UHL will collect this information about you to find out if the Service you receive has resulted in any behaviour or health changes or better self-management and, under contract to NHSE, is responsible for the recording, processing and securely storing the information you provide, creating your profile, and any information that you input as part of your engagement with your assigned Programme.

Sharing with third parties

Your identifiable personal data will be shared with:

• Your GP practice if you have consented to share your information with them to update your patient record (where you have self-referred to the programme)

• Personal Demographics Service:

  • To establish your NHS Number – more information below

  • To link your data with the National Diabetes Audit Data – more information below

• NHS Data Services for Commissioners Regional Offices (DSCRO’s)

  • To remove any identifying details and add a special code through a process called pseudonymisation, to allow your data to be linked to the National Diabetes Audit Data and shared for service monitoring purposes with SCW Commissioning Support Unit (SCW) and NHSE without anyone knowing your identity.

Non-identifiable data will be shared with:

• NHSE – for service monitoring and contract management.

• NHSE will receive data in relation to the Service and the contract in place to provide it. NHSE has asked SCW to manage this on their behalf. To undertake contract management, data management and business intelligence services, SCW will access data that does not identify you as it has been pseudonymised prior to it being made available.

• UoL may receive anonymised data about NHS Healthy Living users for the purposes of evaluation.

Service Evaluation

A service evaluation be undertaken to help NHS England understand whether/how the NHS Healthy Living service and its associated digital education programme help people to manage their diabetes. This will be completed with the assistance of NHSE sharing data from the National Diabetes Audit and using data collected by UHL and Promatica via the Healthy Living programmes. Your data will be pseudonymised by UHL and Promatica, and shared with UoL. This means that personal information such as your name and contact details will be removed, some personal information will be replaced with codes that the evaluation team will be provided the definitions for, and you will be assigned a unique identification number that will be used to link the data from UHL with the data within the National Diabetes Audit.

Individuals cannot be identified from the information provided.

Information sharing for evaluation purposes

Personal Demographics Service

If you register using an NHS Login account, the NHS Healthy Living Service will use the Personal Demographics Service to identify your NHS number to:

• Match your usage data to your patient record

• Match your usage data to the National Diabetes Audit (NDA)

Access to the Personal Demographics Service is strictly monitored; more information can be obtained here: Personal Demographics Service - NHS England Digital.

The purpose of this linkage to the NDA is to enable evaluation of the implementation of the Service.

Your name, surname, date of birth and postcode will be securely shared with NHSE to match your information to your NHS number. Your NHS number will then be securely shared with UHL and Promatica to add to your participant monitoring data.

National Diabetes Audit (NDA)

UHL will share the following identifiable personal data with UoL for the purposes of matching programme completion data with the NDA to update the audit with structured education programme usage:

• Name

• DOB

• Postcode

• NHS Number

• Structured Education completion status: Accepted or Completed the Programme

More information about the NDA can be found at National Diabetes Audit Programme – NHS England Digital

Information sharing with your GP practice

Self-referrals

Information on your use of the Programme will only be shared with your GP practice if you provide consent to do so on your registration. It will be used to keep your patient record up to date and inform your health care team that you are using the Service to support your self-manage of your diabetes.

The following will be shared:

• Name

• NHS Number

• Postcode

• Status: Accepted or Completed the Programme

GP referrals:

We will confirm if your referral to the NHS Healthy Living service has been accepted or declined, and when you have completed the Programme, the following will be shared:

• Name

• NHS Number

• Postcode

• Status: Accepted or Completed the Programme

GP System Integration (NHS IM1 Bulk Extract)

Promatica Digital Ltd is an approved supplier under the NHS IM1 (Interface Mechanism 1) pairing integration framework, which allows accredited systems to connect securely with GP clinical systems (EMIS and SystmOne).

Where your GP practice has chosen to take part in the NHS Healthy Living service and has a Data Processing Agreement in place with Promatica, information from GP records is securely extracted each night via the IM1 bulk extract mechanism. This information is processed on your GP practice's behalf and is used to:

·       Identify patients with a diabetes diagnosis who may benefit from the Service, so that they can be sent an invitation to register by SMS

Feedback and Comments

Any feedback or comments submitted to the Service will be reviewed and may be used in future publicity for the programme but will only include your:

• First name

• Location

• Diabetes diagnosis and time since diagnosis

• Feedback or comment

Additional personal identifiable information will only be included as part of the publicity where you have expressly consented to this.

How long your information will be kept for

Subject to the requirements of applicable law (and including in that your deletion right in respect of personal data), your information shall be kept by UHL for 30 days following the end of the contract with NHSE. At this point it will be deleted from the digital platform in accordance with the UHL data deletion policy. Should you wish to withdraw from the Service at any time you can delete your account on the digital platform or alternatively request UHL to do this for you via the NHS Healthy Living helpdesk. You will have the options to either have your data anonymised (i.e. all data excluding anything identifiable to remain in the database) or you can choose to be forgotten (i.e. all data deleted from the database in its entirety).

Information security

All organisations involved have policies and procedures in place to make sure only authorised and trained personnel access your information and that your information is handled and stored in a safe and secure way.

If you would like further information in relation to the information security procedures in place, please contact the relevant organisation.

Your rights

You have the right to request access to the identifiable personal information held by the organisations that hold data about you in relation to this Service; this is more often known as a subject access request. Your GP, the organisation that processed your referral, NHSE and UHL will hold your personal data in relation to your participation in this service.

To exercise this right, you should contact the Controller of the record you wish to access. Your GP will hold limited information relating to the Service but will hold more health information in your medical records. If an organisation has referred you, they may hold information about you in addition to that used for the Service.

You can view the data that UHL holds in your NHS Healthy Living Profile and account information accessible via the main menu once logged in.

For further information regarding making a request, please contact the relevant organisation. NHSE will not hold identifiable personal data as only data with identifiers removed will be processed by them therefore, they will not be able to identify personal data belonging to you and therefore you are unable to exercise the right of access.

You have the right to request that UHL and Promatica stop processing your personal data for the Service and can exercise this right by deleting your account. If you do decide to withdraw, where your data has been shared prior to the withdrawal date it may not be possible to prevent further processing of this information by the organisations that it has been shared with, but a withdrawn status will be applied to your record and shared with them. Where the data processed contains your information but in a way that does not identify you, this data will continue to be processed but will reflect a ‘withdrawn from Healthy Living status’ and so will no longer be actively processed.

Contact information

If you have any queries about this notice or need further information you can use the details below:

UHL c/o Healthy Living service, Leicester Diabetes Centre, Leicester General Hospital, LEICESTER, LE5 4PW.

NHS England, 7 and 8 Wellington Place, Leeds, West Yorkshire, LS1 4AP NHS England » Contact us

The Information Commissioners Office is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. They can be contacted here: Contact us | ICO

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