Privacy Policy

CLPCN Policy

Introduction

Central Liverpool Primary Care Network (CLPCN) is committed to being transparent about how we handle your personal data to protect your privacy and security. We ensure to meet data protection obligations under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

The purpose of this Privacy Notice is to make you aware of how and why we will collect and use your personal information.

Who Are We?

CLPCN is a group of 6 GP practices working with other health and care providers to improve health and wellbeing and address health inequalities in central Liverpool. We operate under the Network Contract Directed Enhanced Service (DES), which outlines our entitlements and requirements. This includes delivering a range of services, such as enhanced support for care homes, social prescribing, and first contact physiotherapy.

Our 6 Member Practices

• Abercromby Family Practice, Grove Street L7 7HG

• Albion Surgery, 45 Everton Road, L6 2EH

• Dingle Park Practice, Park Street L8 6QP

• The Elms Medical Centre, 3 The Elms L8 3SS

• St James Health Centre, 29 Great George Square, L1 5DZ

• Vauxhall Health Centre, Limekiln Lane L5 8XR

The CLPCN Hub is at 81 London Road, Liverpool L3 8JA. This is the main site for Central Liverpool Primary Care Network, serving as the administrative centre and base for many of our services, including the Women’s Health Hub and GP Enhanced Access Services.

The PCN can be contacted at:

The CLPCN is a Data Controller and, as such, is registered with the Information Commissioner’s Office. Its registration number is ZB620661.

The PCN’s Data Protection Officer (DPO) is:

Why Does The PCN Need Your Information?

CLPCN keep records about your health and treatment to ensure the care you receive is effective, of good quality and meets your needs.  The PCN needs information about you to maintain a care record that enables its staff to identify and contact you easily, and to ensure appropriate services are offered to you. Your information is used to help deliver care services to you, including, where appropriate, sharing it with external organisations so that the care services are integrated.

Information will also be used to contribute to the management of the PCN, which means your information will be used to ensure the PCN is paid for the services it provides or is held accountable for the quality of its services.

Whilst the PCN receives information from you when you come into contact with it, it also receives information about you from other individuals or organisations, such as your GP Practice, hospitals, or community services, when you receive treatment from them. Providing the PCN with enough information helps make sure you receive the right healthcare services.

Looking After Your Information

CLPCN has put in place measures to protect the security of your personal information. It has internal policies, procedures, and controls in place to prevent your personal information from being accidentally lost or destroyed, altered, disclosed, used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, other workers, contractors and other third parties who have a business need to know in order to perform their duties and responsibilities. Everyone working for the NHS has a contractual and legal duty to protect your information.

Personal information is held in accordance with the requirements of current Data Protection Legislation. Anyone who receives information from us is also under a legal duty to keep it confidential and secure in accordance with Data Protection Legislation.

CLPCN also have in place procedures to deal with any suspected data security breaches, and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.

What Types Of Personal Information Do We Collect About You?

There are two types of data that the CLPCN uses: personal data and special category data.

Personal data means:

• any information relating to the identification of a person, either directly (e.g. by name or picture) or indirectly (e.g. by age, gender, and postcode)

Special category data means:

• Data concerning physical or mental health (e.g. details about your appointments or diagnosis)

• Data revealing racial or ethnic origin

• Data concerning a person’s sex life

• Data concerning a person’s sexual orientation

• Genetic data (e.g. details about a DNA sample taken from you as part of a genetic clinical service)

• Data revealing religious or philosophical beliefs

• Data relating to criminal or suspected criminal offences

The PCN keeps data on you relating to:

Who you are; where you live; what you do; your family; your emergency contacts; possibly your friends; your employers; your habits; organisations involved in your care; your symptoms; problems and diagnoses; the reasons you seek help; your appointments; where, when and by whom you are seen; referrals to other health and social care providers; tests carried out both by the PCN, your GP Practice, and in other places; investigations and scans; treatments and outcomes of treatments; your medical treatment history; the observations and opinions of other healthcare workers, within and outside the NHS; comments and reminders reasonably made by health and social care professionals in the PCN (who are appropriately involved in your health care).

The PCN will maintain a record of your care that consists of things such as:

Any contacts you have with staff (i.e. visits and appointments); notes or a summary of discussions; treatment/care plans and results of any tests; results of investigations (e.g. laboratory tests, x-rays, etc.); relevant information provided from other professionals; relatives or those who know or care for you; and
information on medicines, side effects and allergies.

Your information will primarily be held electronically.

