Privacy Policy
Active Lifestyles
How we use your information
The categories of this information that we collect, process, hold and share include:
Contact Information
- Telephone number
- Mobile telephone number
- Email address
Personal Information
- Name
- Full Address including post code
- Gender
- Details of registered GP Practice
- Details of medical history
- Smoking status
- Alcohol use
- Lifestyle and physical activity information
Equality Monitoring and special category data
- Employment
- Sexual Orientation
- Religion
- Gender at birth
- Disability
Results of NHS Health Check Testing
- Height
- Weight
- Waist measurement
- Blood pressure
- Heart Rate
- Cholesterol
- QRisk Score (this is the risk rating of you having a cardio-vascular event)
Why we collect and use this information
The Council and The Living Well Sefton Community Service (which includes Sefton CVS, May Logan Centre, Brighter Living Partnership, Netherton Feelgood Factory) use your personal information in order to:
- Organise and deliver the NHS Health Check Programme
- Assess health risks and provide individualised lifestyle and wellbeing support
- To recommend and refer into partner Living Well Sefton lifestyle and wellbeing services (Sefton Council, Sefton CVS, May Logan Centre, Brighter Living Partnership, Netherton Feelgood Factory, Sefton Carer’s Centre and Smokefree Sefton).
- To recommend to other third party lifestyle and wellbeing services
The pseudomynised data is also used to derive statistics and intelligence for research and planning purposes, which include:
- Producing assessments of the health and care needs of the population
- Identifying priorities for action
- Informing decisions eg on the design of services
- Assessing the performance of the NHS Health Checks Programme
- Reporting summary statistics to Office of Health Improvement and Disparities (OHID)
These statistics are presented in such a way that individuals cannot be identified from them and person identifiable details are removed as soon as possible in the process of intelligence.
The lawful bases on which we use this information
Article 6(1)(c) of the General Data Protection Regulation 2016 gives the Council a lawful basis for collecting and using personal data in order to comply with its legal obligations,
Article 6(1)(e) of the General Data Protection Regulation 2016 gives the Council a lawful basis for collecting and using personal data where it is in the exercise of official authority vested in the Council, performance of the task carried out in the public interest or in the exercise of the controller’s official authority.
Article 9(2) (g) of the General Data Protection Regulation 2016 gives the Council a lawful basis for collecting and using ‘special category’ data where the processing is necessary for reasons of substantial public interest, on the basis of Union or Member State 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 the interests of the data subject.
Article 9 (2) (i) processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy.
The NHS Health Check Programme is a legal responsibility of unitary or upper tier local authorities in England as per Local Authorities (Public Health Functions and Entry to Premises by Local Healthwatch Representatives) Regulations 2013. The data processed as part of the check is used to establish a QRisk score which predicts the probablitity of an individual developing cardio-vascular disease. With consent, this information is also used to refer to partner Living Well Sefton lifestyle and wellbeing services (Sefton Council, Sefton CVS, May Logan Centre, Brighter Living Partnership, Netherton Feelgood Factory and Smokefree Sefton) or to advise the individual of other services as appropriate.
Section 149 of the Equalities Act 2010 imposes a number of duties on public authorities when exercising their functions. More information on these duties can be viewed at the following link:
https://www.gov.uk/government/publications/public-sector-equality-duty
Storing this information
We hold your information for a period of 10 years from the date of your latest appointment in order to:
- ensure client eligibility for an NHS Health Check
- prevent duplicate records being created
- monitor and review the NHS Health Check programme
Data access is limited to key staff who are regularly trained to understand their duty towards protecting data and good information governance procedures.
Confidential public health data will only be shared with other areas of Sefton Council, Sefton CVS, May Logan Centre, Brighter Living Partnership, Netherton Feelgood Factory, Sefton Carer’s Centre, Smokefree Sefton, Sefton GP Practices and Public Health England with the permission of the Caldicott Guardian, once the necessary legal basis has been established and data protection safeguards have been verified, so that the data is managed and used under the same restrictions. Anyone who received information from the controller is also under a legal duty to keep it confidential.
Who we share this information with
We share data gathered as part of the NHS Health Check with the following parties in order to deliver the NHS Health Check Programme. We will also share your information to the following parties in order to refer into Living Well Sefton lifestyle and wellbeing services with your consent:
- Sefton Council
- Sefton CVS
- May Logan Centre
- Brighter Living Partnership
- Netherton Feelgood Factory
- Sefton Carer’s Centre
- Smokefree Sefton
Some personal information including name, address and date of birth will be held on a database and will be accessible by the parties as listed above for the purpose of preventing duplication of client reports.
We will transfer your information to other third party lifestyle and wellbeing services with your consent or you may wish to self-refer into these services.
GP Practices – Results of the NHS Health Check will be sent to your registered GP Practice with your consent. There will also be circumstances where the controller may have to share information due to Public Interest for example, where the processing is necessary in order to protect the vital interest of the subject or another individual.
Office for Health Improvement and Disparities– Anonymised aggregate information is shared eg the total number of people receiving an NHS Health Check.
Requesting access to your personal data
Under data protection legislation, you have the right to request access to information that we hold. To make a request for your personal information contact:
Lindsay McDowall at Lindsay.McDowall@sefton.gov.uk
Scott Morgans at scott.morgans@sefton.gov.uk
or the Data Protection Officer at: ino.information@sefton.gov.uk
You also have the right to:
- object to processing of personal data that is likely to cause, or is causing, damage or distress
- prevent processing for the purpose of direct marketing
- object to decisions being taken by automated means
- in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed
- right to data portability in certain circumstances
- The right to lodge a complaint with the supervisory authority (the Information Commissioner’s Office)
If you have a concern about the way we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/
Further information
If you would like further information about this privacy notice, please contact:
Lindsay McDowall, Development Manager at Lindsay.McDowall@sefton.gov.uk
Scott Morgans, Development Manager at scott.morgans@sefton.gov.uk
Or contact Sefton Council’s Data Protection Officer at:
Telephone: 0345 140 0845 email ino.information@sefton.gov.uk