NHS App privacy policy: personal health record services

Version 2, 30 March 2023

Version 2, 30 March 2023

The NHS App privacy policy provides details of how we use and process any personal information you give us. It also has details of who to contact should you need to speak to the relevant data protection officer.

The information below describes how we use your data when you use personal health record services using the NHS App. The information in this policy also applies when you access these same services by logging in through the NHS website in a web browser.

What are personal health record services?

Personal health record services typically allow you to:

• view parts of your GP or hospital care medical records online
• message your healthcare professionals online
• record information about your health and share this with your GP or hospital online

If your GP surgery, hospital or other care provider offers a personal health record service, this will be made clear on their website along with the functionality available to you.

For NHS funded personal health record services in England, your GP surgery or hospital's chosen service may also be available within the your NHS App. Due to the way personal health record services are made available within the NHS App (through what is technically called a "webview") this is classed as a "connecting service" and NHS England does not undertake any processing of your personal information when you are using the personal health record service. Such connected services are described in the NHS App terms of use.

The NHS App is provided by NHS England and supports online access to a range of health services. You can download the app from the App Store and Google Play. You can also use the NHS website to log in.

Who is involved in providing personal health record services?

The following organisations are involved in providing personal health record services available through your NHS App. Their respective roles are described below.

The service purchaser: your GP surgery or hospital

If a personal health record service is available at your GP surgery or hospital, then the GP surgery, the integrated care board (ICB) they belong to, or your hospital will have usually engaged one or more specialised personal health record supplier(s) to provide the service.

Personal health record supplier

A personal health record supplier is a commercial organisation providing the personal health record service on behalf of the service purchaser (your GP surgery or hospital). When choosing a supplier, the service purchaser scrutinises the service including technical, clinical, privacy and security aspects.

The agreements in place with the supplier(s) ensure that your GP surgery or hospital remains a "controller" of your information. This means each has a legal basis for processing your information, and is able to determine the purpose (why) and means (how) of such processing.

The supplier is either of the following, depending on the arrangements your GP surgery or hospital has made with them:

• a "processor" on their behalf (which means it processes your personal information in accordance with instructions issued by the service purchaser and is not able to use the information for other purposes)
• a “joint controller” with your GP surgery or hospital (subject to agreements setting out how the supplier may process the data)

A supplier may also be an “independent controller” of some of your personal information. This only applies where you have inputted personal information directly into the personal health records service and not shared this with your GP surgery or hospital through the service. For example, if you use the service to keep your own records of blood pressure readings taken at home but do not share these with your GP surgery or hospital.

Your information is not used by the supplier for any purpose other than the personal health record service purpose.

NHS England

NHS England connects the NHS App to the service purchaser's personal health record service. Because NHS England provides the NHS login service it is the controller for the personal information used to verify your identity but not for any health-related information. If you use the NHS App, you will have already verified your identity via the NHS login service, and can directly access the personal health record service through your NHS App. For this verification process to work, the personal health record service provider will process the information from your NHS login account as a processor on behalf of NHS England. The information processed is your:

• NHS number
• date of birth
• first and last names
• identity level (you can find out more about proving your identity)
• unique ID for this service
• email address
• mobile number

The NHS App also enables you to share your details from your NHS login account with the personal health record service so they can deliver their service. You will be asked if you wish to do this, and the specific pieces of personal information that are shared will be described within the NHS App the first time you use the service. If you do not wish to share these details you should not access the personal health record service using the NHS App.

Who is my personal health record supplier?

The personal health record services offered to you as a patient will depend upon which personal health record suppliers have been engaged by your GP surgery, the integrated care board (ICB) they belong to, or your hospital.

The name of the supplier is shown within your NHS App before any personal health record service is accessed. It will also be named on the service purchaser's website. If you are still unsure who your supplier is, ask the service purchaser (your GP surgery or hospital).

If your GP surgery or hospital does not offer personal health record services, you will not see any options relating to personal health records within your NHS App.

Links to privacy policies and help information

DrDoctor

DrDoctor lets you view and manage referrals and hospital appointments. See your hospital’s privacy policy and the DrDoctor privacy policy. Visit the DrDoctor website for help.

Health Call

Health Call Solutions lets you view and manage referrals and hospital appointments. See your hospital’s privacy policy and the Health Call privacy policy. Visit the Health Call website for help.

Healthcare Communications

Healthcare Communications lets you view and manage your hospital referrals and appointments. See your hospital’s privacy policy and Healthcare Communications’ privacy policy. Visit the Healthcare Communications website for help.

Induction Healthcare (UK) Limited

Induction Healthcare lets you view and manage your referrals and hospital appointments. See your hospital’s privacy policy and the Induction Healthcare privacy policy. Visit the Induction Healthcare website for help.

Netcall

Netcall lets you view and manage your hospital referrals and appointments. See your hospital’s privacy policy and the Netcall privacy policy. Visit the Netcall website for help.

Patients Know Best

Patients Know Best (PKB) also operate under the name Care Information Exchange (CIE). It lets you view parts of your GP or hospital care medical records online. You can also message your healthcare professionals, and record information about your health and share this with your GP or hospital.

PKB is a joint data controller with your local hospital for these services. See your hospital’s privacy policy and the PKB privacy policy [GP3] or CIE privacy policy. Visit the PKB or CIE websites for help information.

Substrakt Health

Substrakt lets you update your personal details, ask your GP surgery a question, or take part in a patient participation group. See your hospital’s privacy policy and the Substrakt Health privacy policy . Visit the Substrakt website for help.

Universal Care Plan / Better

The Universal Care Plan (UCP) is available in London and provided by a supplier called Better. It supports digitally sharing ‘What matters to you’ with everybody who cares for you – the ambulance service, GPs, in hospital or at home. See your hospital’s privacy policy and the Better privacy policy. Please visit the UCP website for more information about the UCP.

What personal data is processed for personal health record services and why?

The personal data processed when you use personal health record services varies depending upon the supplier. It generally include the following categories.

NHS login account information

This is used to identify you to the personal health record service.

Information in personal health records not supplied by you

This includes the content of your GP and hospital medical records, including information such as appointment details, medications, health conditions, messages and test results. Exactly what is shared by a healthcare provider with the personal health record service is determined by the functionality the service offers and local policies on what information the GP surgery or hospital uploads.

Information in personal health records supplied by you

If offered by the personal health record service, this may include information such as measurements (for example, weight and blood pressure), symptom severity ratings, diarised notes and messages provided by you.

Your rights

Data protection law provides a number of rights to you. You can exercise your rights by contacting the appropriate Controller. For your rights in relation to:

• NHS login account information (as described above) see the NHS App privacy policy
• your personal health record contents (as described above), contact your GP surgery or hospital for a copy of their privacy policy
• any data privacy objections or complaints, see section 9 of the NHS App privacy policy for details of how to contact our Data Protection Office