Your information, what you need to know
This privacy notice explains why we collect information about you, how that information will be used, how we keep it safe and confidential and what your rights are in relation to this.
Why we collect information about you
Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received. These records help to provide you with the best possible healthcare and help us to protect your safety.
We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we will collect information about you which helps us respond to your queries or secure specialist services. We will keep your information in written form and/or in digital form
Our Commitment to Data Privacy and Confidentiality Issues
As a GP practice, all of our GPs, staff and associated practitioners are committed to protecting your privacy and will only process data in accordance with the Data Protection Legislation. This includes the General Data Protection Regulation (EU) 2016/679 (GDPR), the Data Protection Act (DPA) 2018, the Law Enforcement Directive (Directive (EU) 2016/680) (LED) and any applicable national Laws implementing them as amended from time to time. The legislation requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
In addition, consideration will also be given to all applicable Law concerning privacy, confidentiality, the processing and sharing of personal data including the Human Rights Act 1998, the Health and Social Care Act 2012 as amended by the Health and Social Care (Safety and Quality) Act 2015, the common law duty of confidentiality and the Privacy and Electronic Communications (EC Directive) Regulations.
Data we collect about you
Records which this GP Practice will hold or share about you will include the following:
- Personal Data – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Special Categories of Personal Data – this term describes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
- Confidential Patient Information – this term describes information or data relating to their health and other matters disclosed to another (e.g. patient to clinician) in circumstances where it is reasonable to expect that the information will be held in confidence. Including both information ‘given in confidence’ and ‘that which is owed a duty of confidence’. As described in the Confidentiality: NHS code of Practice: Department of Health guidance on confidentiality 2003.
- Pseudonymised – The process of distinguishing individuals in a dataset by using a unique identifier which does not reveal their ‘real world’ identity.
- Anonymised – Data in a form that does not identify individuals and where identification through its combination with other data is not likely to take place
- Aggregated – Statistical data about several individuals that has been combined to show general trends or values without identifying individuals within the data.
How we use your information
Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care. For example it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed. This is explained further in the Local Information Sharing at Appendix A.
Whenever you use a health or care service, such as attending Accident & Emergency or using Community Care services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:
- improving the quality and standards of care provided
- research into the development of new treatments
- preventing illness and diseases
- monitoring safety
- planning services
This may only take place when there is a clear legal basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential patient information about your health and care is only used like this where allowed by law.
Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed.
A full list of details including the legal basis, any Data Processor involvement and the purposes for processing information can be found in Appendix A.
How long do we hold information for?
All records held by the Practice will be kept for the duration specified by national guidance from NHS Digital, Health and Social Care Records Code of Practice. Once information that we hold has been identified for destruction it will be disposed of in the most appropriate way for the type of information it is. Personal confidential and commercially confidential information will be disposed of by approved and secure confidential waste procedures. We keep a record of retention schedules within our information asset registers, in line with the Records Management Code of Practice for Health and Social Care 2016.
Individuals Rights under GDPR
Under GDPR 2016 the Law provides the following rights for individuals. The NHS uphold these rights in a number of ways.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (not an absolute right) only applies in certain circumstances
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Your right to opt out of data sharing and processing
The NHS Constitution states ‘You have a right to request that your personal and confidential information is not used beyond your own care and treatment and to have your objections considered’.
Type 1 Opt Out
This is an objection that prevents an individual’s personal confidential information from being shared outside of their general practice except when it is being used for the purposes of direct care, or in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If patients wish to apply a Type 1 Opt Out to their record they should make their wishes know to the practice manager.
National data opt-out
The national data opt-out was introduced on 25 May 2018, enabling patients to opt-out from the use of their data for research or planning purposes, in line with the recommendations of the National Data Guardian in her Review of Data Security, Consent and Opt-Outs.
By 2020 all health and care organisations are required to apply national data opt-outs where confidential patient information is used for research and planning purposes. NHS Digital has been applying national data opt-outs since 25 May 2018. Public Health England has been applying national data opt-outs since September 2018.
The national data opt-out replaces the previous ‘type 2’ opt-out, which required NHS Digital not to share a patient’s confidential patient information for purposes beyond their individual care. Any patient that had a type 2 opt-out recorded on or before 11 October 2018 has had it automatically converted to a national data opt-out. Those aged 13 or over were sent a letter giving them more information and a leaflet explaining the national data opt-out. For more information go to National data opt out programme
To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.
