotherapy advice provided to employee. 

4. In employment health monitoring e.g. night worker questionnaires, stress and / or musculo-skeletal symptom questionnaires. 

5. In employment health surveillance e.g. skin checks, symptom questionnaires, self-reporting consultations. 

6. Data set extract for all customer organisation’s staff to populate the OH system referral module: person match. 

7. Legacy (staff member no longer employed) Occupational Health NLPSS undertook in employment health consultations to address health impairments affecting or affected by work and advise on fitness for work. 

8. Legacy (staff member no longer employed) Preemployment Health Checks:  

   1. review of applicant health declarations, 

   2. blood tests (screening) for blood borne viruses in healthcare workers carrying out exposure prone procedures, 

   3. pre-employment health monitoring (e.g. night workers),

   4. pre-employment baseline health surveillance (e.g. lung function tests, hearing tests, blood tests for blood borne viruses),

   5. pre-employment assessment of declared health impairments requiring reasonable adjustment. 

9. Legacy (staff member no longer employed) physiotherapy treatment services. 

10. Legacy (staff member no longer employed) In employment health monitoring e.g. night worker questionnaires, stress and / or musculo-skeletal symptom questionnaires. 

11. Legacy (staff member no longer employed) In employment health surveillance e.g. skin checks, symptom questionnaires, self-reporting consultations.

We collect information we hold about you from: 

• your paper health or electronic questionnaires, 

• your line manager through referral questionnaires, 

• providing clinical services to you (e.g. vaccination history, blood test results, and GP reports). 

We process the following categories of personal data: 

• name, 

• contact details, 

• date of birth, 

• directorate/ICSU and department/department affiliation, 

• employment start and leaving dates, 

• job title, 

• information supplied by you through questionnaire, email, telephone or face to face consultation. 

• health /medical history, 

• lifestyle information and social circumstances, 

• your interests and extra-curricular activities, 

• racial information which may be relevant to clinical assessments (e.g. lung function). 

• information supplied by your line manager which may include information such as attendance history, medical information. 

• medical information supplied by your GP/ Specialist with your consent. 

• covid-19 vaccination history. 

Depending on the processing activity, we rely on the following lawful basis for processing your personal data under the GDPR; 

• for sole processing of RFL own employee data, see RFL privacy notice for staff, 

• for supporting OH Shared Services. 

Royal Free London Lawful basis for hosted services  

1. Occupational Health NLPSS including in employment health consultations to address health impairments affecting or affected by work and advise on fitness for work RFL as joint controller UK GDPR Article 6 (1)(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks. RFL are not providing OH advisory services as part of their public function and therefore are able to utilise legitimate interest’s lawful basis in this instance. 

2. Preemployment Health Checks:  

   1. review of applicant health declarations. 

   2. blood tests (screening) for blood borne viruses in healthcare workers carrying out exposure prone procedures. 

   3. pre-employment health monitoring (e.g. night workers). 

   4. pre-employment baseline health surveillance (e.g. lung function tests, hearing tests, blood tests for blood borne viruses). 

   5. pre-employment assessment of declared health impairments requiring reasonable adjustment RFL as joint controller UK GDPR Article 6 (1)(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. 

   6. Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks. 

   7. RFL are not providing pre-employment screening services as part of their public function and therefore are able to utilise legitimate interest’s lawful basis in this instance. 

3. Physiotherapy advice services: RFL as joint controller UK GDPR Article 6 (1)(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. 

   1. Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks.

   2. RFL are not providing OH advisory services as part of their public function and therefore are able to utilise legitimate interest’s lawful basis in this instance. 

4. In employment health monitoring e.g. night worker questionnaires, stress and / or musculo-skeletal symptom questionnaires: 
   1. RFL as joint controller UK GDPR Article 6 (1)(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. 
   2. Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks. 
   3. RFL are not providing employment health monitoring as part of their public function and therefore are able to utilise legitimate interest’s lawful basis in this instance. 

5. In employment health surveillance e.g. skin checks, symptom questionnaires, self-reporting consultations: 

   1. RFL as joint controller UK GDPR Article 6 (1)(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. 

   2. Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks. 

   3. RFL are not providing employment health surveillance as part of their public function and therefore are able to utilise legitimate interest’s lawful basis in this instance. 

6. Data set extract for all customer organisation’s staff to populate the OH system referral module RFL as joint controller UK GDPR Article 6 (1)(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. 

   1. Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks. 

   2. RFL are not providing OH services as part of their public function and therefore are able to utilise legitimate interest’s lawful basis in this instance. 

7. Legacy (staff member no longer employed)Occupational Health NLPSS including in employment health consultations to address health impairments affecting or affected by work and advise on fitness for work. RFL is a processor. 
8. Legacy (staff member no longer employed) Pre-employment Health Checks:
   1. review of applicant health declarations,
   2. blood tests (screening) for blood borne viruses in healthcare workers carrying out exposure prone procedures, 
   3. pre-employment health monitoring (e.g. night workers),
   4. pre-employment baseline health surveillance (e.g. lung function tests, hearing tests, blood tests for blood borne viruses), 
   5. pre-employment assessment of declared health impairments requiring reasonable adjustment 
   6. RFL is a processor. 

