OccWellbeing | Bringing quality occupational health expertise to your business

1. Who are we

OccWellbeing works as the in-house occupational health service to City Health Care Partnership CIC (CHCPCIC) and works alongside other local organisations, helping them to promote and maintain the health and wellbeing of their staff.

Your Occupational Health (OH) records are classed as a 'clinical record'. We have a legal and ethical duty (under relevant health professional codes of conduct) not to disclose confidential medical information to third parties, including your manager or HR, without your informed consent, unless there is a grave risk of serious harm to others or is the subject of a court order.

Data Controller

The data controller responsible for keeping your information is City Health Care Partnership CIC. We are registered with the Information Commissioner’s Office (ICO). The ICO is the UK’s independent body set up to uphold information rights. Our registration number is: Z2201882

Data Protection Officer

The Data Protection Officer is responsible for:

Informing and advising us and its employees about their obligations to comply with data protection laws.
Monitoring compliance with data protection laws.
Being the point of contact regarding data protection.
Available for advice and support with regards to the use and processing of personal data.

Our Data Protection Officer is:

Claire Attwood, Information Governance and Compliance Manager
City Health Care Partnership CIC
Business Support Centre
5 Beacon Way
Hull
HU3 4AE
Tel: 01482 347620
Email: Claire.Attwood@nhs.net

2. Why we collect your information

We collect and process your data to enable us to provide occupational health services to CHCPCIC staff and partner agencies. To enable us to meet our commitment to you in protecting and promoting your health at work, advising on the management of work-related health problems and health problems which may be affected by work including:

Ascertain your fitness to undertake work where there is an established fitness standard.
Establish baseline health records where you may be working with substances and agents which have the potential to cause disease.
Monitor your health if you continue to be exposed to workplace allergens or substances which may cause disease.
Monitor your hearing if you are exposed to noise at work in line with the Noise at Work Regulations.
Advise on the management of accidents and exposures in the course of your work.
Provide advice and support to you in the management of a work-related health problem or health problem that affects you at work.
Within the established practice of medical confidentiality provide advice to your line manager on the management of work related health problems or health problems that may affect you at work.

3. What information do we collect

Records may be written down or held electronically. Your records can include:

Demographic details, such as name, date of birth and address.
Job details, such as employment start and leaving dates, job title, service/directorate affiliation.
Information supplied by you through health questionnaires, email, telephone or face to face consultation.
Details about your occupational health assessments such as pre-employment checks, health surveillance and immunisations.
Results of investigations, such as x-rays and laboratory tests.
Relevant information from other healthcare or social care professionals who care for you.
Health / medical history including lifestyle information and social circumstances.
Information supplied by your line manager which may include information such as attendance history, medical information.
Medical information supplied by your GP/ Specialist with your consent.

4. Who do we collect data from:

You (the data subject).
Your manager.
Human Resources.
Health specialists/services that we may refer you to as part of our assessment process.
With your consent, your GP or other specialists from whom you have received treatment.

5. How is it collected:

In writing referrals / questionnaires.
Electronically via referrals / questionnaires / emails / vaccination history / blood test results.
Visually while providing clinical services to, you: skin / audiology assessments.
Verbally by way of telephone calls, online communication platforms or during face-to-face conversations.

6. Will my information be shared

We will not disclose your information to any other third parties without your permission unless there are exceptional circumstances, such as a serious crime has been committed, there is a risk to the public or staff or we have a legal duty to pass on information:

Information on your fitness to work is shared with your line manager, department safety officers and HR - with your consent.
Details of your medical conditions will be shared with others involved, or to be involved, in the provision of your healthcare – with your consent.
Details of infectious diseases which present significant risk to human health and the wider public under the Public Health (Control of Disease) Act 1984 and the Health Protection (Notification) Regulations 2010 to relevant official – where we have a legal duty.
Where a court orders us to share your information – where we have a legal duty.
When it’s required by us or others to detect, investigate or prevent serious crime - where we have a legal duty.
Assisting third parties with regulatory responsibilities such as the Care Quality Commission and Information Commissioner’s Office - where we have a legal duty.

7. How do we maintain the confidentiality of your information

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

Data Protection Act
The General Data Protection Regulations 2016
Human Rights Act 1998
Common Law Duty of Confidentiality
Health and Social Care Act 2012
Confidentiality Code of Practice 2003
Information Security Management Code of Practice 2007
Records Management Code of Practice for Health and Social Care 2016
Information: To Share or Not to Share Review
OccWellbeing staff have a legal obligation to keep information about you confidential. Staff also undertake data security training.

8. How long do we keep your information for

We store information for the time stipulated in Records Management Code of Practice 2021

Occupational health reports: Keep until 75th birthday or 6 years after the staff member leaves whichever is sooner.
Occupational health report of staff member under health surveillance, keep until 75th birthday.

9. Your rights

Data protection laws give individuals’ rights in respect of the personal information that we hold about you. These are:

To be informed why, where, and how we use your information.
To request access to your information.
To request that an amendment is attached to your OH record if you believe any of the information held by us is inaccurate or misleading.
To request for your information to be deleted or removed where there is no need for us to continue processing it.
To request us to restrict the use of your information.
To request us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information.
To object to how your information is used.
To challenge any decisions made without human intervention (automated decision making).

10. Accessing your information

You can make a request for copies of records verbally or in writing. All requests MUST be directed to the Quality Improvement and Compliance Team at the Business Support Centre or email at chcp.accesstorecords@nhs.net Tel number: 01482 347627.

11. Concerns

Should you wish to raise a concern about the use of your information, please contact the Customer Care Team at chcp.customercare@nhs.net Tel: 01482 236969.
If you remain unhappy with the outcome of your enquiry you can contact the Information Commissioner:
The Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
www.ico.org.uk

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