On this web page you will:
- See what is meant by confidential patient information
- Find examples of when confidential patient information is used for individual care and examples of when it is used for purposes beyond individual care
- Find out more about the benefits of sharing data
- Understand more about who uses the data
- Find out how your data is protected
- Be able to access the system to view, set or change your opt-out setting
- Find the contact telephone number if you want to know any more or to set/change your opt-out by phone
- See the situations where the opt-out will not apply
Right of Access to your information (Subject Access Request)
Under Data Protection Legislation everybody has the right have access to, or request a copy of, information we hold that can identify you, this includes your medical record, there are some safeguards regarding what you will have access and you may find information has been redacted or removed for the following reasons;
- Does not cause harm to the patient
- That legal confidentiality obligations for the non-disclosure of third-party information are adhered to
You do not need to give a reason to see your data. And requests can be made verbally or in writing. Although we ask you to complete a form in order that we can ensure that we have checked your identity and you have the correct information you require.
Where multiple copies of the same information is requested the surgery may charge a reasonable fee for the extra copies.
You will need to provide proof of identity to receive this information.
If you would like to access your GP record online click here https://www.fairfieldsurgery.co.uk/
Change of Detail
It is important that you tell the surgery if any of your contact details such as your name or address have changed especially if any of your other contacts details are incorrect. It is important that we are made aware of any changes immediately in order that no information is shared in error.
Mobile telephone number
If you provide us with your mobile phone number, we may use this to send you text reminders about your appointments or other health screening information. Please let us know if you do not wish to receive text reminders on your mobile.
Where you have provided us with your email address, with your consent we will use this to send you information relating to your health and the services we provide. If you do not wish to receive communications by email please let us know.
Data Protection Legislation requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.
We are registered as a Data Controller and our registration can be viewed online in the public register at: http://ico.org.uk/what_we_cover/register_of_data_controllers
Any changes to this notice will be published on our website and in a prominent area at the Practice.
Data Protection Officer
Should you have any data protection questions or concerns, please contact our Data Protection Officer- Julie Watson, by telephoning the surgery or in writing.
What is the right to know?
The Freedom of Information Act 2000 (FOIA) gives people a general right of access to information held by or on behalf of public authorities, promoting a culture of openness and accountability across the public sector. You can request any non-personal information that the GP Practice holds, that does not fall under an exemption. You may not ask for information that is covered by the Data Protection Legislation under FOIA. However you can request this under a right of access request – see section above ‘Access to your information’.
Right to Complain
If you have concerns or are unhappy about any of our services, please contact the Julie Watson (Practice Manager)
For independent advice about data protection, privacy and data-sharing issues, you can contact:
The Information Commissioner
Phone: 0303 123 1113 Website: https://ico.org.uk/global/contact-us
The NHS Care Record Guarantee
The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under Data Protection Legislation.
The NHS Constitution
The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to. These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programs available to you, confidentiality, information and your right to complain if things go wrong.
Appendix A – The Practice will share your information with these organisations where there is a legal basis to do so.
|CCG||Purpose – Anonymous data is used by the CCG for planning and performance as directed in the practices contract.|
Legal Basis – Contractual
Processor – East Sussex CCG
|Summary Care Record||Purpose – During the Covid19 pandemic practices have been told to share details of patients personal confidential and special category data onto the summary care record. The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.|
Legal Basis – Direct Care
The relevant COPI notice states that its purpose: “…is to require organisations to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI.”
Full details of the Summary Care Record supplementary privacy notice can be found here
Patients have the right to opt out of having their information shared with the SCR by completion of the form which can be downloaded here and returned to the practice. Please note that by opting out of having your information shared with the Summary Care Record could result in a delay care that may be required in an emergency.
