Health and Community Services' privacy policy

Health and Community Services comprise of:

• over 65s Community and Social Service
• over 65s  Nursing and Residential
• Adult Community Support Services
• Adult Mental Health
  
• Adults Social Work
• Alcohol and Drugs Services
• Clinical Support, including radiology, pathology, pharmacy, physiotherapy
  
• Commissioning and Supporting Voluntary Sector
• General Hospital
• Medical Specialists and Emergency Care
• New Healthcare Facilities
• Occupational Therapy
• Patient Transport Services
• Preventative Programmes
• Primary Care Governance
• Psychology
• Speech and Language
• Strategic Health Delivery Policy, including the Jersey Care Model
  
• Surgical Services
• Theatres and Anaesthetics
• Women and Children, including paediatrics,​​ gynaecology and obstetrics
  

We process and hold your information in order to protect vital interests, provide public services and meet our statutory and legal obligations. In some instances, we may also process your information where you have provided your consent. This notice explains how we use and share your information. Information may be collected on a paper or online form, by telephone, email, or by a member of our staff, or in some cases, by another States department.

We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law.

What information we collect about you

We collect the following types of information about you, which includes special category data:

• name
• address
• telephone number
• email address
• bank account details, where charges apply
  
• social security number and other unique identifiers
• date of birth
• non-binary or gender expression
• medical history and diagnoses
• observation charts and test results
• next of kin information
• correspondence and communication, via email, telephone calls and letters
• views, opinions or insights into services, treatments or facilities​
• family, lifestyle and social circumstance
• physical or mental health or condition
• racial or ethnic origin
• religious or other beliefs of a similar nature
• sexual life
  

Why we collect information about you

We need to collect, hold and process information about you, in order to:

• stay in touch with you
• verify you are who you say you are
• provide treatment and enable medical care
• fulfil the function of social services and social care
• protect against cross-border threats and ensure a high standard of health and social care
• answer your query and investigate complaints, relating to service provision and standards
• ensure that we meet our legal obligations
• prevent and detect crime
• process financial transactions including charges, where they apply
• protect individuals from harm or injury
  
• assure the quality of data and ensure that records are matched accurately
  
• allow the statistical and qualitative analysis of data so we can plan the provision of services, monitor the services provided and develop healthcare facilities

Use of your information for screening programme purposes

We use automated data processing to identify individuals who are eligible for certain disease screening tests, for example, to screen for certain types of cancer.

For further information on screening programmes, including who is eligible check out cancer screening and diabetic retinopathy programmes.​

Use of your information for public consultation purposes

We process information provided to us during engagement with the public to analyse view, insight and concerns in relation to our services and development of HCS facilities. Those engaging with public consultations will not be obligated to provide any information about themselves. Where those engaging with public consultations do provide identifying information, it will not be disclosed further or used for any other purpose.​

Use of your information for Clinical Audit purposes

Clinical audit is a way to find out if healthcare is being provided in line with standards, allowing Health and Community Services (HCS) and patients to know where services are doing well and where there could be improvements.

Health and Community Services have committed to robust local clinical audits to ensure best practice and good outcomes for patients in the services we deliver. In order to benchmark our standards and activity in service areas, we're also committed to National Audit which helps us identify areas where we can deliver improvements in the quality of services.

We ensure throughout the clinical audit process that: 

• your data is used only when necessary
• we process only the minimum necessary data for the purpose of the audit
• we will pseudonymise or anonymise your data wherever possible

Where we participate in National Audit, we do so in partnership with the Healthcare Quality Improvement Partnership (HQIP). The HQIP have robust protocols to ensure that your data is kept secure and enable your privacy rights.

Opting out

You can choose to opt-out of sharing your confidential patient information for National Audit. Opting out doesn't mean that we will stop using your data when we need to deliver care and treatment to you, but when we'd like to use your data for audit, quality improvement, research and planning.

To exercise your right to opt-out of your data being used for National Audit and research, email the Clinical Audit team at HSSClinicalAuditDepartment@health.gov.je. You can also request that we restrict the processing of your information for national audit purposes through the online form found at your personal data rights.

How we use the information about you

We will use the information you provide in a manner that conforms to the Data Protection (Jersey) Law 2018.

We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept. Ask to see our retention schedules for more detail about how long we retain your information.

We may not be able to provide you with a service unless we have enough information.

We will not pass any personal data on to anyone outside of the Government States of Jersey, other than those who either process information on our behalf, provide you with health or social care or because of a legal requirement. Where sharing is appropriate, we will only do so after we have ensured that sufficient steps have been taken by the recipient to protect your personal data. 

