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FOOTFALL ONLINE AND VIDEO CONSULTATION PRIVACY NOTICE

The information contained in this document describes the use of your information
when you use the GP’s online consultation and video consultation service
provided by Silicon Practice.

This privacy notice supplements other privacy notices such as the one provided
by your GP practice which is available on their website.


INTRODUCTION

Your GP Practice has engaged a specialised online consultation and video
consultation supplier.

Your GP Practice as the data controller of your information remains responsible
for your data and will ensure that any data you provide to use this service is
used for the online consultation and video consultation purposes only.

The name of the organisation that your GP Practice has engaged with to provide
this service is Silicon Practice Ltd.


WHO ARE WE?

Silicon Practice operates a platform that is used to connect patients with their
GP Practice online.  Silicon Practice are acting as data processors for your GP
Practice under General Data Protection Regulation (GDPR) based on our data
processing agreement.


OUR CONTACT DETAILS

ICO – Registration Number Z9216576

Name: Silicon Practice

Address: Silicon Practice Ltd
Kingston House
Lydiard Fields
Swindon
SN5 8UB

Phone Number: 01793 710500

E-mail: gdpr@siliconpractice.co.uk

For all enquiries regarding data protection, please address your correspondence
to our Compliance Officer who will liaise with our Data Protection Officer as
needed.


WHAT ARE THE PURPOSES OF THE PROCESSING?

Up to date information regarding the process of information is outlined on the
NHS England website.


 WHAT IS THE LEGAL BASIS FOR PROCESSING THIS DATA?

Silicon Practice act as the data processor in relation to patients’ data.

The following legal bases set out in the General Data Protection Regulation
(GDPR) and UK Data Protection Act 2018 allow your GP to use your information
when you use this online consultation service provided by them:

 1. When using your Personal Information (Personal Data):
    Article 6 (1) (e) of the GDPR, which permits us to process your personal
    information that is necessary to provide a service which is in the public
    interest
 2. When using your Sensitive Personal Information (Sensitive Personal Data):
    Article 9(2) (h) of the GDPR which permits us to process your health
    information which is necessary for the provision of health treatment.


WHAT PERSONALLY IDENTIFIABLE INFORMATION DO WE COLLECT ABOUT YOU, AND WHY?

When you use our site to send a request to your GP Practice using one of our
forms, we collect your personal information and any medical data that you enter
in the form. We process this information in accordance with the data processing
agreement we have with your GP Practice and only ever act of their instructions.

We collect your personal information such as:

 * Your full name
 * Your phone number
 * Date of birth
 * Your email address
 * Postcode
 * Sex

In the case of you contacting the practice on behalf of someone else (e.g. a
child), we will also collect the name, sex and date or birth of the patient.

This information is collected so that:

 * Your GP practice can identify you (or the patient) in their records to enable
   them to reference medical history and respond to your online request
   appropriately.
 * To enable your GP Practice to send you a response either by email or text
   message, or to telephone you.

We safely collect, store and transmit communications and documents sent to you,
or received from you via Silicon Practice software. These communications and
documents include:

 * Requests sent in by you to the GP Practice, including any images or documents
   that you include.
 * Messages sent by your GP Practice to you.
 * Confirmation that you have accepted the terms and conditions associated with
   the use of the online consultation services.
 * Information about the devices and software you use to connect to our
   services.

Silicon Practice also collects usage data such as:

 * The data and time you sent your request to the GP Practice
 * The date and time that you read a reply from your GP Practice. This allows us
   to provide audit trials, so that we can convey to the GP practice whether you
   have read the message in order to maintain the clinical safety of our
   service.
 * Confirmation that you have accepted the terms and conditions associated with
   the use of the online consultation services.
 * The features of the Silicon Practice online consultation product you are
   using
 * Page views
 * Site navigation paths
 * As well as information about the timing, frequency and pattern of service
   use.
 * Details of the type of computer you are using.
 * The ip address you are using
 * We also monitor the functioning of our software to prevent fraud,
   cyberattacks and other dishonest behaviours.


VIDEO CONSULTATIONS

For patients using the Video Consultation feature, in addition to the
information above we collect and store:

 * The call participant’s browser type and version
 * Operating system
 * Length of call
 * Timing frequency and patterns of service use.

The video and audio communication of the video consultation is only visible to
the participants on the call and is never recorded or stored on any server.


DO WE SHARE YOUR PERSONAL INFORMATION?

As your GP has engaged Silicon Practice as a specialised organisation to provide
online consultation services and video consultation services on their behalf,
your personal data will be shared with your GP Practice in order for them to
provide this service to you.

Information which is not needed for the service is not collected by Silicon
Practice.

We use third-party data processors, such as email and storage providers. These
organisations are only given the data required to carry out their service (e.g.
your name and email address for emailing a GP Practice reply to you).

We provide anonymised statistics about the use of our platform, such as the use
of different features by our users. All personal data is removed by aggregating
the data. We share these aggregated usage statistics with third parties
including NHS Digital, NHS England, local commissioning bodies such as CCG’s and
STP’s and relevant government departments.


 HOW LONG IS YOUR PERSONAL INFORMATION KEPT?

Patients’ data is kept in line with the retention schedules stated within the
Records Management Code of Practice for Health and Social Care 2016.

 




CERTIFICATES AND COMPLIANCE

FootFall is currently on the NHS Dynamic Purchasing System for GP Online
Consultations and we are compliant with the following standards:


NHS

 * Cyber Essentials
 * DCB0129 Clinical Risk Management: its application in the Manufacture of
   Health IT Systems
 * CHECK approved Penetration Testing
 * NHS Data Security Awareness Training- Level 1
 * NHS Digital- Data Security and Protection Toolkit- Standards Met
 * Public Sector Bodies (Websites and Mobile Applications)(No.2) Accessibility
   Regulations 2018
 * Records Management Code of Practice for Health and Social Care 2016


GENERAL

 * General Data Protection Regulations 2018
 * Data Protection Act 2018
 * Privacy and Electronic Communications Regulations 2003
 * Computer Misuse Act 1990
 * Copyright, Designs and Patents Act 1988
 * Registered Designs Act 1949
 * Companies Act 2006



We are currently working towards achieving ISO 27001- Information Security
Standard- UKAS accreditation and compliance with the requirements of the GP IT
Futures Framework.

© Silicon Practice Ltd
 * Accessibility
 * Silicon Practice Privacy Notice
 * Job Applicants Privacy Notice
 * Modern Slavery Statement
 * Data Processing Agreement
 * Security Measures
 * Copyright
 * Disclaimer
 * Legal Statements
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