This update includes some new information for applicants applying to give someone access to their GP services. This service now allows patients to either apply to give someone else access to their GP services, or request access to someone else's GP services.
This privacy policy covers 2 use cases:
- a patient applying to nominate someone to have access to their GP services
- a patient applying to request access to someone else's GP services
1. How we use your personal information
This privacy policy explains how we use your personal data when you use Apply to manage someone's GP services for them, or get help managing yours, also known as the proxy application service. You can use this online service to apply to give someone access to your GP services or get access to some else's GP services.
This service is available on the NHS website.
You should read this policy alongside the terms of use for this service.
2. Terms we use in this policy
You may find it helpful to understand these terms when reading this policy.
- Data is "processed" when any action is taken with it. For example, when it is collected or reviewed.
- A "controller" is an organisation or person that decides what data is processed. They also decide how and why this needs to be done. They are legally responsible for that data.
- A controller may appoint a "processor". This is another organisation or person that processes data under the instruction of the controller.
- "Special category data" is personal information that has more legal protection, including data about your health.
You can find out more about these terms on the Information Commissioner’s Office website.
Apply to manage someone's GP services for them, or get help managing yours and who we are
This service, provided by NHS England, lets you send an application to your GP surgery, requesting to give someone you choose access to your GP services, or get access to help someone manage their GP services. The person you name in your application must be aware of the application and understand and consent to any access given.
Section 270 (1) (d) of the Health & Social Care Act 2012 allows NHS England to provide new services to improve health and care in England. This is our legal basis for providing this pilot.
Under data protection law, NHS England is a processor for the personal data you provide when you use this service.
NHS England is the controller for the following services which are used to provide Apply to manage someone's GP services for them, or get help managing yours:
- the Personal Demographics Service (PDS) which is the national electronic database of NHS patient details such as name, address, date of birth and NHS number (known as demographic information).
- NHS login which provides patients with a simple, secure and re-usable way to access multiple digital health and care services. About NHS login.
When you access our service using your NHS login details, the identity verification services are managed by NHS England. NHS England is the controller for any personal information you provided to NHS England to get an NHS login account and verify your identity, and uses that personal information solely for that single purpose. For this personal information, our role is a "processor" only and we must act under the instructions provided by NHS England (as the "controller") when verifying your identity. See NHS login privacy notice and NHS login terms and conditions. This restriction does not apply to the personal information you provide to us separately.
4. Information we collect about you
| Category of information | Personal data | Special categories |
|---|---|---|
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours log/audit data |
Personal data
Information captured against your session ID about your use of the service, such as the time of use, actions you took using the service, and associated technical log events. |
Special categories
No |
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours performance data |
Personal data
IP addresses are transmitted to Adobe as part of performance data but are not stored so users cannot be identified. |
Special categories
No |
|
Category of information
NHS login account information |
Personal data
The personal data provided by NHS login. |
Special categories
No |
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours data you enter |
Personal data
The information you enter during your application - which may include information about your health or the person you name in your application's health, or other special category data. |
Special categories
Yes |
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours metadata |
Personal data
The personal data that is derived by the service from the demographic information you provide and is auto generated. Metadata includes: date and time of submission, application reference number, NHS login identity proofing level, PDS match (of you and the person you name in your application), PDS calculated age (of you and the person you name in your application), PDS matched NHS number (of you and the person you name in your application), the organisation code for current GP practice (of you and the person you name in your application), success or failure of application. |
Special categories
Yes |
5. How we use your data
5.1 NHS login data
Apply to manage someone's GP services for them, or get help managing yours uses NHS login to prove who you are to the highest level of identity verification. When we send your application to your GP surgery they know the application has come from you. The service also uses your NHS login information to find your patient record on the Personal Demographics Service (PDS), and to get your contact details.
5.2 Personal Demographics Service (PDS) data
Apply to manage someone's GP services for them, or get help managing yours finds your patient record on PDS. It checks your name, NHS number, date of birth and your current GP surgery, to check you are eligible to use this service and your GP surgery is taking part in the pilot.
The service checks the information you enter about the person you name in your application. It checks either their name, date of birth, postcode, and current GP surgery, or their NHS number, date of birth and current GP surgery. This is done to check this person is eligible for this service and that you are both registered at the same GP surgery.
The service checks for contact details to include in your application which is sent to your GP surgery, so they can process the application.
Your contact details and the person you name in your application's contact details are used to send information about your application to you both.
5.3 Securely send your application to your GP surgery
The service uses NHS mail to securely send your application to your GP surgery. This includes NHS login data, PDS data, and data you have entered as part of your application.
Your GP surgery will become the data controller for your application when it is securely received by them.
5.4 Send application copy to you and the patient, and text notification
5.4.1. When you apply to give someone access to your GP services
If your application is completed successfully, the service will send you a copy of the application to the email address or addresses stored on NHS login. The person you want to give access to will also receive an email about the application, if they have contact information stored on PDS. This email will only show what services you’ve requested to give them access to.
The service will send you a text message about your application, using the mobile phone number stored on NHS login. This is done using gov.uk Notify. Find out more about security on Notify.
If a mobile phone number is found on PDS for the person you want to give access to, the service will send them a text message using gov.uk Notify. Find out more about security on Notify.