Processor – NHS England and NHS Digital via GP connect
|Research||Purpose – We many share personal confidential or anonymous information with research companies. Where you have opted out of having your identifiable information shared for this purpose your information will be removed.|
Legal Basis – consent is required to share confidential patient information for research, unless there is have support under the Health Service (Control of Patient Information Regulations) 2002 (‘section 251 support’) applying via the Confidentiality Advisory Group in England and Wales
Processor – currently we do not share information with any research companies
|Individual Funding Requests||Purpose – We may need to process your personal information where we are required to fund specific treatment for you for a particular condition that is not already covered in our contracts.|
Legal Basis – The clinical professional who first identifies that you may need the treatment will explain to you the information that is needed to be collected and processed in order to assess your needs and commission your care; they will gain your explicit consent to share this. You have the right to withdraw your consent at any time
Data processor – East Sussex CCG
|Safeguarding Adults||Purpose – We will share personal confidential information with the safeguarding team where there is a need to assess and evaluate any safeguarding concerns.|
Legal Basis – Because of public Interest issues, e.g. to protect the safety and welfare of vulnerable adults, we will rely on a statutory basis rather than consent to process information for this use.
Data Processor – Safeguarding teams, social services locally, other primary care providers involved in your care ie district nurses
|Safeguarding Children||Purpose – We will share children’s personal information where there is a need to assess and evaluate any safeguarding concerns.|
Legal Basis – Because of public Interest issues, e.g. to protect the safety and welfare of Safeguarding we will rely on a statutory basis rather than consent to share information for this use.
Data Processor – safeguarding team and social services locally, other primary care support services that you are accessing i.e. health visitor
|Risk Stratification – Preventative Care||Purpose – ‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.|
Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information. This can help us identify and offer you additional services to improve your health.
If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.
Type of Data – Identifiable/Pseudonymised/Anonymised/Aggregate Data
GDPR Art. 6(1) (e) and Art.9 (2) (h). The use of identifiable data by CCGs and GPs for risk stratification has been approved by the Secretary of State, through the Confidentiality Advisory Group of the Health Research Authority (approval reference (CAG 7-04)(a)/2013)) and this approval has been extended to the end of September 2022 NHS England Risk Stratification which gives us a statutory legal basis under Section 251 of the NHS Act 2006 to process data for risk stratification purposes which sets aside the duty of confidentiality. We are committed to conducting risk stratification effectively, in ways that are consistent with the laws that protect your confidentiality.
Processors – East Susssex CCG and Rural Rother PCN
Screening programmes (identifiable)
Notifiable disease information (identifiable)
Smoking cessation (anonymous)
Sexual health (anonymous)
|Purpose – Personal identifiable and anonymous data is shared.|
The NHS provides national screening programmes so that certain diseases can be detected at an early stage. These currently apply to bowel cancer, breast cancer, aortic aneurysms and diabetic retinal screening service. The law allows us to share your contact information with Public Health England so that you can be invited to the relevant screening programme.
More information can be found at: https://www.gov.uk/topic/population-screeningprogrammes [Or insert relevant link] or speak to the practice
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Data Processors PHE Surrey and Sussex Health Protection Team (South East), county Hall. Chart Way, Horsham.
Other Care Providers
|Purpose – Personal information is shared with other secondary care trusts and providers in order to provide you with direct care services. This could be hospitals or community providers for a range of services, including treatment, operations, physio, and community nursing, ambulance service.|
Legal Basis – The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 1 (a) Consent (c) Vital interest and (e) direct care and 9 (a) explicit consent; 9 2 (c) Vital interest and 9 2 (h) to provide health or social care: In some cases patients may be required to consent to having their record opened by the third party provider before patients information is accessed. Where there is an overidding need to access the GP record in order to provide patients with lifesaving care, their consent will not be required.
