Privacy Policy

The Data Protection (Bailiwick of Guernsey) Law 2017 came into force on 25th May 2018.

Our commitment to managing an individual’s personal data is detailed in our ‘Patient Privacy Notice’. We have a notice relating to ‘in hours’ work at the two surgeries and a separate notice relating to the Out of Hours service we run through Sarnia Medical Services Limited in conjunction with Island Health and Healthcare Group Guernsey.

In hours privacy notice

This privacy notice tells you what we do with your personal information when you contact us or use one of our services. It applies to everyone who uses our services. Personal information is any information that can be linked to a living person.

Who are we?

Queens Road Medical Practice provides a range of medical services and as such, we use information about our patients to provide them with the best possible health care. Queens Road Medical Practice are responsible for keeping the personal information we use safe and we take the privacy and rights of our patients very seriously. The policy detailed below outlines how we use data received from Patients and other members of the public and provides contact details should you require any further information.

What information do we collect?

We collect personal information in order to provide you with medical services. The information we collect will include:

• Names
• Contact details such as telephone number, email address, postal address
• Account information

We may also collect electronic information, such as:

• Your online identifier
• Your Internet Protocol (IP) address
• Tracking data such as your browsing choices on our website using internet cookies
• Hardware and software used
• General location data

Most of the data we hold is about health and medical conditions and this is considered ‘special category data’. This data is generally collected from the individual themselves, or other healthcare professionals. Under Data Protection Law, this ‘special category data’ is any personal information about someone's:

• Health (including mental health)
• Sex life
• Sexual orientation
• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership

How do we use this information?

Primarily we collect and use this data to provide the best possible medical care and to help us improve our services and the patient experience. This is in accordance with local law, which allows for the processing of data “for health and social care purposes undertaken by a health professional.” We use your information to:

• Verify your identity
• Improve our services and your patient experience
• Comply with regulation

We may also use your data to:

• Investigate or respond to legal enquiries
• Contact you if there are any changes to the policy
• Ensure we comply with legal requirements

Finally, data may be used for ‘legitimate interests of our business’. For example, to see that the Practice runs efficiently, plans for future services, trains its staff and receives monies due. Information may also be needed to help educate tomorrow's clinical staff and to carry out medical and other health research for the benefit of everyone.

We only share data according to the conditions set out in Law. This is primarily for direct medical care purposes, for example, with Sarnia Medical Services Ltd (the local primary care out of hours service), specialists, Island agreed screening programmes, Social Services and Employment and Social Security. We also share data for Public Health purposes. In exceptional circumstances, if there is an overriding public interest, for example people’s lives are at risk, we may share information with Police. These exceptions are:

• Exceptional cases permitted by law where we are legally compelled to do so
• Where there is a duty to the public to disclose
• Where disclosure is required to protect the vital interests of a patient
• Where disclosure is made at your request or with your consent

There are circumstances where we believe use of third-party processors would be beneficial to enabling us to provide you with the best service, but this would not be considered ‘essential’. In these circumstances we will seek explicit consent from you before using your data in this way, and you are entitled to say you would prefer us not to at any point. One example of this is a piece of software called ‘Heidi AI’, which transcribes conversations between you and our doctor during your consultation. This enables excellent contemporaneous efficient note keeping, allowing the doctor to spend more time focusing on what matters most - the patients themselves - without slowing down the consultations. Should you have any questions about this, please do not hesitate to get in touch with us.

Use of Email

We appreciate many people like to use email as a means of communication these days and we would like to accommodate this.

Under The Data Protection (Bailiwick of Guernsey) Law 2017 we are required to apply appropriate technical and organisational measures to ensure the security of our patients’ (data subjects) data.

However, it is important that you understand that we cannot guarantee the secure transmission of emails to personal email accounts.

Some email service providers provide a level of encryption, to reduce the risk that emails could be intercepted (hacked). Please check with your service provider exactly what cover they provide. Please also bear in mind that personal email accounts are at risk of being hacked once emails have been received.