The person you want to give access to will only see your name and the services you chose during your application. They will not see your contact details, or any other data retrieved from NHS login or PDS, in the text or email they receive.
You will only see the information you entered as part of your application in the copy you receive. You will not see any information about the person you want to give access to, retrieved from PDS.
5.4.2. When you apply to get access to someone else's GP services
If your application is completed successfully, the service will send you and the patient a copy of the application, to the email address or addresses stored on NHS login or PDS.
If a mobile phone number is found on PDS, the service will send the patient a text message, using gov.uk Notify. Find out more about security on Notify.
The patient will only see your name and the details you entered in the application. They will not see your contact details, or any other data retrieved from NHS login or PDS, in the text or email they receive.
You will only see the information you entered as part of your application in the copy you receive. You will not see any patient information retrieved from NHS login or PDS.
5.5 Service improvement, audit and troubleshooting
We look at how the service is being used to help us make it better. We store some of the information you enter, which is not identifiable, to see how people are using the service. This includes information you enter in any free text boxes.
We put small files called "analytic cookies" on to your device. These cookies are optional. The information collected includes: the type of device you used, your browser type, your operating system, the date/time you used the service and how you interacted with the service. For more information, see our cookie policy.
We also store technical log data for audit and troubleshooting (bug/fix) purposes and to make improvements to the service.
The personal data collected by the service will be de-identified and analysed to optimize the service and for policy developments. Information on how many people use the service and its performance will also be used to publish anonymous statistical dashboards. See log/audit data for more information.
6. Legal basis and how long NHS England hold your data
| Category of information | Legal basis for use | Retention period |
|---|---|---|
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours application data - non-identifiable data |
Legal basis for use
Legal obligation – UK GDPR Article 6 (1)(c) to comply with section 270 (1) (d) of the Health & Social Care Act 2012 |
Retention period
We do not store any identifiable information after your application is sent to your GP surgery. We store non-identifiable information indefinitely to track performance of the service so we can improve it. This includes options you chose in your application, and any free text you entered. We also store calculated age (applicant and named person) to track who is using the service. |
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours analytics data - non-identifiable data |
Legal basis for use
Legal obligation – UK GDPR Article 6 (1)(c) to comply with section 270 (1) (d) of the Health & Social Care Act 2012 |
Retention period
We store non-identifiable information about your use of the service indefinitely, to track performance and improve the service. This includes analytics data on the success or failure of the application, timeouts and other service performance data. |
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours performance data |
Legal basis for use
Your consent via acceptance of NHS website cookies – UK GDPR Article 6 (1) (a) |
Retention period
12 months |
|
Category of information
NHS login account information |
Legal basis for use
Legal obligation – UK GDPR Article 6 (1)(c) to comply with the NHS Login Directions 2021 |
Retention period
2 years |
|
Category of information
Personal Demographics Service data - demographic information (applicant and named person) |
Legal basis for use
Legal obligation – UK GDPR Article 6 (1)(c) to comply with section 270 (1) (d) of the Health & Social Care Act 2012 |
Retention period
We do not store any identifiable information after your application is sent to your GP surgery. We store calculated age (applicant and named person) and GP surgery information to track who is using the service. |
|
Category of information
Apply to manage someone's GP services for them, or get help managing yours metadata |
Legal basis for use
Legal obligation – UK GDPR Article 6 (1)(c) to comply with section 270 (1) (d) of the Health & Social Care Act 2012 |
Retention period
We do not store any identifiable information after your application is sent to your GP surgery. We store non-identifiable information indefinitely to track performance of the service so we can improve it. This includes options you chose in your application, and any free text you entered. We also store calculated age (applicant and named person) to track who is using the service. |
7. Where we store your data
We only store and process your personal data within the UK.
8. Personal data for which NHS England is the controller outside the scope of Apply to manage someone's GP services for them, or get help managing yours
| Category of information | How the data is used and handled |
|---|---|
|
NHS login account information |
|
|
NHS demographic information |
9. Your rights
Data protection law provides you with a number of rights. You can exercise your rights by contacting NHS England's Data Protection Officer at enquiries@nhsdigital.nhs.uk.
- Right to be informed – this privacy policy explains how we use your personal data to provide this service.
- Right of access – to get a copy of the data we store that you gave to this service, you can request this by completing a Subject Access Request (SAR).
- Right to rectification – if you want to change or withdraw your application after it is completed, contact your GP surgery.
- Right to restrict processing – if you want to change or withdraw your application after it is completed, contact your GP surgery.
- Right to withdraw consent – you have the right to withdraw consent for analytical cookies to be placed on your device by selecting "Reject analytics cookies". See the NHS website cookie policy.
10. Who to contact with questions about your privacy
For any questions about your application data after you have submitted your application, contact your GP surgery.
Visit NHS login privacy notice for any questions about NHS login data.
11. Complaints
You can contact our Data Protection Officer to make a complaint:
By email
By post
Data Protection Officer
7 and 8 Wellington Place
Leeds
West Yorkshire
LS1 4AP
We ask that you try to resolve any issues with us first, although you have a right to lodge a complaint with the Information Commissioner's Office (ICO) at any time. The ICO is the UK regulator for data protection and upholds information rights.
12. Changes to the privacy policy
We may make changes to this notice. If we do, the version and date on this page will also change. Any changes to this notice will apply immediately from the date of any change.