Processors – East Sussex Hospital Trust and Maidstone and Tunbridge wells NHS health trust
|Care Quality Commission||Purpose – The CQC is the regulator for the English Health and Social Care services to ensure that safe care is provided. They will inspect and produce reports back to the GP practice on a regular basis. The Law allows the CQC to access identifiable data.|
More detail on how they ensure compliance with data protection law (including GDPR) and their privacy statement is available on our website: https://www.cqc.org.uk/about-us/our-policies/privacy-statement
Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2) (h) as stated below
Processors – Care Quality Commission
|Payments, Invoice validation||Purpose – Contract holding GPs in the UK receive payments from their respective governments on a tiered basis. Most of the income is derived from baseline capitation payments made according to the number of patients registered with the practice on quarterly payment days. These amount paid per patient per quarter varies according to the age, sex and other demographic details for each patient. There are also graduated payments made according to the practice’s achievement of certain agreed national quality targets known as the Quality and Outcomes Framework (QUOF), for instance the proportion of diabetic patients who have had an annual review. Practices can also receive payments for participating in agreed national or local enhanced services, for instance opening early in the morning or late at night or at the weekends. Practices can also receive payments for certain national initiatives such as immunisation programs and practices may also receive incomes relating to a variety of non patient related elements such as premises. Finally there are short term initiatives and projects that practices can take part in. Practices or GPs may also receive income for participating in the education of medical students, junior doctors and GPs themselves as well as research. In order to make patient based payments basic and relevant necessary data about you needs to be sent to the various payment services. The release of this data is required by English laws.|
Legal Basis – Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.” And Article 9(2)(h) ‘as stated below
Data Processors – NHS England, CCG, Public Health
|Patient Record data base||Purpose – Your medical record will be shared, in order that a data base can be maintained and managed in a secure way|
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – Emis Webb
Subject Access Requests
|Purpose – Your medical record may be shared in order that solicitors instructed on your behalf or insurance companies seeking a medical report can have a copy to your medical history for a specific purpose.|
Legal Basis – Your explicit consent will be required before a GP can share your record for this purpose.
Processor – iGPR,
|Purpose – Your anonymous aggregated information will be shared in order to optimise medication. This will enable your GP to provide a more efficient medication regime for your personal care. Some of the anonymous information may be used nationally to drive wider understanding of the medication is used. No patients will be able to identified from the data shared.|
Legal Basis – Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Processor – currently we do not use this product
|Medicines Management Team||Purpose – your medical record is shared with the medicines management team, in order that your medication can be kept up to date and any changes can be implemented.|
Processor – East Sussex CCG medicines management team
GP Extended Access
|Purpose – Your medical record will be shared with the Rural Rother Federation in order that they can provide direct care services to the patient population. This could be in the form of video consultations, Minor injuries clinics, GP extended access clinics|
Processor – Rural Rother federation and Hastings federation
|PCN||Purpose – Your medical record will be shared with the Rural Rother PCN in order that they can provide direct care services to the patient population.|
Processor – Oldwood surgery, Martin’s oaK surgery, Northiam surgery, Seddlescombe and Westfield surgery , Ferry road Surgery and Rye medical center.
|Smoking cessation||Purpose – personal information is shared in order for the smoking cessation service to be provided.|
Legal Basis – consented
Processor – STAR
|Social Prescribers||Purpose – Access to medical records is provided to social prescribers to undertake a full service to patients dependent on their social care needs.|
Legal Basis – Consented
Processor –Southdown organisation
|Subject Access Requests Requestors||Purpose – Personal information will be shared with the person or their representative at their request|
Legal Basis – Contractual agreement with the patient – and consented
Processor – Patients and or their representatives – e.g. family members, solicitors, insurance companies
|Medical Reports||Purpose – Personal information will be shared with Insurance companies, or potential or active employers at the patients request|
Legal Basis – Consented
Processor – Patients and or their representatives – e.g. Insurance companies, RAF, Navy
|Police||Purpose – Medical reports may be requested by the police for criminals|
Legal Basis – Consented or Article 10 GDPR
Processor – Police Constabulary
|Coroners||Purpose – Personal information may be shared with the coroner|
Legal Basis – Legal Obligation
Processor – The Coroner
|Private healthcare providers||Purpose – Personal information shared with private health care providers in order to deliver direct care to patients at the patients request|
Legal Basis – Consented and under contract between the patient and the provider
Provider – as per agreed with the patient ie Sussex Nuffield, Sussex spire, Benenden hospital
|Purpose – Personal identifiable information shared with the texting service in order that text messages including appointment reminders, campaign messages related to specific patients health needs and direct messages to patients|
Legal Basis – Consent from patients and direct care
Provider – AccuRX, Mjog,
Including – Video Consultation
|Purpose – Personal information including images may be processed, stored and with the patients consent shared, in order to provide the patient with urgent medical advice during the COVID-19 pandemic.|
Legal Basis – Direct Care and Consent
Patients will be asked to provide consent if required to provide photographs of certain areas of concern. There are restrictions on what the practice can accept photographs of. No photographs of the full face, no intimate areas, no pictures of patients who cannot consent to the process. No pictures of children.
