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 arrangement 1. We may also use your medical records to carry out research within the practice.
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) Controller contact details
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Dr Sean Kennedy
STEPPS SURGERY 131 Cumbernauld Road, Stepps, G33 6EY
0141 779 4445
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2) Data Protection Officer contact details
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Mrs Michelle Nobes Information Governance Manager, DPO eHealth Department Kirklands Hospital Fallside Road Bothwell, G71 8BB
01698 858079
michelle.nobes@lanarkshire.scot.nhs.uk
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3) Purpose of the processing
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Medical research
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4) Lawful basis for processing
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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...’
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5) Recipient or categories of recipients of the processed data
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The recipient of the data will be advised in advance in the case of any research activity being undertaken
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6) Rights to object
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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.
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7) Right to access and correct
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You have the right to access any identifiable data that is being shared and have any inaccuracies corrected.
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8) Retention period
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The data will be retained for the period as specified in the specific research protocol(s).
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9) Right to Complain.
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You have the right to complain to the Information Commissioner’s Office, you can use this link ico.org.uk/global/contact-us
or call their helpline Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
The Information Commissioner’s National Offices for Scotland is at
45 Melville Street, Edinburgh EH3 7HL
0303 123 1115
scotland@ico.org.uk
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