Practice Policies

General Practice Transparency Notice for GPES Data for Pandemic Planning and Research (COVID-19)

This practice is supporting vital coronavirus (COVID-19) planning and research by sharing your data with NHS Digital.

The health and social care system is facing significant pressures due to the coronavirus (COVID-19) outbreak. Health and care information is essential to deliver care to individuals, to support health, social care and other public services and to protect public health. Information will also be vital in researching, monitoring, tracking and managing the coronavirus outbreak. In the current emergency it has become even more important to share health and care information across relevant organisations. This practice is supporting vital coronavirus planning and research by sharing your data with NHS Digital, the national safe haven for health and social care data in England. 

Our legal basis for sharing data with NHS Digital

NHS Digital has been legally directed to collect and analyse patient data from all GP practices in England to support the coronavirus response for the duration of the outbreak. NHS Digital will become the controller under the General Data Protection Regulation 2016 (GDPR) of the personal data collected and analysed jointly with the Secretary of State for Health and Social Care, who has directed NHS Digital to collect and analyse this data under the COVID-19 Public Health Directions 2020 (COVID-19 Direction).

All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the data provision notice issued by NHS Digital to GP practices.

Under GDPR our legal basis for sharing this personal data with NHS Digital is Article 6(1)(c) - legal obligation. Our legal basis for sharing personal data relating to health, is Article 9(2)(g) – substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the COVID-19 Direction.

The type of personal data we are sharing with NHS Digital

The data being shared with NHS Digital will include information about patients who are currently registered with a GP practice or who have a date of death on or after 1 November 2019 whose record contains coded information relevant to coronavirus planning and research. The data contains NHS Number, postcode, address, surname, forename, sex, ethnicity, date of birth and date of death for those patients. It will also include coded health data which is held in your GP record such as details of:

      • diagnoses and findings

      • medications and other prescribed items

      • investigations, tests and results

      • treatments and outcomes

      • vaccinations and immunisations

How NHS Digital will use and share your data

NHS Digital will analyse the data they collect and securely and lawfully share data with other appropriate organisations, including health and care organisations, bodies engaged in disease surveillance and research organisations for coronavirus response purposes only. These purposes include protecting public health, planning and providing health, social care and public services, identifying coronavirus trends and risks to public health, monitoring and managing the outbreak and carrying out of vital coronavirus research and clinical trials. The British Medical Association, the Royal College of General Practitioners and the National Data Guardian are all supportive of this initiative.

NHS Digital has various legal powers to share data for purposes relating to the coronavirus response. It is also required to share data in certain circumstances set out in the COVID-19 Direction and to share confidential patient information to support the response under a legal notice issued to it by the Secretary of State under the Health Service (Control of Patient Information) Regulations 2002 (COPI Regulations).

Legal notices under the COPI Regulations have also been issued to other health and social care organisations requiring those organisations to process and share confidential patient information to respond to the coronavirus outbreak. Any information used or shared during the outbreak under these legal notices or the COPI Regulations will be limited to the period of the outbreak unless there is another legal basis for organisations to continue to use the information. 

Data which is shared by NHS Digital will be subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the coronavirus purpose will be shared. Organisations using your data will also need to have a clear legal basis to do so and will enter into a data sharing agreement with NHS Digital. Information about the data that NHS Digital shares, including who with and for what purpose will be published in the NHS Digital data release register.

For more information about how NHS Digital will use your data please see the NHS Digital Transparency Notice for GP Data for Pandemic Planning and Research (COVID-19).

National Data Opt-Out

The application of the National Data Opt-Out to information shared by NHS Digital will be considered on a case by case basis and may or may not apply depending on the specific purposes for which the data is to be used. This is because during this period of emergency, the National Data Opt-Out will not generally apply where data is used to support the coronavirus outbreak, due to the public interest and legal requirements to share information.

Your rights over your personal data

To read more about the health and care information NHS Digital collects, its legal basis for collecting this information and what choices and rights you have in relation to the processing by NHS Digital of your personal data, see:

Last edited: 14 May 2020 2:10 pm

Statement of Purpose

Patient Privacy Notice 

This Privacy Notice explains what information we collect about you, how we store this information, how long we retain it and with whom and for which legal purpose we may share it.

Please click on the link below for further information .

Privacy Policy

Malcolm Gandy

Deputy Director of Information  and Acting Data Protection Officer

St Helens and Knowsley Teaching Hospitals NHS Trust

Alexandra Business Park, Court Building, Prescott Road, St Helens,

WA10 3TP

 Tel: 0151 676 5245/5639



Confidentiality & Medical Records

Locked blue folderThe practice complies with data protection and access to medical records legislation. Identifiable information about you will be shared with others in the following circumstances:

      • To provide further medical treatment for you e.g. from district nurses and hospital services.

      • To help you get other services e.g. from the social work department. This requires your consent.

      • When we have a duty to others e.g. in child protection cases anonymised patient information will also be used at local and national level to help the Health Board and Government plan services e.g. for diabetic care.