Queens Road Medical Practice sends emails using forced Transport Layer Security (TLS), and therefore any email address which also has TLS will be automatically encrypted in this way.

If we are unaware of the TLS status, we ensure any emails containing personal identifiable information are be password protected.

Please note, due to the risks mentioned above, Queens Road Medical Practice will never initiate the use of email to communicate details about your medical care (Special Category Data). Should you wish to use email for this purpose, it will be at your own risk.

If you provide us with an email address it will be used for providing information considered relevant to your health. This may include:

• Information regarding services we think would be of interest / benefit to your health
• Practice development initiatives, e.g. health improvement surveys, patient feedback, Practice newsletter.

You can request we do not use your email address for any of the above purposes at any time by emailing/ calling / unsubscribing at any time.

Does your information go elsewhere?

To function efficiently we use other companies (‘data processors’) to fulfil certain obligations. For example, we outsource the secure destruction of data no longer required to another company. In all instances, these ‘data processors’ are vetted to ensure they also comply with the current regulations.

The Practice Policy for retaining data is in line with NHS UK guidance - the length of time records are kept for depends on the details within the medical history.

For any circumstances we may think it beneficial to process your data in a way that is not covered by another lawful basis, we will ensure we seek your explicit consent.

Access to your information

If you would like to request a copy of the information that we hold about you, please use the contact details below. To ensure your personal information is up to date, please inform us of any changes you think we should be aware of.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on our website. This privacy policy was last updated on 6th February 2025

Privacy Notice – Sarnia Medical Services Limited (SMSL), Guernsey

Sarnia Medical Services Limited is a joint venture between the entire Island’s GP Practices and it serves the whole population of Guernsey by running the Out of Hours GP Service.

Healthcare 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 us to provide you with the best possible medical care.  This privacy notice explains why Sarnia Medical Services Limited collects information about patients and how we keep it safe and confidential and how that information may be used.

We collect and hold data for the purpose of providing healthcare services to our patients.  We may keep your information in a written form and / or a digital form. The records will include basics details about you, such as your name, address and date of birth but they may also include more sensitive data (known as ‘special category’ data) such as information about your health, your problems, medical investigations, treatments and outcomes of treatments, your habits, appointments you have attended, referrals to specialists and other healthcare providers, the observations and opinions of other healthcare workers within and outside of Sarnia Medical Services Limited, as well as comments and aide memoires reasonably made by healthcare professionals who are appropriately involved in your healthcare.

In some situations your health needs may require care from other healthcare providers or healthcare services outside of Sarnia Medical Services Limited or your own GP Practice, such as referral to see a specialist.  In these situations we will exchange with them information about you that is necessary for them to provide that care.  Anyone with whom we share this information will have a professional and contractual duty of confidentiality.

We share all records of the care provided by the Out of Hours Service with your GP Practice.  Your GP Practice will pass the minimum details required (date, name, GY number, date of birth, doctor’s initials, code indicating whether a consultation or home visit and the amount charged) to the Office of the Committee for Employment & Social Security (ESS) in order to claim the grant on your behalf towards the cost of your Out of Hours consultation.

Health and Social Care (HSC) provide a number of screening programmes to detect certain diseases such as bowel and breast cancer at an early stage.  For patients eligible for this screening your GP Practice will share a basic level of information with HSC such as your name, age and address so that you are invited to the relevant screening programmes.   We are also obliged to inform Public Health if patients are suffering with certain notifiable illnesses such as food poisoning.  This will require sharing some personal information with this organisation.  Anonymised data may be used at a local level to help the States of Guernsey plan services.

In all of these situations we would only share your information with others involved in your care who have a genuine need for it and only the minimum amount of information required to serve that purpose would be released. However, you do have a right to object to our sharing of any of your data.

We would not share your information with any other third parties without your explicit consent unless there were exceptional circumstance (i.e a life and death situation) or where disclosure is in the public interest or when there is a legal duty to do so, for example a court order.

