Purpose and Legal basis for processing
Most NHS care and treatment goes well but sometimes things can go wrong. If you are unhappy with your care or the service you have received, it is important to let us know so we can improve. When West Lancashire CCG receive a complaint, to allow it to be fairly and thoroughly managed, in most cases personal information will be required. CCGs have statutory duties (Section 6 of the Local Authority Social Services and National Health Service Complaints [England] Regulations (2009) (under section 113 “Complaints about Healthcare” of the Health and Social Care (Community Health and Standards) Act 2003)) which allow the processing of personal data in relation to complaints.
The legal basis we rely on to process your personal data is article 6(1)(e) of the GDPR, which allows us to process personal data when this is necessary to perform our public tasks as a CCG.
If the information you provide us in relation to your complaint contains special category data, such as health, religious or ethnic information the legal basis we rely on to process it is article 9(2)(g) of the GDPR, which also relates to our public task and the safeguarding of your fundamental rights. And Schedule 1 part 2(6) of the DPA 2018 which relates to statutory and government purposes.
Sources of personal data
West Lancashire CCG will generally collect/receive information when members of the public, their representatives, or members of Parliament, contact us with concerns or enquiries. In order to process a complaint West Lancashire CCG will collect the relevant information at the point of contact to enable the team to provide a sufficient response to the request.
Categories of personal data
Information relating to complaints would generally include the following categories of personal data:
- Patient’s name
- Patient’s address
- Patient’s contact number
- GP Surgery
- Patient’s NHS number
- Patient’s date of birth
- Representative details (if applicable)
- Representative address (if applicable)
- The nature of the complaint
Recipients of personal data
The recipients of personal data relating to complaints include:
- Any team within the CCG that may receive an enquiry or complaint
- Midlands and Lancashire Commissioning Support Unit who manage complaints on behalf of the CCG under contract
- Relevant providers (with the consent of the data subject) in order to fully investigate the complaint being made
Do we use any processors?
Yes – West Lancashire CCG commission Midlands and Lancashire Commissioning Support Unit to provide these services on their behalf.