If you do not wish anonymous information about you to be used in such a way, please let us know.

Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.

How we use your information

Freedom of Information

Information about the General Practioners and the practice required for disclosure under this act can be made available to the public. All requests for such information should be made to the practice manager.

Access to Records

In accordance with the Data Protection Act 1998 and Access to Health Records Act, patients may request to see their medical records. Such requests should be made through the practice manager. No information will be released without the patient consent unless we are legally obliged to do so.


Customer service form

If you have a complaint or concern about the service you have received from the doctors or any of the staff working in the practice, please let us know.

We operate a practice complaints procedure as part of the NHS system for dealing with complaints. Our complaints system meets national criteria.


We hope that most problems can be sorted out easily and quickly, preferably at the time they arise and with the person concerned. If your problem can not be sorted out in this way and you wish to make a complaint, we would like you to let us know as soon as possible - this will enable us to establish what happened more easily. If it not possible to do that, please let us have details of your complaint.

You may choose to make your complaint orally or in writing

      • within 12 months of the incident that caused the problem

      • within 6 months of discovering that you have a problem provided this is within 12 months of the incident.

Complaints should be addressed to the Practice Manager, Culcheth Medical Centre at the above address. Alternatively, you may ask for an appointment with the Practice Manager to discuss your concerns.

We will explain the complaints procedure to you and will ensure that your concerns are dealt with promptly. It will be great help if you are as specific as possible about your complaint. 

If you wish to discuss your concerns further please contact: 

NHS England Contact Centre, PO Box 16738h, Redditch B87 9PT 

What we shall do 

We shall acknowledge your complaint within 3 working days. You may then receive a formal reply in writing or you may be invited to meet with us to resolve the issue. If the matter is likely to take w while to investigate then we will let you know and keep you informed as investigations progress.

      • Find out what happened and what went wrong

      • Make sure you receive an apology, where this is appropriate

      • Identify what we can do to make sure the problem does not happen again

If you are complaining on behalf of someone else, we have to know that you have their permission to do so. A note signed by the person concerned will be needed unless they are incapable (because of illness) of providing this.

Where the patient is incapable of providing consent due to illness or accident, it may still be possible to deal with the complaint.

Please provide the precise details of the circumstances which prevent this in your correspondence.

Please note that we keep strictly to the rules of confidentiality.

If you are not satisfied with the practices' response, please refer your complaint to the

The Parliamentary and Health Service Ombudsman, Citygate, Mosley Street, Manchester, M2 3HQ or visit the 'Making a complaint page' at (to complain online or download a paper form).      

Practice Complaints Leaflet

Violence Policy

The NHS operate a zero tolerance policy with regard to violence and abuse and the practice has the right to remove violent patients from the list with immediate effect in order to safeguard practice staff, patients and other persons. Violence in this context includes actual or threatened physical violence or verbal abuse which leads to fear for a person’s safety. In this situation we will notify the patient in writing of their removal from the list and record in the patient’s medical records the fact of the removal and the circumstances leading to it.

Culcheth Medical Centre Whistleblowing Policy


Practice Protocol for the safe and effective use of AccuRx messaging and video consultations.

AccuRx Protocol

Practice Leaflet

Safeguarding at Culcheth Medical Centre

What is safeguarding?

Safeguarding simply means keeping people safe from harm. It is about protecting children and adults from abuse or neglect. There are many different types of abuse.

Types of abuse that children can suffer include:

physical abuse

sexual abuse


emotional abuse

domestic abuse

bullying and cyberbullying

child sexual exploitation

child trafficking

criminal exploitation and gangs

female genital mutilation


For more information on these types of abuse and how you can spot them, visit:

Warrington Safeguarding Partnership:



Types of abuse/neglect that adults can experience include:

physical abuse

sexual abuse

domestic abuse

psychological or emotional abuse

financial or material abuse

modern slavery

discriminatory abuse

organisational or institutional abuse



For more information on these types of abuse, you can visit:

Warrington Safeguarding Adults Board:

Social Care Institute of Excellence:

Who is responsible for safeguarding?

Safeguarding is everyone’s responsibility. Here at Culcheth Medical Centre all staff members play a role in safeguarding. Safeguarding is not just something we choose to do, it is also something we are required by law to do.

At Culcheth Medical Centre the Safeguarding Lead is Dr Animesh Sinha and the Deputy Safeguarding Lead is Tracy Whitford.

How does Culcheth Medical Centre safeguard children and adults who are, or who might be, experiencing abuse or neglect?

Keeping children and adults safe from abuse and neglect cannot be done by one person or one agency. At the heart of any safeguarding process is the child or adult who may be suffering abuse. We work in partnership with our patients who are, or who are at risk of, experiencing abuse as well as their families and advocates as appropriate.

We work closely with our health colleagues such as health visitors, the school nursing team, midwives, paediatricians, mental health teams and other hospital colleagues.  We also work with our partner agencies locally such as child and adult social care, education and the police to ensure any child or adult suffering abuse can be supported and protected and any concerns about abuse can be properly investigated.

