The Clatterbridge Cancer Centre NHS Foundation Trust is one of the UK’s leading cancer centres providing highly specialist cancer care across Merseyside, Cheshire and the surrounding areas, including the Isle of Man. 

We are based in Wirral, Liverpool and Aintree, and have a number of satellite sites. 

Out Trust is registered with the Information Commissioner’s Office (ICO) to process personal information under the Data Protection Act 2018, and our registration number is Z7367711.

 

Our privacy notice explains how we look after the information we hold about you. 

If you are a staff member or volunteer at The Clatterbridge Cancer Centre, read our Staff Privacy Notice.

If you want a child friendly copy or a copy in a different format, just email our Data Protection Officer.

Click here for an audio version. 

 

How do we get information and why do we have it?

 

The personal information we collect is provided directly from you for one of the following reasons:

● you have provided information to seek care – this is used directly for your care, and also to manage the services we provide, to clinically audit our services, investigate complaints, or to be used as evidence as part of an investigation into care

● you have sought assistance with our benefits team

● you have signed up to our patient participation group

● you have made a complaint

We also receive personal information about you indirectly from others, in the following scenarios: 

● from other health and care organisations involved in your care so that we can provide you with care

● from family members or carers to support your care

  • Your name, address, contact details and date of birth – we need this to send you letters or telephone you about your care, and to identify you when you visit us. It also helps us to receive your information from other hospitals if needed.
  • Your health information including any scans and test results.
  • Information about your family or carers or next of kin. This lets us know who to contact in an emergency. Your next of kin does not have a legal right to view your medical records or access any confidential information about you.
  • Whether you have a disability or any communication needs so we can make sure we can meet any needs you have.
  • Your GP details to let them know what care and treatment you receive from us.

We may also collect information such as:

  • your ethnic or racial origin
  • your religious beliefs
  • your sexual orientation and sex life
  • genetic data
  • any criminal or suspected criminal offences

Direct care

We use your information to provide you with care and treatment. This might include sharing your information with other NHS organisations that provide care to you. 

Complaints, feedback, legal claims and incidents

If you have made a complaint, staff investigating the complaints will need to access your health records and might need to share information with third parties such as solicitors. The same applies if you have made a legal claim against The Clatterbridge Cancer Centre.

If you have provided feedback on a service, we may need to share your information about your care with us with relevant staff, in order to look into your feedback.

If you have been involved in a serious incident, staff investigating the incident will need to access your health records.

Clinical audits

We have to monitor the services and treatment we provide. This means our clinical staff have to use patient information to look at the quality of care we provide. 

Research

We might use anonymised information for research – this means you cannot be identified from the information. If identifiable information is needed, you will be asked for consent first. 

CCTV

We have CCTV at our sites in order to protect patients, staff and visitors, and to prevent crime. CCTV is also used to monitor safety incidents. We do not have CCTV in any areas where patients receive treatment or that would be considered private. 

Health service planning and management

Information about how our patients are cared for is collected, such as appointment waiting times. This is used to monitor the service we are providing and to help us make sure our services continue to meet patient needs.

The Clatterbridge Cancer Centre NHS Foundation Trust works closely with other organisations to support patient care. This means that information will be shared between the hospital and other organisations who may be caring for you or involved in your care or who have a responsibility for management of the whole NHS. 

These may include:

  • NHS England
  • planners of health and care services (such as Integrated Care Boards)
  • NHS Business Services Authority
  • NHS Counter Fraud Authority
  • UK Health Security Agency and Office for Health Improvement and Disparities
  • Other NHS trusts
  • Your GP
  • Ambulance services
  • Cancer registries
  • Local authorities such as social services

We may also share information with third party data processers such as IT system suppliers, who provide the Trust with software that holds our patient data. 

In some circumstances we are legally obliged to share information or if the public good of sharing outweighs your right to confidentiality. This includes:

  • when required by NHS England to develop national IT and data services
  • when registering deaths
  • when reporting some infectious diseases
  • when a court orders us to do so
  • where a public inquiry requires the information
  • informing the police where a serious crime has been committed
  • where there are serious risks to the public or staff
  • to protect children or vulnerable adults

We are part of a regional sharing agreement across Cheshire and Merseyside, ensuring records can be shared by other care providers involved in your treatment and care. More information can be found at Cheshire and Merseyside's website

We also have to share data for monitoring our performance, such as analysis of cancer waiting times. This looks at whether we are seeing patients in a timely manner.

