Practice Policies & Patient Information
CCTV Policy
Introduction and Objectives
A Closed-Circuit Television System (CCTV) has been introduced by Arcadian Gardens Surgery (“the Practice”) comprising a number of cameras that are fixed. All cameras are fully operational.
The owner of the system is the Practice.
For the purposes of the UK Data Protection Legislation, the data controller is the Practice, which is registered with the Information Commissioner, registration ZA327350.
The system manager is the GP Principal, DR M C K PERERA. The GP Principal is also the key contact point, and should be contacted via the Practice’s normal contact details on the website for any issues relating to the system
It is recognised that operation of the Practice’s CCTV System may be considered to infringe on the privacy of individuals. The Practice recognises that it is their responsibility to ensure that CCTV on the premises should always comply with all relevant legislation, to ensure its legality and legitimacy. CCTV will only be used as a proportional response to identified problems and be used only in so far as it is necessary in a democratic society, in the interests of national security, public safety, the economic well-being of the area, for the prevention and detection of crime or disorder, for the protection of health and morals, or for the protection of the rights and freedoms of others.
The legislation concerning CCTV in Section 30 of the Protection of Freedoms Act 2012 has produced a CCTV Code of Practice from the Surveillance Camera Commissioner that has been approved by Parliament and the Practice must pay due regard to the code.
The Practice in managing its CCTV operations under this Code of practice will endorse and comply with all 12 guiding principles of the Surveillance Camera Code of Practice.
The Codes of Practice and observance of the Operational Procedures contained in the policy shall ensure that evidence is secured, retained and made available as required to ensure there is absolute respect for everyone’s right to a free trial.The Practice CCTV System shall be operated with respect for all individuals, recognising the right to be free from inhuman or degrading treatment and avoiding discrimination on any ground such as sex, race, colour, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth or other status.
Objectives
The objectives of the Practice CCTV System which form the lawful basis for the processing of data are: –
• To help deter crime and reduce the fear of crime
• To ensure the safety of persons in or near our premises and vehicles
• To protect our property from theft, vandalism and other threats
• To help detect crime and disorder, or other public safety issues
• To provide evidential material suitable for court proceedings, dispute resolution and civil proceedings
• To assist in supporting civil proceedings
• To assist in the overall management of the Practice, including dispute resolution and discipline management
Procedures
The GP Principal will provide access to the system where this is required. In their absence, the Practice Manager or Senior Partner will provide access.
Recordings will only be accessed where an incident has occurred or is suspected which falls within the objectives above. Review of recordings will take place only under supervision, and export of recordings will only be permitted where there is a legal requirement to do so. The persons involved in an incident may be present to review the information (including patients) where this is deemed necessary.
A record will be made of all uses of recordings and who viewed them.
Recording will be redacted (identifiable information such as faces blurred) when requested as part of a Subject Access Request.
How we comply with the code
Principle 1 Use of a surveillance camera system must always be for a specified purpose which is in pursuit of a legitimate aim and necessary to meet an identified pressing need.The specific purposes are given in Objectives above. There is a pressing need for the Practice to ensure the safety of its staff, patients and visitors, and to protect its assets.
Principle 2 The user of a surveillance camera system must take into account its effect on individuals and their privacy, with regular reviews to ensure its use remains justified.
This has been carefully considered. Fixed cameras record continuously within their scope and public areas are excluded from scope. Mobile cameras are not used.
Cameras are not placed in enclosed areas where there is an expectation of privacy e.g. bathrooms/toilets etc.
Principle 3 There must be as much transparency in the use of a surveillance camera system as possible, including a published contact point for access to information and complaints.
This is provided by this policy.
Principle 4 There must be clear responsibility and accountability for all surveillance camera system activities including images and information collected, held and used.
The Operations Manager/Practice manager is responsible and accountable for all activities
Principle 5 Clear rules, policies and procedures must be in place before a surveillance camera system is used, and these must be communicated to all who need to comply with them.
These are provided by this policy
Principle 6 No more images and information should be stored than that which is strictly required for the stated purpose of a surveillance camera system, and such images and information should be deleted once their purposes have been discharged.
Recordings made by detection are deleted after 30 days unless action is taken to preserve them. This is only done where the recordings are required for one of the objectives noted above.
Principle 7 Access to retained images and information should be restricted and there must be clearly defined rules on who can gain access and for what purpose such access is granted; the disclosure of images and information should only take place when it is necessary for such a purpose or for law enforcement purposes.
