NHS Somerset Health Checks Privacy Policy

Our contact details

The NHS Somerset Health Checks service is provided by:

Thrive Tribe, 1st Floor office, Kesslers Building, 11 Rick Roberts Way, London, E15 2NF

Telephone: 020 3434 2520

Our Information Governance Lead is oliver.langford@thrivetribe.org.uk and our Caldicott Guardian is jackie.williams@thrivetribe.org.uk

Thrive Tribe are registered with the ICO Z195597x

What type of information we have

Thrive Tribe collect, process and store Personal and Sensitive Information. This enables us to deliver our services. This information can include Name, DOB, Address, GP, NHS Number, Email, Telephone Number, Gender, Scio Economic Status, Ethnicity, Sexual Orientation, Smoking Status, Treatment, Paying for Prescriptions and Medical Conditions.

How we get your information and why we do we have it

We collect the information from a range of processes and hold on the Lawful Basis of Consent. You have the right to withdraw consent at any time by contacting:

Thrive Tribe, 1st Floor office, Kesslers Building, 11 Rick Roberts Way, London, E15 2NF

Telephone: 020 3434 2520 Email: hello@thrivetribe.org.uk

What we do with your information

As data controller we use a range of GDPR compliant processing platforms to collect, process and store data:

 

What type of information we have?

 

Thrive Tribe Ltd. store and process identifiable information of Somerset residents, solely for the purpose of meeting contract requirements set by Somerset County Council as Data Controller. This identifiable information includes:

  • Forename
  • Surname
  • Address
  • Postcode
  • Registered GP Surgery
  • NHS Number

No additional information is held by Thrive Tribe Ltd. to fulfil his purpose. Thrive Tribe Ltd. has no access to further resident data including health information or medication history.

Residents booking appointments with the Somerset NHS Health Checks can opt-in to providing Thrive Tribe Ltd. with personal contact information (Mobile phone number, landline phone number, e-mail address), enabling the service to communicate directly with the patient regarding their appointment. The booking process for Somerset NHS Health Checks required Thrive Tribe Ltd. to utilise other GDPR compliant processors (Detailed below) to meet their contractual obligations.

All patient appointment data collected by Thrive Tribe Ltd. as part of an NHS Health Check is stored anonymously on secure servers provided by other GDPR compliant processors. This enables Thrive Tribe Ltd. to meet their obligations to Somerset County Council.

How we get your information and why we do we have it?

Thrive Tribe Ltd. acts as a Data Processor on behalf of Somerset County Council, who are the Data Controller regarding Somerset NHS Health Checks. Resident information is obtained by Thrive Tribe Ltd. from NHS Digital as part of an ongoing agreement between Somerset County Council and NHS England. Data is provided to Thrive Tribe Ltd. by NHS Digital for this purpose twice annually, ensuring data records are as accurate as possible.

This information enables Thrive Tribe Ltd. To act on behalf of Somerset County Council to meet their statutory functions, laid down by legislation. As such Somerset County Council and therefore Thrive Tribe Ltd. do not rely on ‘consent’ as the lawful basis for processing data.

Thrive Tribe Ltd therefore rely on the below as lawful basis for processing resident data, ensuring that Somerset County Council can comply with their legal obligations as Data Controller:

  • Legal Obligation
  • Public Task
  • Legitimate Interest

During your NHS Health Check appointment, your patient data and clinical information will be entered in to our secure, private software (HC Application). This data is completely anonymised after submission of an NHS Health Check on Thrive Tribe’s HC Application and anonymised data will be shared with Somerset County Council to enable Thrive Tribe Ltd. to meet their contractual requirements.

What we do with your information?

 

Somerset NHS Health Checks Invitations

A statutory obligation of Somerset County Council (Local Authorities Regulations 2013 – Public Health Functions and Entry to Premises by Local Healthwatch Representatives) is to invite all their population aged 40 – 74 for an NHS Health Check. Thrive Tribe Ltd. fulfils this function on behalf of Somerset County Council as a core requirement of the relevant contract between both parties.

Thrive Tribe Ltd. sends printed NHS Health Check invitations regularly, following a pattern agreed with Somerset County Council as Data Controller. This procedure ensures that around 20% of the eligible population are invited for an NHS Health Check each year. There is no guarantee that an eligible resident will receive an invite for a Somerset NHS Health Check within a set period of time, or that an eligible resident will receive an NHS Health Check invitation within a set period of time from the day that they become eligible.

The procedure for inviting Somerset County Council residents to an NHS Health Check currently comprises two formal letter invitations from Thrive Tribe Ltd. on behalf of the local authority. There is currently not standardised timeline for follow up invitations to arrive with a recipient.

Should the recipient of a Somerset NHS Health Check invitation letter not wish to receive further invitations for a Somerset NHS Health Check, they retain the right to be removed from this invitation process. Please note that this removal would be permanent or at least until the resident contacted Thrive Tribe Ltd. to re-instate any future NHS Health Check invitations. A resident in this circumstance would still be welcome to book and attend an NHS Health Check with the service but would not receive further formal invitations to do so.

Thrive Tribe Ltd. also utilises some Somerset based GP surgeries as a sub-contractor on the Somerset NHS Health Check programmes, in order to meet the contract requirements, set by Somerset County Council. Patients of these specific GP surgery locations may receive a letter or text (SMS) invitation to attend a Somerset NHS Health Check at the surgery.

During a Somerset NHS Health Check appointment, a patient will be encouraged to leave their personal contact details including landline telephone number, mobile phone number and e-mail address. This provides Thrive tribe Ltd. with a means to contact a patient regarding their booked appointment (e.g. To notify them of any need to cancel this appointment). A patient must consent to this data being collected and opt in, however not providing such information will prevent the service from contacting the patient about their booking.

