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Privacy Notice

Who we are 

The HealtheIntent Population Health Management Programme (PHM), allows health and care professionals to work collaboratively, using a jointly managed information system to deliver better safer care. 

Providers & partner organisations will be able to use patient information to understand the needs of the local population, including health inequalities and target support where it will have the most impact. 

These organisations provide health and care services in Coventry and Warwickshire. They include local GP practices, hospitals, community and mental health. 

Each is also registered with the Information Commissioner’s Office (ICO) as a data controller – an organisation that decides what information is collected and why, and how it is handled. The partners will be joint data controllers for any personal, or special categories of personal information they handle.

The privacy notice below explains how your personal information will be used, what for, who will be able to see it and why. 


What will your personal information be used for?

By sharing and analysing this information, we expect that everyone in Coventry and Warwickshire will have equal opportunities to live and enjoy the best, healthiest life possible.

We are already seeing many examples of clinicians and commissioners across the country taking a population health approach and thinking differently about how to plan and design care in an integrated way.

PHM allows us to:

  • Proactively provide care to you       
  • understand patient needs that might have been overlooked
  • design better health services
  • prevent diseases
  • predict future health issues

Where will information be stored and who will be able to see it? 

Patient information will be stored on a secure information system.

The information will be collected from General Practice, hospitals, mental health providers, community services, social care, and other sources. This will include personal information about your care. Only health and social care staff who are involved in providing your care will be able to see your identifiable information.

In some cases, the people working with the information will be able to look at anonymised information from citizens across all of Coventry and Warwickshire, for example, to look at health trends across the region. However, they wouldn’t be able to see personal information that could identify you.

All health and social care organisations in Coventry and Warwickshire that share information for Population Health Management will have signed an information sharing agreement that sets out, what information will be shared, what it will be used for, and the measures in place to protect the information and the individual’s rights and freedoms.


Our lawful basis for processing your information

Personal and special categories of data are processed to provide individual care. 
Under the data protection regulations, the processing of personal data for the purpose of health and social care provision is permitted by the Data Protection Act 2018 section 8(c) – “the exercise of a function conferred on a person by an enactment or rule of law”, specifically the NHS Act 2006 and the Health and Social Care Act 2012. The processing (sharing) of Personal Data for these purposes is permitted under Article 6(1) (e) of the UK General Data Protection Regulation:

Public Task: the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

For special category personal data (including health data), the processing (sharing) is permitted under the Data Protection Act section 10 (1) (c) – health and social care via Schedule 1 Part 1 section 2 “Health or social care purposes” satisfying section 10 (2) of permitting the legal basis of Article 9 (2) (h) of the UK General Data Protection Regulation:

Direct Care and Administration: processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of domestic law or pursuant to contract with a health professional and subject to the conditions and safeguards

We will also recognise your rights established under UK case law collectively known as the “Common Law Duty of Confidentiality”


How long do we keep your records?

Information is kept in line with ‘The Records Management Code of Practice for Health and Social Care’ 
To fulfil your ‘right to object’ (please see the next section), the platform will keep limited information about you, such as your name, date of birth and NHS number. This will ensure that, where you have objected, no health data will be made available for analysis. 


Your rights

You have the right to:

  1. Object to your information being available analysis through the Population Health Management Programme.
  2. Complain to the Information Commissioner’s Office if you are unhappy with the way we are handling your information. See below for details of how to do this.  

Contact your relevant health or care provider to:

  1. Ask to see the personal information they hold about you 
  2. Ask them to change information they hold about you if it is wrong. 

If you would like to object to your records being made available for professionals to view through the Integrated Care Record, you can find out how to do so on our right to object page.

If you are aged 16 or above, we will process your ‘right to object’ form by carrying out our normal checks on the details you have given us.

From the age of 13 to 16, we will consider your right to object if your form has been signed on your behalf by someone with parental responsibility.
If it has not, we will ask a recognised health or care professional if they consider you to be competent to make such a decision. 

If you are under the age of 13, we will only consider your right to object if your form has been signed on your behalf by someone with parental responsibility.



You have the right to complain if you are unhappy with the way your information is handled, or disagree with your healthcare provider’s decision about your information. In these circumstances you can contact the healthcare provider and ask them to look again at the decision.
If you are not happy with any decision your healthcare provider makes, you can contact the Information Commissioner’s Office at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) 
Telephone: 01625 545 745 (national rate) 
Fax: 01625 524 510