We are required by Articles in the Data Protection (Bailiwick of Guernsey) Law, 2017 to provide you with information in the following subsections: 

Further information may be requested from Rob Jordan c/o Queens Road Medical Practice, St Peter Port, Guernsey GY1 1RH, Telephone (01481) 724184 or e-mail robjordan@eqrmp.com

As a ‘data subject’ you have rights concerning data that any organisation holds about you.

Those relevant to Queens Road Medical Practice include:

Right to Information for Personal Data:
You can expect us, as a ‘data controller’ to be open and honest about what data we hold and what we do with it.

Right to Data Portability:
You can ask us to transfer you data to another ‘data controller’.

Right of Access:
You are entitled to request access to information we hold about you. This is known as a Subject Access Request. Further details can be found under Subject Access Request.

Right to Object to Processing for Direct Marketing Purposes:
You are entitled to request we do not contact you for direct marketing purposes.

Right to Rectification:
If you dispute the accuracy or completeness of your personal data, you have the right to request this be amended.

Right to Erasure:
For data processed in certain circumstances, you have the right to request erasure of data. This is also known as ‘the right to be forgotten’. Please be aware there are specific circumstances, as stated in local law, when erasure is not appropriate, these include healthcare records. Therefore, we cannot guarantee we will be able to comply with these requests, but are happy to discuss any concerns you have regarding content of your records.

Right to Restriction of Processing:
For data processed in certain circumstances, you have the right to request the restriction of processing data.

All patients have the right to seek a second opinion on diagnosis and treatment options

Further Information:
Should you require further information please contact our Lead for Data Protection, Rob Jordan at robjordan@eqrmp.com

Every patient of the Practice is entitled to:

• Receive treatment which is, in the opinion of the Practitioner, reasonably necessary for the patient’s well-being, regardless of his or her ability to pay
• A clear explanation of, and advice on, the patient’s medical condition and any proposed treatment
• A referral for specialist’s medical opinion or other second opinion in appropriate circumstances
• Receive information via the Practice’s notice board or web site of any relevant health promotion exercises and preventative medicine initiatives
• Access to necessary paramedical support
• Absolute confidentiality of medical records maintained by the Practice subject to any provisions for disclosure imposed or allowed by law
• Be kept informed by means of the Practice notice board or web site of any substantial changes in the prices, terms or conditions upon which the Practice will serve the needs of its patients
• Have any formal complaint against the Practice investigated and dealt with in a manner which is both fair and expeditious and in accordance with the Practice protocol
• Maintain their liberty at all times, unless necessary for their treatment and care, after considering all national and local policies, procedures and legislation

The Practice is entitled to:

• Receive honesty, courtesy and civility from its patients

The Practice will not accept:

• Rudeness, threats or aggressive behaviour directed towards practitioners staff or other patients
• Repeated abuse of its facilities including at the out of hours service, located at The Princess Elizabeth Hospital.

Under local law, you are entitled to request a copy of the information the Practice holds about you.

The best way to do this is by completing the form below as it ensures we have all the information required to process your application – this process is known as making a ‘subject access request’.

Please note, photographic identification will be required before releasing medical notes. This is to ensure the highest standards of data security with regard to your information are maintained.

Most requests will be processed within one month, unless they are identified as complex, in which case the Practice has three months to complete the request.

If you require help completing this form or for further information regarding subject access requests please contact us at admin@eqrmp.com or on 01481 724184.

Please use the form below to make a subject access request.

Subject Access Request Form

By proceeding with treatment, the patient confirms that they have independently verified their insurance coverage for the services requested. It is the patient's sole responsibility to confirm with their insurance provider whether the proposed treatment(s) are covered, including any applicable co-pays, deductibles, or limitations.

Queens Road Medical Practice LLP operates under the assumption that this confirmation has been completed prior to scheduling or receiving care. We are not responsible for any denial of claims, partial reimbursements, or unexpected out-of-pocket expenses resulting from lack of insurance coverage. Any balance not covered by the patient’s insurance remains the responsibility of the patient.