 

Somerset NHS Health Check Reporting

After your appointment, your health results are anonymised, and this anonymous information is accessed and analysed by both Thrive Tribe Ltd. and Somerset County Council to meet contractual and legal reporting obligations; as well as assess the performance of Somerset NHS Health Checks service against agreed expectations.

Patients who opt in to providing their contact information and also ‘Consent to Follow Up’ during an NHS Health Check with the service may be contacted a minimum of three months after their appointment to complete an online feedback survey. Completion is optional on behalf of the resident and all completed surveys remain anonymous. This patient feedback is necessary for Thrive Tribe Ltd. to collate to meet the requirements of the contract held with Somerset County Council.

Somerset NHS Health Check Data Transfer

At the point of completion of your NHS Health Check an anonymised version of your personal NHS Health Check results will be digitally transferred to your GP surgery. In most circumstances, where appropriate permissions exist between Thrive Tribe Ltd. (On behalf of Somerset County Council) and the GP surgery these results will automatically update your patient record at your GP surgery.

Maintaining this data flow is a contractual obligation of Thrive Tribe Ltd. regarding the service specification designed by Somerset County Council, as part of national expectations for all NHS Health Checks programmes. As a patient, you retain the right to refuse for your data to be transferred to your GP surgery’s patient record; but please note in these circumstances, we will be forced to terminate your NHS Health Check at that point, and you will not receive further care from Thrive Tribe Ltd.

Other Data Processors Utilised

In addition, for Thrive Tribe Ltd. to adequately deliver on their Somerset County Council contract we use other 3rd party software and GDPR compliant processing platforms to collect, process and store data.

 

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

 

 

 

 

VISITORS TO OUR WEBSITE

 

The following details how we process, collect, manage and store those details and how your rights under the GDPR, DPA & PECR are adhere to. Additionally, it will explain the use of cookies or software, advertising or commercial sponsorship from third parties and the download of any documents, files or software made available to you (if any) on this website. Further explanations may be provided for specific pages or features of this website in order to help you understand how we, this website and its third parties (if any) interact with you and your computer / device in order to serve it to you. Our contact information is provided if you have any questions.

 

USE OF COOKIES

 

This website uses cookies to better the users experience while visiting the website. As required by legislation, where applicable this website uses a cookie control system, allowing the user to give explicit permission or to deny the use of /saving of cookies on their computer / device.

 

WHAT ARE COOKIES?

 

Cookies are small files saved to the user’s computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.

 

Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit.

 

WEBSITE VISITOR TRACKING

 

This website uses tracking software to monitor its visitors to better understand how they use it. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.

 

 

DOWNLOADS & MEDIA FILES

 

Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party antivirus software or similar applications.

 

We accept no responsibility for third party downloads and downloads provided by external third party websites and advise users to verify their authenticity using third party antivirus software or similar applications.

 

 

CONTACT & COMMUNICATION WITH US

 

Users contacting this us through Thrive Tribe websites do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.

 

Where we have clearly stated and made you aware of the fact, and where you have given your express permission, we may use your details to send you products/services information through a mailing list system. This is done in accordance with the regulations named above.

 

 

EMAIL MAILING LIST & MARKETING MESSAGES

 

We operate an email mailing list program, used to inform subscribers about products, services and/or news we supply/publish. Users can subscribe through an online automated process where they have given their explicit permission. Subscriber personal details are collected, processed, managed and stored in accordance with the regulations named in ‘The policy’ above. Subscribers can unsubscribe at any time through an automated online service, or if not available, other means as detailed in the footer of sent marketing messages (or unsubscribe from all Mailchimp lists). The type and content of marketing messages subscribers receive, and if it may contain third party content, is clearly outlined at the point of subscription.

 

Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.

 

Our EMS (email marketing service) provider is Mailchimp and you can read their privacy policy in the resources section.

 

 

EXTERNAL WEBSITE LINKS & THIRD PARTIES

 

Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website.

 

Shortened URL’s: URL shortening is a technique used on the web to shorten URL’s (Uniform Resource Locators) to something substantially shorter. This technique is especially used in social media and looks similar to this (example: https://bit.ly/2IYPgR2). Users should take caution before clicking on shortened URL links and verify their authenticity before proceeding.

 

We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.

 

 

SOCIAL MEDIA POLICY & USAGE

 

We adopt a Social Media Policy to ensure our business and our staff conduct themselves accordingly online. While we may have official profiles on social media platforms users are advised to verify authenticity of such profiles before engaging with, or sharing information with such profiles. We will never ask for user passwords or personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.

 

There may be instances where our website features social sharing buttons, which help share web content directly from web pages to the respective social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about some social media privacy and usage policies in the resources section below.

 

How we store your information

We keep your information in harmony with Thrive Tribe’s records management policy. This policy is available on request from oliver.langford@thrivetribe.org.uk

How to complain

Thrive Tribe, 1st Floor office, Kesslers Building, 11 Rick Roberts Way, London, E15 2NF

Telephone: 020 3434 2520

Our Information Governance Lead is oliver.langford@thrivetribe.org.uk and our Caldicott Guardian is jackie.williams@thrivetribe.org.uk

Thrive Tribe are registered with the ICO Z195597x

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:     

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

 

 

 

 

Service changes to this web site privacy notice   

We keep our web site privacy notice under regular review. This web site privacy notice was last updated on 20th January 2020.

 

How to contact us

If you want to request information about our privacy policy you can email us (hello@thrivetribe.org.uk) or write to:

 

Information Governance Department,

1st Floor office

Kesslers Building

11 Rick Roberts Way

London

E15 2NF