Processor – e-Consult, AccuRX
|MDT meetings||Purpose – Personal information will be discussed with other providers of care, in order to provide a secure video meeting platform to discuss patients needs during the COVID-19 pandemic.|
Legal Basis – Direct Care
Processor – MS Teams
Research and Planning
|Purpose – for the collection of Personal confidential data regarding the diagnosis, testing, self-isolating, fitness to work, treatment medical and social interventions and recovery from Covid-19. To enable research and planning during the Covid-19 pandemic.|
Legal Basis – Notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI), which were made under sections 60 (now section 251 of the NHS Act 2006) and 64 of the Health and Social Care Act 2001. Data will only be extracted for those patients who have consented to the process.
Provider – BioBank
|Purpose: Patients personal confidential data will be extracted and shared with NHS Digital in order to support vital health and care planning and research. Further information can be found here|
Patients may opt out of having their information shared for Planning or Research by applying a National Data Opt Out or a Type 1 Opt Out. Details of how to Opt Out can be found on our Privacy Notice. For the National Data Opt Out patients are required to register their preference below. https://www.nhs.uk/your-nhs-data-matters/
For Type 1 Opt Out they can complete the form and return it to their registered practice for action by the 23rd June 2021. https://nhs-prod.global.ssl.fastly.net/binaries/content/assets/website-assets/data-and-information/data-collections/general-practice-data-for-planning-and-research/type-1-opt-out-form.docx
Legal Basis : The legal basis for this activity can be found at this link : General Practice Data for Planning and Research: NHS Digital Transparency Notice – NHS Digital
Processor: NHS Digital
|Medication/Prescribing||Purpose : Prescriptions containing personal identifiable and health data will be shared with chemists/pharmacies, in order to provide patients with essential medication or treatment as their health needs dictate. This process is achieved either by face to face contact with the patient or electronically. Where patients have specified a nominated pharmacy they may wish their repeat or acute prescriptions to be ordered and sent directly to the pharmacy making a more efficient process. Arrangements can also be made with the pharmacy to deliver medication|
Legal Basis : Article 6(1)(e); “necessary… in the exercise of official authority vested in the controller’ And Article 9(2)(h) as stated below
Patients will be required to nominate a preferred pharmacy.
Processor – Pharmacy of choice
|GP Registrar – trainee|
We are not currently accepting trainee GPs
|Purpose – We are a GP training surgery. On occasion you may be asked if you are happy to be seen by one of our GP registrars. You may also be asked if you would be happy to have a consultation recorded for training purposes. These recordings will be shared and discussed with training GPs at the surgery, and also with moderators at the RCGP and HEE.|
Legal Basis – 6 1 (a) consent, patients will be asked if they wish to take part in training sessions.
9 2 (a) – explicit consent will be required when making recordings of consultations
Recordings remain the control of the GP practice and they will delete all recordings from the secure site once they are no longer required.
Processor – RCGP, HEE, iConnect, Fourteen Fish
|Learning Disability Mortality Programme|
|Purpose : The Learning Disability Mortality Review (LeDeR) programme was commissioned to improve the standard and quality of care for people with a learning disability.|
Legal Basis: It has approval from the Secretary of State under section 251 of the NHS Act 2006 to process patient identifiable information without the patient’s consent.
Processor : Bristol University.
|Technical Solution||Purpose: Personal confidential and special category data in the form of medical record, is extracted under contract for the purpose of pseudonymisation. This will allow no patient to be identified within the data set that is created. SCWCSU has been commissioned to provide a data processing service, no other processing will be undertaken under this contract.|
Legal Basis: Under GDPR the legitimate purpose for this activity is under contract to provide assistance.
6 1 (e) Public Task
9 2 (h) Health Care
Processor: SCW CSU
|Anti Coagulation Data Base||Purpose: Personal confidential data is shared with the INR database in order to provide certain patients who meet the criteria with an anticoagulation service. Data is held on the data base and can be accessed by the practice.|
Patients may exercise their rights of access by using the practices SARs process.
Legal Basis: Under UK GDPR Article 6 1 (e) Public Task
And Article 9 2 (h) Health data
Reviews of and Changes to our Privacy Notice
We will keep our Privacy Notice under regular review. This notice was last reviewed in April 2020.
Lawful basis for processing:
The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the GDPR:
- Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’; and
- Article 9(2)(h) ‘necessary for the purposes of preventative 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…”
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