Only the roles noted above can access images except where required by law enforcement. The roles noted above will manage the viewing of images in normaluse to meet the objectives above. Viewing of images by persons involved in incidents will be granted where necessary for the objectives.
Principle 8 Surveillance camera system operators should consider any approved operational, technical and competency standards relevant to a system and its purpose and work to meet and maintain those standards.
These have been considered. As a technical standard, we have a minimum image size of 1080p to ensure sufficient clarity. However the resolution is not sufficient to allow document or computer screens to be read from the CCTV system.
Principle 9 Surveillance camera system images and information should be subject to appropriate security measures to safeguard against unauthorised access and use.
Images are stored on the servers at the Practice. These are appropriately secured.
Principle 10 There should be effective review and audit mechanisms to ensure legal requirements, policies and standards are complied with in practice, and regular reports should be published.
This policy is reviewed annually, the review date is at the end. No reporting is considered necessary by the practice except for logging of details of individual accesses for the purposes.
Principle 11 When the use of a surveillance camera system is in pursuit of a legitimate aim, and there is a pressing need for its use, it should then be used in the most effective way to support public safety and law enforcement with the aim of processing images and information of evidential value.
This principle is supported by this document.
Principle 12 Any information used to support a surveillance camera system which compares against a reference database for matching purposes should be accurate and kept up to date.
No reference databases are used.
Last updated June 2023.
Code of Behaviour for Patients and Visitors
Complaints Form and Policy
Submit a complaint using our online form.
Print off complaints form and the following complaints policy.
Important Notice
If you have a complaint or concern about the service you have received from the doctors or any of the staff working in this practice, please let us know by completing the form on this page.
We operate a practice complaint procedure as part of an NHS complaints system, which meets or exceeds national criteria. We hope that we can sort most problems out easily and quickly, often at the time they arise and with the person concerned. We make every effort to give the best service possible to everyone who attends our Practice.
However, we are aware that things can go wrong, resulting in a patient feeling that they have a genuine cause for complaint. If this is so, we would like the matter to be settled as quickly, and as amicably, as possible.
To have your complaint investigated, you need to complain within 12 months of the event happening, or as soon as you first become aware of the issue you want to complain about.
The time limit can be extended in special circumstances.
Interpreting Service
We can arrange for a meeting with the Practice Manager and an Interpreter for any patient whose first language is not English and needs help with their complaint.
How to make a compliment or complaint
Whether you are happy or unhappy with the care and treatment that you have received, please get in touch and let us know your views.
Receiving compliments and complaints is important to ensuring good quality local healthcare in our Practice – helping us to find out more about what we’re getting right and what we can improve.
We hope this will help you to make your feelings and experiences known to the appropriate people. Should you have a complaint we hope this page will give you more information about what to do, who to contact and what happens next.
How do I raise a concern / informal complaint?
You can speak to any member of staff initially with your complaint. This gives you the opportunity to resolve any concern you may have without it going through a formal process.
Most complaints are best resolved within the practice and these should be made via the Practice Manager.
Formal Complaint
What we will do
We will contact you about your complaint within three working days and offer to discuss with you the best way to investigate it, including the time scales for a reply. We will aim to offer you an explanation within that time frame. Or a meeting with the people involved.
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- Find out what happened and what went wrong
- Invite you to discuss the problem with those involved, if you would like this
- Apologise where this is appropriate
- Identify what we can do to make sure that the problem does not happen again.
If you feel you do not want to contact the surgery directly, then you can contact the NHS Complaints team on:
NHS England, PO Box 16738, Redditch, B97 9PT
If you are making a complaint please state: ‘For the attention of the complaints team’ in the subject line. Contact information for NHS England can be found here.
In General
If you have a complaint to make, you can either contact the Practice Manager or ask the Receptionist for a copy of our Complaints Procedure. We will endeavour to:
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- acknowledge any letter or Complaints Form within 3 working days of receiving it.
- deal with the matter as promptly as possible – usually within 20 working days – dependent on the nature of the complaint.
Who can complain
Complainants may be current or former patients, or their nominated or elected representatives (who have been given consent to act on the patients behalf).
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- Patients over the age of 16 whose mental capacity is unimpaired should normally complain themselves or authorise someone to bring a complaint on their behalf.
- Children under the age of 16 can also make their own complaint, if they’re able to do so.
If a patient lacks capacity to make decisions, their representative must be able to demonstrate sufficient interest in the patient’s welfare and be an appropriate person to act on their behalf. This could be a partner, relative or someone appointed under the Mental Capacity Act 2005 with lasting power of attorney.
Appropriate person
In certain circumstances, we need to check that a representative is the appropriate person to make a complaint.