When registering, all patients who receive NHS care are logged on a national database; this database was previously held by NHS England (a national organisation which had legal responsibilities to collect NHS data), but, under the health reforms and NHS Modernisation Bill (aka the Health Bill), patient data is now primarily housed on the NHS Spine via the Personal Demographics Service (PDS), which remains under the management and statutory control of the National Health Service. All collected data from NHS England is currently being aggregated into a new Single Patient Record system; these records remain secure and under NHS ownership, even when accessed through platforms managed by external tech providers - however you have the option to complete the National Data Opt-Out form online via this link.

Some of the PCN’s databases connect to the national database to ensure your details remain up to date. This means if you change your address with the PCN, the new address will be automatically uploaded to the national database and will be available to other health and social care providers involved in your care. The PCN also uses other databases that it is responsible for, either directly or through legal contracts with suppliers. Please note: in some instances, some records may be held in paper format; these are stored securely and, may be transferred to electronic format at some point.

What Is The Purpose Of Processing Data?

The CLPCN processes your data to:

• Provide the appropriate services to you (e.g. Women’s Health or ADHD)

• Review its standards of care to ensure they are safe and effective

• Teach or train healthcare professionals

• Review your suitability for and/or carry out audits and research

• Undertake service evaluations

• Participate in national health screening programmes to ensure only those who should be called for screening are called, and those at highest risk are prioritised

• Ensure security and safety (e.g. for the prevention and detection of fraud and other serious crimes, assisting in the prevention and control of diseases, or recording images on CCTV cameras)

• Manage complaints, concerns, legal claims and incidents

• Make sure the PCN is paid for the services that it provides

Lawful Basis For Processing

CLPCN needs your personal, sensitive, and confidential data to provide you with healthcare services. Therefore, under current Data Protection Legislation (the Data Protection Act 2018) and the UK General Data Protection Regulation (UK GDPR), the processing of your personal data is necessary under:

• UK GDPR Article 6(1)(e) “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”

Where we process special categories of sensitive information relating to your physical and/or mental health, racial or ethnic origin, etc, we do so under:

• UK GDPR Article 9(2)(h) “processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services….”

The PCN has an obligation to protect the health of the general public and where this is done your personal data will be processed under:

• UK GDPR Article 6(1)(e) “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.”

Where we process special categories of sensitive information relating to protecting the health of the general public, we do so under:

• UK GDPR Article 9(2)(i) “processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Domestic Law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy.”

As a healthcare provider, there are occasions where we need to process personal and/or special category data because someone is at risk of serious harm (e.g. life or death situations in emergencies or major incidents) and, where we do this, we will process the information under:

• UK GDPR Article 6(1)(d) “processing is necessary in order to protect the vital interests of the data subject or of another natural person.”

• UK GDPR Article 9(2)(c) “processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.”

Sometimes there are occasions when we are obliged to process information to comply with: a court order, coroner’s instruction, to prevent or detect crime, or to comply with the law (e.g. to provide the Secretary of State with information and reports on the status, activity, and performance of the practice). If we must do this with your information, we will ensure there is a legal justification for such processing, for example under:

• UK GDPR Article 6(1)(c) “processing is necessary for compliance with a legal obligation to which the controller is subject.”

• UK GDPR Article 9(2)(f) “processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”

Meeting the Duty of Confidentiality

Consent is not required when recording information about individual patients. CLPCN has a professional requirement to keep clear, accurate, and legible records, as set out by registered bodies.

Implied consent

Relevant information is shared to ensure that patients receive safe and effective care. Consent can be implied when sharing relevant information with those who are directly involved in providing care to a patient unless they have indicated an objection. This is because it is reasonable to assume that a patient would consent if asked, and that a patient would expect relevant information to be shared with those caring for them on a need-to-know basis.

If we process your information for other purposes that are not described above, then we will seek your consent to do so before we process it.

Data Processing And Sharing

CLPCN shares information with a range of organisations or individuals for a variety of lawful purposes; this may include:

• Your GP Practice

• Other healthcare professionals (e.g. hospitals, community services, ambulance services, etc.)

• Partner organisations who contribute to your long-term care (e.g. NHS organisations, Integrated Care Systems, social services/local authorities, education, etc.)

• Private, Voluntary Sector and/or Charity Providers who contribute to your care

• Parents, carers or guardians with parental responsibilities or legal responsibilities

• NHS managers and the Department of Health & Social Care for the purposes of planning, commissioning, managing, and auditing healthcare services

• Organisations that are contracted to provide services to or on behalf of the PCN

• Community pharmacists who will provide patients with their medication following discharge from hospital

• Bodies with statutory investigative powers (e.g. NHS Resolution, the Care Quality Commission, General Medical Council, Nursing and Midwifery Council, Audit Commission or the Parliamentary and Health Service Ombudsman)

• Government departments for national screening programmes and other national initiatives (e.g. NHS England, UK Health Security Agency, or the Home Office)

• Police and other emergency services, out-of-hours services, courts (including coroner's court), solicitors and tribunals and national inquiries

Patient information will only be shared if it is for the provision of your care or required for our statutory function and legal obligations.

