FootFall Online and Video Consultation Privacy Notice

The information contained in this document describes the use of your information when you use the GP’s online consultation and video consultation service provided by Silicon Practice.

This privacy notice supplements other privacy notices such as the one provided by your GP practice which is available on their website.

Introduction

Your GP Practice has engaged a specialised online consultation and video consultation supplier.

Your GP Practice as the data controller of your information remains responsible for your data and will ensure that any data you provide to use this service is used for the online consultation and video consultation purposes only.

The name of the organisation that your GP Practice has engaged with to provide this service is Silicon Practice Ltd.

Who are we?

Silicon Practice operates a platform that is used to connect patients with their GP Practice online.  Silicon Practice are acting as data processors for your GP Practice under General Data Protection Regulation (GDPR) based on our data processing agreement.

Our contact details

ICO – Registration Number Z9216576

Name: Silicon Practice

Address: Silicon Practice Ltd
Kingston House
Lydiard Fields
Swindon
SN5 8UB

Phone Number: 01793 710500

E-mail: gdpr@siliconpractice.co.uk

For all enquiries regarding data protection, please address your correspondence to our Compliance Officer who will liaise with our Data Protection Officer as needed.

What are the purposes of the processing?

Up to date information regarding the process of information is outlined on the NHS England website.

 What is the legal basis for processing this data?

Silicon Practice act as the data processor in relation to patients’ data.

The following legal bases set out in the General Data Protection Regulation (GDPR) and UK Data Protection Act 2018 allow your GP to use your information when you use this online consultation service provided by them:

  1. When using your Personal Information (Personal Data):
    Article 6 (1) (e) of the GDPR, which permits us to process your personal information that is necessary to provide a service which is in the public interest
  2. When using your Sensitive Personal Information (Sensitive Personal Data):
    Article 9(2) (h) of the GDPR which permits us to process your health information which is necessary for the provision of health treatment.

What personally identifiable information do we collect about you, and why?

When you use our site to send a request to your GP Practice using one of our forms, we collect your personal information and any medical data that you enter in the form. We process this information in accordance with the data processing agreement we have with your GP Practice and only ever act of their instructions.

We collect your personal information such as:

  • Your full name
  • Your phone number
  • Date of birth
  • Your email address
  • Postcode
  • Sex

In the case of you contacting the practice on behalf of someone else (e.g. a child), we will also collect the name, sex and date or birth of the patient.

This information is collected so that:

  • Your GP practice can identify you (or the patient) in their records to enable them to reference medical history and respond to your online request appropriately.
  • To enable your GP Practice to send you a response either by email or text message, or to telephone you.

We safely collect, store and transmit communications and documents sent to you, or received from you via Silicon Practice software. These communications and documents include:

  • Requests sent in by you to the GP Practice, including any images or documents that you include.
  • Messages sent by your GP Practice to you.
  • Confirmation that you have accepted the terms and conditions associated with the use of the online consultation services.
  • Information about the devices and software you use to connect to our services.

Silicon Practice also collects usage data such as:

  • The data and time you sent your request to the GP Practice
  • The date and time that you read a reply from your GP Practice. This allows us to provide audit trials, so that we can convey to the GP practice whether you have read the message in order to maintain the clinical safety of our service.
  • Confirmation that you have accepted the terms and conditions associated with the use of the online consultation services.
  • The features of the Silicon Practice online consultation product you are using
  • Page views
  • Site navigation paths
  • As well as information about the timing, frequency and pattern of service use.
  • Details of the type of computer you are using.
  • The ip address you are using
  • We also monitor the functioning of our software to prevent fraud, cyberattacks and other dishonest behaviours.

Video consultations

For patients using the Video Consultation feature, in addition to the information above we collect and store:

  • The call participant’s browser type and version
  • Operating system
  • Length of call
  • Timing frequency and patterns of service use.

The video and audio communication of the video consultation is only visible to the participants on the call and is never recorded or stored on any server.

Do we share your personal information?

As your GP has engaged Silicon Practice as a specialised organisation to provide online consultation services and video consultation services on their behalf, your personal data will be shared with your GP Practice in order for them to provide this service to you.

Information which is not needed for the service is not collected by Silicon Practice.

We use third-party data processors, such as email and storage providers. These organisations are only given the data required to carry out their service (e.g. your name and email address for emailing a GP Practice reply to you).

We provide anonymised statistics about the use of our platform, such as the use of different features by our users. All personal data is removed by aggregating the data. We share these aggregated usage statistics with third parties including NHS Digital, NHS England, local commissioning bodies such as CCG’s and STP’s and relevant government departments.

 How long is your personal information kept?

Patients’ data is kept in line with the retention schedules stated within the Records Management Code of Practice for Health and Social Care 2016.