To find out more about how agencies work together in Cheshire to keep children and adults safe visit:

Warrington Safeguarding Partnership:


Warrington Safeguarding Adults Board:

Safeguarding Training

All staff at Culcheth Medical Centre have the appropriate levels of safeguarding training for their job role. Safeguarding training standards are set nationally for all healthcare professionals and we follow this national guidance. Safeguarding training is essential to ensure all staff are able to spot signs of abuse or neglect and take action. We work hard to make safeguarding a key priority for our practice and our patients.

What will happen if a GP or any member of staff at the practice is worried that a child or adult is being abused or neglected?

All staff in the practice have a duty and responsibility to speak up and say something if they are worried a child or adult might be being abused or neglected. If any staff member has concerns they will discuss this with the practice Safeguarding Lead or with one of the other GPs who will decide what needs to happen next.

If a doctor is concerned that a child or young person is at risk of abuse or neglect, they must take steps to make sure the child or young person is protected. It can be very upsetting and stressful for families when this happens and parents often have questions about what their doctor may or may not do.

This leaflet from the General Medical Council (GMC) helps to answer those questions:

If a doctor is concerned that an adult is at risk of abuse or neglect, they will

Ask the person if they require any immediate support to keep themselves safe

Explain how safeguarding works

Ask the person what they would like to happen (Making Safeguarding Personal)

Support the person in a way to give them choice and control to improve their quality of life, wellbeing, and safety.

To do this the doctor will:

Listen to the person

Understand their views and wishes

Take them seriously

Treat them with respect

Support them to feel as safe as they want

Support them to make their own decisions

Keep them informed and involved

Tell the person what will happen next.


When making decisions about what action is necessary to safeguard an adult, healthcare professionals have to consider whether the person has capacity to understand their situation and make decisions about what should happen to them.

What is capacity?

Capacity means the ability to use and understand information to make a decision, and communicate any decision made.

A person lacks capacity if their mind is impaired or disturbed in some way, which means they're unable to make a decision at that time.

For more information on capacity visit:

All professionals have to follow The Mental Capacity Act which empowers and protects people who are not able to make their own decisions. This covers decisions about property and financial affairs, health, welfare and where they live.

For more information on The Mental Capacity Act visit:

Information Sharing

Sharing information with other relevant professionals is an important part of safeguarding. Sadly, reviews of cases where a child or adult has been killed or seriously harmed due to abuse or neglect, have often found that professionals have not shared the right information with the right person at the right time to keep the child or adult safe.

All staff at the practice must comply with the law and national guidance when making decisions about information sharing. The General Medical Council (GMC) provide guidance for doctors making decisions about information sharing. The practice also follows the Caldicott Principles:

Justify the purpose(s) for using confidential information

Don't use personal confidential data unless it is absolutely necessary

           Use the minimum necessary personal confidential data 

           Access to personal confidential data should be on a strict need-to-know basis 

           Everyone with access to personal confidential data should be aware of their responsibilities 

           Comply with the law

 The duty to share information can be as important as the duty to protect patient confidentiality

As a general rule we will ask for the person’s (or relevant parent/guardian, advocate, Power of Attorney) permission before sharing information for safeguarding purposes.

However, there are circumstances where we will need to share information even without the person’s permission (consent). Examples of these circumstances include:

Other people are, or may be, at risk, including children

Sharing the information could prevent a serious crime

A serious crime has been committed

Someone in a position of trust is implicated in causing abuse/neglect

The risk of serious harm or death is very high in a domestic abuse situation

A court order  has requested the information

Again as a general rule, we will inform the person that we will need to share information about them in order to keep them or others safe from serious harm, as long as this does not increase risk of harm to the person or others.

Where can you get help if you are worried you or someone else is suffering abuse or neglect?


Abuse is always wrong

No one should have to live with abuse

By reporting abuse you can help bring it to an end

Worried about a child?

Where there are significant immediate concerns about the safety of a child, you should contact the police on 999.

if you are worried about any child and think they may be a victim of neglect or abuse, you can make a referral to:

Children’s Social Care Multi-Agency Safeguarding Hub (MASH) –
Tel: 01925 443322 (select option 2, then option 1)

Children’s Social Care Out of Hours: 01925 444400


You can also contact the NSPCC helpline on 0808 800 5000, email them or submit an online form. Further details are on the NSPCC website:

Worried about an adult?

Many adults may need help. This isn’t always safeguarding, (i.e, there is no one abusing them or neglecting them). They may need help because they can no longer cope for various reasons. They may require support to manage their needs or because they can no longer cope be being a carer, or they may need a number of referrals for services who can assess and support them

Whether its Safeguarding or care and support the number is the same

If you or the person you are concerned about is in danger and immediate action is required, you should ring the emergency services on 999.

If you or the person you are concerned about is not in immediate danger, you should ring

Adults Social Care – Tel: 01925 443322 (select option 2, then option 2)

Adults Social Care Out of Hour – Tel: 01925 444400

You can also speak in confidence to any member of the Culcheth Medical Centre team.

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