Privacy Notice – Corporate Functions
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Conflicts of Interest and Declaration of Gifts and Hospitality
Purpose
All persons who are required to make a declaration of interest(s) or a declaration of gifts or hospitality should be aware that the register(s) may be published on the ICB’s website. This information may also be provided to individuals identified in the registers because they are in a relationship with the person making the declaration.
Legal Basis
Section 140 and section 14z8 of the NHS Act 2006
Processing Activities
An annual summary of the register(s) of interests (including the register of gifts and hospitality) are published as part of the ICB’s Annual Report and Annual Governance Statement. Where appropriate person identifiable information is excluded from our public registers.
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Management of Complaints
Purpose
To process your personal information if it relates to a complaint where you have asked for our help or involvement. From 01/07/2023 this included complaints regarding primary medical services.
Legal Basis
Explicit Consent – We will need to rely on your explicit consent in writing to conduct such activities.
Processing Activities
If you have a complaint about the ICB or a service that we commission, we will use your information to communicate with you and to investigate any concern that you raise with the ICB in line with its complaint policy.
Where the ICB is investigating a complaint involving several organisations then the information provided by the complainant (including personal details like for example name, address) may need to be shared as appropriate in order for the complaint to be investigated.
The ICB will use your postcode for monitoring to understand our community engagement and to ensure equality of service. This information will be anonymised by using Lower layer Super Output Areas Lower Layer Super Output Area (datadictionary.nhs.uk)
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Management of Serious Incidents
Purpose
NHS Norfolk and Waveney ICB is accountable for effective governance and learning following all Serious Incidents (SIs) that occur within Norfolk and Waveney.
Legal Basis
Statutory Obligation – Serious Incident Framework 2015
Processing Activities
NHS Norfolk and Waveney ICB work closely with all provider organisations as well as neighbouring ICBs to ensure all SIs are reported and managed appropriately. The Francis Report (February 2013) emphasised that commissioners, as well as providers had a responsibility for ensuring the quality of health services provided.
The ICB investigate, manage and reporting of all SIs.
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National Fraud Initiative
Purpose
NHS Norfolk and Waveney ICB is required by law to protect the public funds it administers. It may share information provided to it with other bodies responsible for auditing, or administering public funds, or where undertaking a public function, in order to prevent and detect fraud.
Legal Basis
The Cabinet Office is responsible for carrying out data matching exercises under its data matching powers set out in Part 6 of the Local Authority and Audit Act 2014 as part of the National Fraud Initiative (NFI).
Processing Activities
Under this legislation the Cabinet Office:
- May carry out data matching exercises for the purposes of assisting in the prevention of and detection of fraud;
- May require certain bodies to provide data for data matching exercises;
- May accept data submissions on a voluntary basis;
- Must prescribe a scale or scales of fees for mandatory data matching exercises;
- May charge a fee for voluntary data matching exercises; and
- Must consult mandatory participants and relevant stakeholders before prescribing the mandatory scale or scales of fees
Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information. Computerised data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.
NHS Norfolk and Waveney ICB participates in the Cabinet Office’s National Fraud Initiative to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Minister for the Cabinet Office for matching for each exercise, as detailed here. The Cabinet Office has published a privacy notice in respect of the National Fraud Initiative below:
National Fraud Initiative Privacy Notice
The use of data by the Cabinet Office does not require the consent of the individuals concerned under the Data Protection Act 2018.
Data matching by the Cabinet Office is subject to a Code of Practice.
For further information on the Cabinet Office’s legal powers and the reasons why it matches particular information, please refer to: www.gov.uk/government/collections/national-fraud-initiative
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Patient and Public Involvement
Purpose
If you have asked us to keep you regularly informed about the work of the ICB or if you are actively involved in our engagement and consultation activities, we will collect and process personal information that you have shared with us.
You input is invaluable in shaping health and integrated care services.
Legal Basis
Statutory Obligation – 14Z2 of the Health and Social Care Act 2012 Explicit Consent
Processing Activities
We will only use the information you have provided for this purpose. You will be actively informed how your information will be used for engagement and consultation activities. Your personal information will only be accessible by authorised staff from our Engagement Team will be retained for the minimum time necessary to satisfy the original purpose for collection.
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Locum Reimbursements
Purpose
To provide monetary reimbursements to GP Practices where they must employ a locum GP to cover GP long term sickness
/maternity/paternity cover.
Legal Basis
NHS Act 2006, Health and Social Care Act 2012.
Processing Activities
Locum reimbursement applications received and processed from GP Practices containing details of the GP clinician who is off sick/maternity/paternity in order to calculate the reimbursement amount due. Applications may also include invoices from Locum GPs, which may contain Locum GP Name and Address.
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Recruitment
Purpose
When an individual applies to work for NHS Norfolk and Waveney ICB, we will use the information they supply to us to process their application and to monitor the recruitment statistics. Where we want to disclose information to a third party, for example to take up a reference or obtain a “disclosure” from the Disclosure and Barring Service, consent is obtained during the application process, unless the disclosure is required by law.
Legal Basis
Consent: the individual has given clear consent to process their personal data for a specific purpose.
Processing Activities
NHS Norfolk and Waveney ICB uses the Trac Jobs recruitment platform to process its applications. Any information submitted by an applicant in relation to a vacancy within the organisation is provided with the candidate’s consent with a view to potentially entering into a contract of employment.
Further information on how your information is handled can be found here.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment process has been completed. It will then be securely destroyed using our confidential waste facilities or deleted from our network. We only retain anonymised statistical information about applicants to help inform our recruitment activities.
Once an individual has taken up employment with us, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for the purposes directly related to the individual’s employment. Once their employment has ended, we will retain the file in accordance with the Records Management Code of Practice for Health and Social Care.