Where information is to be shared across organisational boundaries on a regular basis, we put in place information sharing agreements between all of the sharing parties involved. 

We may also process your information in order to de-identify it, so that it can be used for purposes beyond your individual care whilst maintaining your confidentiality. These purposes will include to comply with the law and for public interest reasons. 

 

Federated Data Platform

We share data with other organisations providing you care, via a federated data platform. Further information can be found here.

We will use a product called Cancer 360, which will be part of the federated data platform. It aims to help us improve your cancer care pathway. Information on how your data is protected in this product can be found here

 

Example Data Sharing Patient Infographic.png
Caption - A diagram giving an example of who the Trust may share your information with. This gives a visual display of information provided in the above paragraphs.

 

The law (Section 251, NHS Act 2006) says we must share some patient information with NHS England, for national registers. This includes the Cancer Registry* and the National Disease Registration Service**.

* Information about National Cancer Registration and Analysis Service (NCRAS)
** Information about the National Disease Registration Service

By law, we have to share some information, such as to the police to prevent a crime or to notify of infectious diseases. We will also share information for this purpose securely and in line with the law.

  • All staff at The Clatterbridge Cancer Centre must abide by the Common Law Duty of Confidentiality and have a confidentiality clause in their contract of employment.
  • All staff at The Clatterbridge Cancer Centre undertake annual training (Data Security Awareness) on keeping your information safe, secure and confidential and additional training relevant to their role
  • Every year we must meet certain standards (Data Security and Protection Toolkit) to make sure we are keeping information secure and to make sure our computer security meets high standards.
  • We only collect, use and share the minimum information necessary about you.
  • We only store your information in locations or with third parties which meet strict requirements in line with data protection law

We only keep your data for as long as is necessary. This is required by law. We follow the NHS Records Management Code of Practice.

For cancer patient records, this is usually 30 years after you last had contact with us, or 8 years after a patient passes away. 

 We will then dispose of the information as recommended by the Records Management Code for example we will securely dispose of your information by an approved confidential shredding service for paper records, an approved service for sanitising hardware or permanently delete information. There may be occasion where information is retained for archiving purposes. 

Under data protection law, you have rights including:

1. Your right of access - You have the right to ask us for copies of your personal information (known as a subject access request).

2. Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. Please email our Data Protection Officer  to place a request for records to be amended. 

3. Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. Please email our Data Protection Officer  to place a request for erasure. 

4. Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. Please email our Data Protection Officer  to place a request for restriction of processing. 

5. Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances. Please email our Data Protection Officer  to object to processing.

6. Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

7. You have a right to withdraw your consent. For example, if you consented to us using your patient story in communications, you can withdraw your consent for it to be used in this way. Please email our Data Protection Officer  for advice on withdrawing consent, or if you have received a consent form, contact details will be provided. 

 

You are not required to pay any charge for exercising your rights, such as asking for a copy of your records, however, there may be an administrative charge if a request for duplicates is received. If you make a request, we have one month to respond to you.

To make a request relating to your rights, please contact our Data Protection Officer via the email address provided in our contact details. 

There may be some activities we use artificial intelligence for, such as converting an audio recording of a consultation into text.

We also use something called 'Robotic Process Automation'. This is where an online robot (known as a digital worker) undertakes administrative tasks that would usually be carried out by a person.

We will inform you via the privacy notice of how the artificial intelligence makes decisions, in a way that is easy to understand. 

 

Artificial Intelligence for Radiation Treatment - Limbus AI

The Trust use artificial intelligence based computer software to help in some radiation treatments.

This computer software has learnt from lots of images of bodily organs to be able to provide an outline (known as a contour) of your organs near the region we are treating to help plan your radiotherapy treatment.