9. Legacy (staff member no longer employed) physiotherapy treatment services: RFL is a processor. 

10. Legacy (staff member no longer employed) In employment health monitoring e.g. night worker questionnaires, stress and / or musculo-skeletal symptom questionnaires: RFL is a processor. 

11. Legacy (staff member no longer employed) In employment health surveillance e.g. skin checks, symptom questionnaires, self-reporting consultations: RFL is a processor. 

In line with the principles of medical confidentiality no medical information (diagnosis, results of tests etc.) is shared without your informed consent (permission). This is a professional requirement separate to any requirements of data protection legislation. 

Where specific health assessment processes are undertaken, information on the outcome of such assessments is shared internally to nominated individuals who have a business need to know. 

All pathology is undertaken by an accredited external laboratory who are GDPR compliant. 

Referrals to NHS Specialist’s, Employee Assistance Program or Independent Practitioners are not made without consultation with service users and only with their agreement. 

We have no electronic interface with NHS record keeping systems. 

Occupational health records are archived using a third-party document management system. 

We may in exceptional circumstances process your personal data because it is necessary to protect your or another person's vital interests, for example, where you have a life-threatening accident or illness in the workplace, and we have to share your personal data in order to ensure you receive appropriate medical attention. 

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. We do not allow our Processors to use your information for their own purposes or allow them to link this to other personal data they may. We don’t routinely transfer staff personal data overseas but when this is necessary, we ensure that we have appropriate safeguards in place. 

The category of our processors are organisations who: 

• provide our IT systems; 

• provide the platforms which process your OH record 

Record retention for employing organisations is as follows:

For RFL employees the retention period is as above. 

Customers set own retention for their data.  

Data protection laws give you a number of rights over your personal data. These rights are detailed below. 

The right to be informed 

It is the responsibility of each controller to ensure data subjects for who’s data they are a controller, are informed regarding transfer of data to and processing by a third party OH provider. Your employer is controller, please see your employer’s privacy notice for full details. It is also the responsibility of each controller to ensure notification to staff include, where relevant, the sharing of personal data with any outsourced HR/recruitment function. 

The right of access 

Data subjects are able to exercise this right for data of which RFL is the controller by following the Trust’s established processes detailed on the Trust’s privacy notice on the public facing website at Information management and technology (IT) - Staff privacy notices (royalfree.nhs.uk) and Privacy notice | For patients, carers and visitors | The Royal Free 

It is the responsibility of other controllers to honour this right to their data subjects. Your employer is controller, please see your employer’s privacy notice for full details. RFL are able to provide information within the system to support a controller’s response. Controllers can access this service by contacting rf.occupationalhealth@nhs.net who will access the records on the controller's behalf.  

The right to rectification 

Data subjects are able to exercise this right for data of which RFL is the controller by following the Trust’s established processes detailed on the Trust’s privacy notice on the public facing website at Information management and technology (IT) - Staff privacy notices (royalfree.nhs.uk) and Privacy notice | For patients, carers and visitors | The Royal Free 

It is the responsibility of other controllers to honour this right to their data subjects. Your employer is controller, please see your employer’s privacy notice for full details. RFL are able to provide information within the system to support a controller’s response. Controllers can access this service by contacting rf.occupationalhealth@nhs.net who will access the records on the controller's behalf. 

Arrangements on this right for joint controller relationships, including where one controller may not have access to the data shall be detailed in joint controller agreements. 

The right to erasure 

Data subjects are able to exercise this right by following the Trust’s established processes detailed on the Trust’s privacy notice on the public facing website at Information management and technology (IT) - Staff privacy notices (royalfree.nhs.uk) and Privacy notice | For patients, carers and visitors | The Royal Free 

It is the responsibility of other controllers to honour this right to their data subjects. RFL are able to provide information within the system to support a controller’s response. Your employer is controller, please see your employer’s privacy notice for full details. Controllers can access this service by contacting rf.occupationalhealth@nhs.net who will access the records on the controller's behalf. 

Arrangements on this right for joint controller relationships, including where one controller may not have access to the data shall be detailed in joint controller agreements. 

The right to restrict processing 

Data subjects are able to exercise this right for data of which RFL is the controller by following the Trust’s established processes detailed at Information management and technology (IT) - Staff privacy notices (royalfree.nhs.uk) and Privacy notice | For patients, carers and visitors | The Royal Free 

It is the responsibility of other controllers to honour this right to their data subjects. Your employer is controller, please see your employer’s privacy notice for full details. RFL are able to provide information within the system to support a controller’s response. Controllers can access this service by contacting rf.occupationalhealth@nhs.net who will access the records on the controller's behalf. 

Arrangements on this right for joint controller relationships, including where one controller may not have access to the data shall be detailed in joint controller agreements. 