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- For example, if the complaint involves a child, we must satisfy ourselves that there are reasonable grounds for the representative to complain, rather than the child concerned.
- If the patient is a child or a patient who lacks capacity, we must also be satisfied that the representative is acting in the patient’s best interests.
If we are not satisfied that the representative is an appropriate person we will not consider the complaint, and will give the representative the reasons for our decision in writing.
Time limits
A complaint must be made within 12 months, either from the date of the incident or from when the complainant first knew about it.
The regulations state that a responsible body should only consider a complaint after this time limit if:
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- the complainant has good reason for doing so, and
- it’s still possible to investigate the complaint fairly and effectively, despite the delay.
Procedure
We have a two stage complaints procedure. We will always try to deal with your complaint quickly however if it is clear that the matter will need a detailed investigation, we will notify you and then keep you updated on our progress.
Stage one – Early, local resolution
We will try to resolve your complaint within five working days if possible.
If you are dissatisfied with our response, you can ask us to escalate your complaint to Stage Two.
Stage Two – Investigation
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- We will look at your complaint at this stage if you are dissatisfied with our response at Stage One.
- We also escalate some complaints straight to this stage, if it is clear that they are complex or need detailed investigation.
- We will acknowledge your complaint within 3 working days and we will give you our decision as soon as possible. This will be no more that 20 working days unless there is clearly a good reason for needing more time to respond.
Complain to the Ombudsman
If, after receiving our final decision, you remain dissatisfied you may take your complaint to the Ombudsman.
The Ombudsman is independent of the NHS and free to use. It can help resolve your complaint, and tell the NHS how to put things right if it has got them wrong.
The Ombudsman only has legal powers to investigate certain complaints. You must have received a final response from the Practice before the Ombudsman can look at your complaint and it will generally not look into your complaint if it happened more than 12 months ago, unless there are exceptional circumstances.
Address:
Parliamentary & Health Service Ombudsman, Tower 30, Millbank, London, SW1P 4QP
Phone: 0345 015 4033
More information to the Ombudsman
Independent Complaints Advocacy Service (ICAS)
If you have concerns about or wish to make a complaint about the quality of care you receive from the NHS, or any other issues or experiences when using the NHS, ICAS can help. People using the health service usually feel they can raise such concerns with a member of staff, such as a Therapist, Doctor, Nurse or Receptionist and the NHS expects that the person you approach will do their best to help you. However, if you are not satisfied by their response or prefer to talk to someone who is not directly involved in your healthcare, ICAS is there to help.
ICAS provide a service which aims to improve your satisfaction and reduce any confusion or anxiety you may have and ICAS staff will act as quickly, and creatively, as possible to support patients, their carers and families to deal with concerns before they become more serious.
Complaints resolution staff at your Practice should give you further information about making a complaint and assist you in contacting ICAS, should you require help with your complaint from outside the NHS.
Please refer to the ICAS website for more information.
Telephone: 0300 330 5454
Confidentiality
All complaints will be treated in the strictest confidence.
Where the investigation of the complaint requires consideration of the patient’s medical records, we will inform the patient or person acting on his/her behalf if the investigation will involve disclosure of information contained in those records to a person other than the Practice or an employee of the Practice.
We keep a record of all complaints and copies of all correspondence relating to complaints, but such records will be kept separate from patients’ medical records.
Statistics and reporting
The Practice must submit to the local primary care organisation periodically/at agreed intervals details of the number of complaints received and actioned.
There Are A Number Of Sources Who Can Help You Make Your Decisions And Give Advice:
These include:
The Citizens Advice Bureau
Find your local Citizens Advice – Citizens Advice
NHS Complaints Independent Advocacy Service,
Tel: 0300 330 5454 or email via their web-site.
(Includes VoiceAbility)
POhWER (An advocacy service that also provides advocacy under the Care Act)
Tel: 03000 456 2370 or email via their web-site.
Heathwatch Haringey (can direct you to other advocacy services)
Tottenham Town Hall, Town Hall Approach Road, London, N15 4RX
Tel: 020 8888 0579
email: [email protected]
How we use your health and care data to improve care
For more information or if you don’t want your data shared please click here or scan the QR code.
You can also call 020 3198 8738 or email [email protected]
NHS Information Sharing
Click here for more information about sharing information from your health records
Privacy Notice
Click here to view our privacy notice
Privacy Notice – Children
Click here for our Privacy Notice for Children
Subject Access Request Form
Subject Access Request
Requesting copies of medical records or extract from medical records.