A trained member of clinical staff then undertakes a manual review of these contours to check they are correct and a second trained member of clinical staff also checks them once your treatment plan is produced to give us confidence that everything produced by the software is correct.

Artificial Intelligence in the Region - Annalise AI

Annalise AI looks at radiology images (like X-rays or CT scans) for anything it has been trained is unusual, to help prioritise image reporting. This aims to help with earlier diagnoses.

 

 

 

We may use your information to make automated decisions, which could have substantial impact on a person, but will always ensure human oversight and review is in place where this could impact patients. Please see our Artificial Intelligence section for details. 

We may use profiling, which refers to the use of personal data to predict things such as an individual’s health. We will provide information in this privacy notice of any profiling that takes place at the Trust. 

Your information will only be sent outside of the UK where the country has laws in place that meet the standards of data protection similar to those in the UK. We perform a number of checks to ensure this.

We will never sell any information about you to other organisations for profit.

We are applying the national data opt-out because we are using confidential information for planning or research purposes. 

The information collected about you when you use health and care 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 lawful basis to use this information. All these uses help to provide better health and care for you, your family and future generations. Confidential health and care information is only used like this when allowed by law. 

Whenever possible data used for research and planning is anonymised, so that you cannot be identified and your confidential information is not accessed. 

You have a choice whether you want your confidential information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential information will still be used to support your individual care. 

To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters 

You can change your mind about your choice at any time. 

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement. 

You have a choice about how you want your confidential patient information to be used. 

If you’re happy for us to use your information, you do not need to do anything.

If you choose to opt out, your confidential patient information will still be used to support your individual care.

There are now a number of different data sharing opt outs you can choose:

1. Stop your GP surgery from sharing your data (Type 1 Opt-Out)

2. Opt out of sharing your information for purposes other than your care and treatment (National Data Opt Out)

3. Opt out of sharing with the Federated Data Platform

Cheshire and Meseyside ICB have created a leaflet explaining how your data may be used in the local Secure Data Environment for research purposes.

If you are happy with this use of information you do not need to do anything. You can change your choice at any time.

If you have any questions or concerns about how we use your information, please contact our Data Protection Officer by post or email. 

Information Governance Manager (Data Protection Officer)
The Clatterbridge Cancer Centre NHS Foundation Trust
Clatterbridge Road
Wirral
CH63 4JY

Email our Data Protection Officer

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).

Find out how to make a complaint to the ICO

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113
01625 545 745

Email the Information Commissioner’s Office.

Some of the key purposes we collect and use your data, and the law we rely on are provided below.

Complaints 

We need your consent to deal with your complaint. We rely on UK GDPR Article 6(1)(a) and 9(2)(a) to deal with complaint information. 

Direct patient care

The Health and Social Care Act 2012 allows us to collect and use data to provide healthcare services to you. We rely on UK GDPR Article 6(1)(e) and 9(2)(h) to process information for direct care.

For other organisations to provide support services for us

We enter into contracts for other organisations to provide services on our behalf. 

They are subject to the same legal rules and conditions for keeping personal information secure. The organisations can only use your information for the service we have contracted for them and not for any other purposes. 

We rely on UK GDPR Article 6(1)(e) and 9(2)(h). 

Patient and public involvement

We will ask for your consent before sharing any information you provide us with for engagement (e.g. patient stories). We rely on UK GDPR Article 6(1)(a) and 9(2)(a). 

National registries

We have a requirement to provide information to certain national registries. We rely on UK GDPR Article 6(1)(e) and 9(2)(h). 

Research

Consent to participate in research is not the same as consent as a legal basis for processing under data protection legislation. We do not use consent to process for research purposes. We rely on UK GDPR Article 6(1)(e) and 9(2)(j). 

CCTV

We use CCTV at our sites for public safety and crime prevention and detection. Signs are displayed notifying visitors of the fact CCTV is in operation and who to contact for further information. We rely on UK GDPR Article 6(1)(e). 

Analysis to improve the services provided to our patients

In order to make sure we continue to provide services and care to meet your needs, we use information to monitor how we are meeting these needs. We rely on UK GDPR 6(1)(e) and 9(2)(h).