The right to data portability 

Data subjects are able to exercise this right for data of which RFL is the controller by following the Trust’s established processes detailed at Information management and technology (IT) - Staff privacy notices (royalfree.nhs.uk) and Privacy notice | For patients, carers and visitors | The Royal Free 

It is the responsibility of other controllers to honour this right to their data subjects. Your employer is controller, please see your employer’s privacy notice for full details. RFL are able to provide information within the system to support a controller’s response. Controllers can access this service by contacting rf.occupationalhealth@nhs.net who will access the records on the controller's behalf. 

Arrangements on this right for joint controller relationships, including where one controller may not have access to the data shall be detailed in joint controller agreements. 

The right to object 

Data subjects are able to exercise this right for data of which RFL is the controller by following the Trust’s established processes detailed at Information management and technology (IT) - Staff privacy notices (royalfree.nhs.uk) and Privacy notice | For patients, carers and visitors | The Royal Free 

It is the responsibility of other controllers to honour this right to their data subjects. Your employer is controller, please see your employer’s privacy notice for full details. RFL are able to provide information within the system to support a controller’s response. Controllers can access this service by contacting rf.occupationalhealth@nhs.net who will access the records on the controller's behalf. 

Arrangements on this right for joint controller relationships, including where one controller may not have access to the data shall be detailed in joint controller agreements. 

Rights in relation to automated decision making and profiling.

The trust does not use automated decision making and profiling for OH Services.  

In order to meet our purpose above we need to process information from you. This processing happens within a secure system and no human is able to link any of the information below to you as an individual: 

• Gender – for equality monitoring  

• Date of Birth – to ensure you are over 18 

• Mobile phone number – to send you a SMS (text message) 

• Department seen in as the location for treatment  

• The feedback you provide - to allow us to monitor and improve services. 

In order to legally be able to process your personal data, we must have a lawful basis under the United Kingdom General Data Protection Regulation (UK GDPR). Our lawful basis for the purpose of processing data in our stated purpose is: 

• UK GDPR Article 6(1)(e) - performance of a task carried out in the public interest. 
• UK GDPR Article 9(2)(h) - purposes of the management of health or social care systems and services. 

By processing your health data, we will also recognise your rights established under English case law, collectively known as the “Common Law Duty of Confidentiality”. This means that we only use your personal data in ways that would reasonably be expected, including where we share your information with your consent or where we can reasonably expect that you would consent, or for reasons of substantial public interest. 

Our processors  

Processors are organisations who act on our behalf and under our authority. They carry out some of the technical processes, for example, providing a system that stores information. We do not allow our Processors to use your information for their own purposes or allow them to link this to other personal data they may hold. 

The category of our processors are organisations who: 

• Provide our IT systems. 

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.  

We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.  

Data protection laws give you a number of rights over your personal data. These rights are detailed below. 

The right to be informed 

The trust is required by law to provide you with information about how it collects and uses your personal data. The trust, by way of this privacy notice is providing you with this information. 

The right of access 

You have the right to access the information we hold about you. To access personal information we hold, please contact the Access Team at rf-tr.AccessRequests@nhs.net.  

The right to rectification 

You have the right to have inaccurate information about you corrected or incomplete information completed. To request any other inaccurate information corrected please contact the Access Team at rf-tr.AccessRequests@nhs.net. 

The right to erasure 

The right to erasure is also known as ‘the right to be forgotten’. The right is not absolute and only applies in certain circumstances. 

This is limited to: 

• where we still hold your personal data, but it is no longer necessary for the purpose for which we originally collected or processed it; or, 

• where we have to erase it to comply with a legal obligation. 

To exercise this right, please contact rf-tr.AccessRequests@nhs.net. 

The right to restrict processing 

You have the right to restrict the processing of your personal data in certain circumstances. This means that you can limit the way we use your data. This is an alternative to requesting the erasure of your data. The right is not absolute and only applies in certain circumstances. 

This is limited to  

• Where you contest the accuracy of your personal data and we are verifying the accuracy; or, 

• When we no longer need the personal data, but you need us to keep it in order to establish, exercise or defend a legal claim. 

To exercise this right, please contact rf-tr.AccessRequests@nhs.net. 

The right to data portability 

You have the right to data portability in some limited circumstances. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. 

To exercise this right, please contact rf-tr.AccessRequests@nhs.net. 

Opt out 

There is 48-hour delay from discharge to receiving a SMS (text message). You can opt out of receiving SMS (text messages) by, scanning QR code displayed on posters around the hospital and completing the form which opens or by emailing rf.patientexperience@nhs.net and stating you do not wish to receive a SMS (text message) in regards to your hospital visit. Finally, you can reply STOP when you receive a SMS (text message) to prevent any further messaging being sent. 

The right to object 

You have the right to object to the processing of your personal data at any time. This effectively allows you to stop or prevent us from processing your personal data. 

An objection may be in relation to all of the personal data we hold about you or only to specific information.  

The right to object only applies in certain circumstances. You must give specific reasons why you are objecting to the processing of your data. These reasons should be based upon your particular situation. 

In these circumstances, your right to object is not an absolute right, and we do not need to comply if we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms. To exercise this right, please contact rf-tr.AccessRequests@nhs.net. 

Rights in relation to automated decision making and profiling 

The trust does not use automated decision making and profiling for recruitment purposes.