Controller’s contact details
[Insert your organisation’s name and contact details here]
Data Protection Officer’s contact details
[Insert contact details of your organisation’s Data Protection Officer]
Our purpose and legal basis for processing
We collect information about you (your personal data) in order to provide you with healthcare. We also use your data to assess the effectiveness of the services we provide so that we can provide you with the best possible care and ensure that we can continually improve our services.
Our lawful basis for processing Patient Level Information and Costing Systems (PLICS) data under the UK General Data Protection Regulation (UK GDPR) is Article 6(1)(e) – because it is necessary for us to process the data to carry out our legal duties under the National Health Service Act 2006.
As the PLICS data we process is health data, which is a special category of data under UK GDPR, we also need an additional legal basis under Article 9 of UK GDPR. This is Article 9(2)(h) – because the processing is necessary for the purposes of providing you with health care or managing the health and social care system - this is permitted under paragraph 2 of Schedule 1 of the Data Protection Act 2018.
NHS Digital has a legal obligation to collect the PLICS data from us, and has issued us with a Data Provision Notice (DPN) under section 259(1)(a) of the Health and Social Care Act 2012. This means we have a legal obligation to submit PLICS data to them in accordance with the manner and frequency set out in the DPN.
What we do with it
The PLICS data is securely sent to NHS Digital, which is the central organisation that receives the PLICS data from other publicly funded providers of Acute, Mental Health, Improving Access to Psychological Therapies, Ambulance and Community Services across England in relation to Patient Level Information and Costing. NHS Digital combines the data we send with other corresponding data sent by other care providers and removes all identifying details before the data is issued to other organisations.
Your data is used to inform new costing methods for NHS services and enables us to receive information back from NHS Digital and NHS Improvement that we can use to maximise our resources and improve efficiencies.
The PLICS data is used to produce reports that only show summary numbers of, for instance, analysis of costing data for accident and emergency (A&E), admitted patient care (APC) and outpatient (OP) activity. It is impossible to identify any individual patient in the reports, but the reports do help us to improve the care we provide to you and other patients. Anonymous information is also published on NHS Digital’s website.
The expected benefits of PLICS to you as a patient include improving patient outcomes and allowing commissioners and providers to better understand costs and activity flows, so enabling them to maximise the use of taxpayer’s investments.
How NHS Digital uses your data
You can find out more information about how NHS Digital uses your PLICS data including their lawful basis for processing, how long they hold it for and your rights at:
Alternatively, you can call 0300 303 5678.
How long we keep it
[Insert details here of how long your organisation retains PLICS data]
What are your rights?
You have a right to object to the processing (use) of your personal data in some circumstances by letting us know [insert contact details here]. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it. This will not affect your treatment in any way.
You can also make a subject access request for information that we hold about you.
[insert details here of how patient can make a subject access request]
You also have the right to have inaccurate personal data rectified and to request the restriction or suppression of your personal data in specific circumstances, for example if you feel that the data held is inaccurate. Please contact us on [insert contact details here].
Your right to complain
If you wish to raise a complaint concerning our handling of your personal data, please visit our feedback and complaints pages [insert link to your organisation’s complaints pages].
You also have a right to raise a concern with the Information Commissioner’s Office at any time. Their contact details are: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.