Privacy Notice: Research
Plain English explanation
This practice participates in research. We will only agree to participate in any project if there is an agreed clearly defined reason for the research that is likely to benefit healthcare and patients. Such proposals will normally have a consent process, ethics committee approval, and will be in line with the principles of Article 89(1) of GDPR.
Research organisations do not usually approach patients directly but will ask us to make contact with suitable patients to seek their consent. Occasionally research can be authorised under law without the need to obtain consent. This is known as the section 251 arrangement1 . We may also use your medical records to carry out research within the practice.
We share information with the following medical research organisations with your explicit consent or when the law allows: TBA when applicable
You have the right to object to your identifiable information being used or shared for medical research purposes. Please speak to the practice if you wish to object.
We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.
1. Data Controller
Phoenix Medical Practice
33 Bell Lane,
Rochester, Kent ME1 3SX
2. Data Protection Officer
Lolu Adeniji & Patrick Mwondela
NHS Medway Clinical Commissioning Group
Unit A. Compass Centre North
Pembroke Road, Chatham Maritime
Kent ME4 4YG
3. Purpose of the processing
4. Lawful basis for the processing
Identifiable data will be shared with researchers either with explicit consent or, where the law allows, without consent. The lawful justifications are:
- Article 6(1)(a) “the data subject has given consent to the processing of his or her personal data for one or more specific purposes” or
- Article 6(1)(e) may apply “necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”
And in addition there are three possible Article 9 justifications
- Article 9(2)(a) – ‘the data subject has given explicit consent…’ or
- Article 9(2)(j) – ‘processing is necessary for… scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member States law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject’. Or
- Article 9(2)(h) – ‘processing is necessary for the purpose of preventative…medicine…the provision of health or social care or treatment or the management of health or social care systems and services...’
5. Recipient of the processed data
Or categories of recipients of the processed data
The data will be shared with TBA when applicable.
6. Rights to object
You do not have to consent to your data being used for research.
You can change your mind and withdraw your consent at any time.
Contact the Data Controller or the practice.
7. Right to access and correct
You have the right to access any identifiable data that is being shared and have any inaccuracies corrected.
8. Retention period
The data will be retained for the period as specified in the specific research protocol(s).
Right to Complain
You have the right to complain to the Information Commissioner's Office. You can visit the ICO Website or call their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) There are National Offices for Scotland, Northern Ireland and Wales, (see ICO website).
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