Overview

The Community Mental Health Transformation Programme (CMHTP) and the Surrey Heartlands GP Integrated Mental Health Service (GPimhs) and Frimley Mental Health Integrated Care Service (MHICS) are designed to deliver support closer to communities by providing services focussed on Primary Care Network (PCN) populations, building on community assets and involving voluntary sector, housing & social care partners.

The model will improve access to NICE-recommended interventions where required with increased and easy access in and out of highly specialised psychological therapies for people with Serious Mental Illness and those with complex mental health difficulties associated with traits of or a diagnosis of personality disorder.

The patient groups within the scope of the joint processing and sharing arrangements are:

• Service users in primary care with unmet needs:
  • Not meeting secondary care Community and Mental Health Recovery Services (CMHRS) and Improving Access to Psychological Therapies (IAPT) criteria, or where patients are not appropriate for IAPT
  • Difficulty accessing the right services
  • Utilise services in potentially chaotic patterns; physical health concerns, medication dependence, substance misuse, co-morbid physical long-term conditions contributing to poor mental health
  • ‘Held’ by GPs as frequent attenders, absorbing excessive non-medical short-term prop-up interventions;
• People in secondary care mental health services that can alternatively receive recovery focused services in primary care:
  • Seamless step-up and step-down as required
  • With potential shared care arrangements for medication. These typically comprise stable psychotic and mood disorders, and emotionally unstable personality disorder; and
• Physical health of SMI patients in primary care:
  • Supporting primary care to improve their delivery of physical health checks and facilitating bridging to evidence based interventions for people on the SMI registers

This service is delivered within your GP Practice in conjunction the Surrey and Borders Partnership NHS Trust (SABP).

The GPimhs / MHICS clinicians that are responsible for providing treatment will have access to your GP record and SABP record (if you have one) in order to provide the best care to you.

Your GP Practice and SABP act as Joint Controllers in order to deliver this service to you and have an agreement between each other to outline the roles and responsibilities of the parties and to document your ability to exercise your rights.

The GPimhs / MHICS service is provide to you under SABP CQC registration and SABP is the lead data controller.

Why do we collect information about you?

It is so we can provide you with the best possible care. But to do this, we need to keep and update your electronic records and the care we provide for you.

How do we keep your records?

Your interaction with the GPimhs / MHICS service will be managed by SABP electronically, with the outcome being sent to your GP for recording on their GP clinical system.

Who can see and update my records?

Only the people who are helping and supporting you as part of the GPimhs / MHICS service will see or update your records.

We are all trained to make sure your records are updated accurately, and all take our legal duty seriously to maintain your privacy and confidentiality.

As part of this service and with your agreement, you may be referred to a voluntary sector organisation who have been selected to provide specialist advice. You will be part of the decision-making process to identify if one of these voluntary sector organisations will be involved in your care.

These specially selected organisations are:

• Andover Mind
• Mary Frances Trust
• Catalyst
• Richmond Fellowship

Remember, we will only share what is needed for your care.

Under the law, there may be times when we must share information without informing you, such as:

• If there is a concern you are putting yourself, or another person (or child) at risk of serious harm
• Where we have been instructed to do so by the Court or part of the investigation of a serious crime
• If you are subject to the Mental Health Act (1983), there are cases where your ‘nearest relative’ must receive information, even if you object

How do you know your privacy will be kept?

Both Surrey and Borders Partnership NHS Foundation Trust and the GP Practice have a public duty under law to care for the people who use services and their personal health data.

• We work strictly within the rules set out by data protection legislation and the common law duty of confidentiality and guidance created by the NHS, such as the NHS Caldicott Principles and the Data Security and Protection Toolkit
• We will not share or sell your health records for marketing purposes or share them with third parties.
• SABP and The GP practices we work with are accredited

Why do we need to keep your records?

We have health records so we (and you) can see what is happening as part of your health and care support. Your records also help us to:

• Check and monitor the quality of the care we are providing you
• Keep your GP informed about the care we are providing
• If we do make an error, your records will show where we went wrong so we can learn from it

What is the legal basis for processing personal data?

The legal basis for the processing of personal data is that the NHS is an official authority with a public duty to care for its patients. Both SABP and the GP Practice process your health data for medical diagnosis and healthcare management purposes.

In law, this translates to relying on Articles 6(1)(e) and e 9(2)(h) of GDPR.

So, what are in your records?

The record of your involvement with the CMHTP has been designed to include only the minimum information necessary in order to provide you with the best care. This is:

• Your name, address, gender, ethnicity and language spoken
• Your NHS Number
• Your contact details
• Your contact preferences
• Relevant diagnosis and medication
• Opinion of your GP about how this service could support you

For each consultation with the service, a consultation form will be completed, recording:

• The type of consultation
• Any concerns the mental health practitioner may have
• Outcomes decided

Consultation documents will then be uploaded to your GPs system and made available to the GP.

How long will we keep your records?

SABP and your GP will keep records of your involvement with the GPimhs / MHICS service in line with the NHS Records Management Code of Practice 2016. This means it will be kept for as long as your GP record is held.

What are my rights about the data you hold on me?

You have a right to see all the records both SABP and your GP Practice hold about you, unless:

• It has been provided by someone else and we do not have their permission to share it
• It relates to criminal offences, or the detection/prevention of crime
• It could cause harm (physical or mental harm) to you or someone else

Under current data protection legislation, you have the following rights regarding
your data:

• The right to be informed,
• The right of access,
• The right to rectification
• The right to restrict processing, and
• The right to object

In order to provide this service, SABP and your GP Practice have signed an agreement which sets out the roles and responsibilities of each organisation. You have the right under data protection law to exercise your rights against both organisations, and this agreement sets out that each organisation is responsible for managing these rights for the personal data they hold about you.

If you wish to exercise your rights with SABP, please contact: Records.Team@sabp.nhs.uk

The Data Protection Officer for SABP can be contacted at: dpo@sabp.nhs.uk

For further details about your data rights, or if you wish to make a complaint, you can contact the Information Commission’s Office at www.ico.org.uk, or write to them at:

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