We will not disclose any information that you provide ‘in confidence’, to anyone else without your permission, except in the few situations where disclosure is required by law, or where we have good reason to believe that failing to share the information would put someone else at risk. You will be told about this unless there are exceptional reasons not to do so.

When we need to transfer your information outside of Jersey we will only do so if we have a legal basis, or failing that we will seek your consent and only if we are reassured that your information is still secure when transferred.

Transferring information to countries within the European Economic Area (EEA) is seen as relatively safe because these countries have strong data protection laws in place. There is a list of countries outside of the EEA that are also deemed safe. If we need to transfer your information outside of the EEA or to a country which is not on the list of safe countries, we will take extra steps to keep your information safe.

Data sharing

We may need to pass your information to other Government of Jersey (GOJ) departments or organisations to fulfil your request for a service. These departments and organisations are obliged to keep your details securely, and only use your information for the purposes for which it has been provided.

We may disclose information to other departments where it is necessary, either to comply with a legal obligation, or where permitted under other legislation. Examples of this include, but are not limited to:

• where the disclosure is necessary for the purposes of the prevention or detection of crime
• for the purposes of meeting statutory obligations
• to prevent risk of harm to an individual
  

We share data with the following organisations.

For information about how Primary Care General Practice use your data to support your care and treatment visit Primary Care Privacy Policy or your Primary Care provider's website.

For information about how​ the Jersey Health and Care Index (JHCI) collect and use your data visit Jersey Health and Care Index (JHCI).

At no time will your information be passed to organisations for marketing or sales purposes or for any commercial use without your prior express consent.

Emails

If you email us we may keep a record of your email address and a copy of the email for record keeping purposes.

For security reasons we will not include any confidential information about you in any email we send to you. We would suggest that you keep the amount of confidential information you send to us via email to a minimum, use our secure online services where possible or correspond with us by post.

We will not share your email address, or your email contents unless it is necessary for us to do so, either to:

• fulfil your request for a service
• comply with a legal obligation
• where permitted under other legislation

Telephone calls

We do not record or monitor any telephone calls you make to us using recording equipment, although if you leave a message on our voicemail systems your message will be kept until we are able to return your call or make a note of your message. File notes of when and why you called may be taken for record keeping purposes.

We will not pass on the content of your telephone calls, unless it is necessary for us to do so; either to:

• fulfil your request for a service
• comply with a legal obligation
• where permitted under other legislation

Publication of your information

We may need to publish your anonymised information on our website and/or in the Jersey Gazette for the following reasons:

• where we are required by law to publicise certain information
• in the interests of demonstrating a fair and transparent decision making process
• where we are required to provide statistical information about a group of people, although your data will be anonymised to protect your identity
• where you have responded to a public consultation, although your comments will be anonymised to protect your identity

We will not publish any of your sensitive personal information unless there is a requirement for us to do so in order to carry out our statutory functions.

Your rights

You can ask us to stop processing your information

You have the right to request that we stop processing your personal data in relation to any of our services. However, this may cause delays or prevent us delivering a service to you. Where possible we will seek to comply with your request but we may be required to hold or process information to comply with a legal obligation, to deliver medical care, and fulfil the function of social services and social care.

You can withdraw your consent to the processing of your information

Where you have been asked to give your consent to process your information, you have the right to withdraw your consent to the further processing of your personal data. However, this may cause delays or prevent us delivering a service to you. We will always seek to comply with your request but we may be required to hold or process your information in order to comply with a legal requirement, to deliver medical care, and fulfil the function of social services and social care.

You can ask us to correct or amend your information

You have the right to challenge the accuracy of the information we hold about you and request that it is corrected where necessary. We will seek to ensure that corrections are made not only to the data that we hold but also any data held by other organisations/parties that process data on our behalf. This does not extend to medical opinions or clinical records supported by accurately recorded data.

You request that the processing of your personal data is restricted

You have the right to request that we restrict the processing of your personal information. You can exercise this right in instances where you believe the information being processed is inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request but we may be required to continue to process your information in order to comply with a legal requirement, to deliver medical care, and fulfil the function of social services and social care.

You can ask us for a copy of the information we hold about you

You are legally entitled to request a list of, or a copy of any information that we hold about you. However where our records are not held in a way that easily identifies you, we may not be able to provide you with a copy of your information, although we will do everything we can to comply with your request.

Complaints​

If you have an enquiry or concern regarding Health and Community Services processing your personal data you can contact the HCS Information Governance team at Information Governance for Health and Community Services.​

You can also complain to the Jersey Office of the Information Commissioner about the way your information is being used.