The PCN is involved in integrated care programmes working with other NHS, Local Authority, private, voluntary and charity organisations. Information about you may be shared with partners in these programmes, where permitted, and for direct care.

Any disclosures will be considered on a case-by-case basis to determine whether they are appropriate and what legal basis there is for sharing. If the sharing goes ahead, only the minimum personal data necessary for the specific purposes and circumstances will be shared, with all suitable security controls in place. Any organisations receiving person-identifiable information from us are legally obligated to protect it.

The PCN will not share your information for marketing, social media, or insurance purposes unless it has your consent to do so. If you do consent to this, you have the right to withdraw your consent to the processing at any time.

Information provided under the Freedom of Information Act 2000 will not include person-identifiable details about patients.

GP Connect Service

We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patient care, leading to improvements in both care and outcomes. GP Connect is not used for any purpose other than direct care.

Authorised Clinicians such as: GPs, NHS 111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts (Hospitals), and Social Care Clinicians can access the GP records of the patients they are treating via a secure NHS (previously NHS Digital) service called GP Connect.

The NHS 111 service (and other services determined locally, for example other GP practices in a Primary Care Network) will be able to book appointments for patients at GP practices and other local services.

National Care Records Services

National Care Records Service (NCRS) replaced the Summary Care Record (SCR) during 2023. NCRS is a service that allows health and social care professionals to access and update a range of patient and safeguarding information across regional Integrated Care Service (ICS) boundaries.

NCRS enables healthcare professionals, in any health or care setting, to access a summary of health and care information to support patients' direct care.

Risk Stratification

Risk stratification is a process that we use in the PCN to assist in identifying and caring for patients with long-term health conditions (e.g. cancer, chronic obstructive pulmonary disease (COPD), diabetes, etc.) and patients who are at high risk of emergency hospital admission.

The PCN may perform in-house risk stratification using various systems to analyse data and produce risk scores. These risk scores are available to authorised PCN staff who are responsible for providing direct care for you. This will help the PCN make better decisions about your future care; for example, we may invite you in for a review, or if we think you may benefit from a referral to a new service, we will discuss this with you.

Your information is also shared with NHS Cheshire and Merseyside ICB (the Integrated Care Board for the region), who can undertake some risk stratification on behalf of the PCN.

Information is also shared with NHS Cheshire and Merseyside for the following:

• Shared Care Record (ShCR)

• Direct Patient Care

• Data into Action (previously known as Combined Intelligence for Population Health (CIPHA))

• Secure Data Environment (SDE) (for research purposes)

• Invoice Validation

For further information, please see NHS Cheshire and Merseyside’s Privacy Notice and Privacy Notices: Digital and Data Programm​e.

Safeguarding

Some members of society are recognised as needing protection, for example children and vulnerable adults. If a person is identified as being 'at-risk-from-harm', CLPCN staff members are expected, as professionals, to do what they can to protect them. In addition, they are bound by specific laws that exist to protect said individuals. This practice is referred to as “Safeguarding.”

Where there is a suspected or actual safeguarding issue, the PCN will share relevant information that it holds with other relevant agencies, regardless of whether or not the individual or their representative agrees. The laws that allow this processing to be undertaken without consent are the Children Act 1989 (Section 47) and the Care Act 2014 (Section 45).

Research

Research in the NHS is essential in helping to improve the health and wellbeing of the population and is included within the NHS Constitution. There is also evidence to suggest that when healthcare organisations engage in research, it is likely to have a positive impact on their performance and patient outcomes. As such, the CLPCN is dedicated to supporting clinical research.

PCN staff may view care records in order to be able to offer new research opportunities to patients and carers, to better support the development of treatments and improve the way the PCN delivers healthcare.

The PCN only participates in research where there is an agreed, clearly defined reason for the research and that it is likely to benefit healthcare and patients alike. Such proposals will normally have a consent process, ethics committee approval, and will be in line with the principles of Article 89(1) of UK GDPR.

Identifiable data will be shared with researchers under:

• UK GDPR Article 6(1)(e) “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.”

• UK GDPR Article 9(2)(j) “processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes…”

Where identifiable patient information is used for research, the common law duty of confidentiality is normally met by explicit consent; however, where the law allows, this may be without consent (e.g. under Section 251 support, Control of Patient Information Notice (COPI), etc.)

For further information, please see: Health Research Authority's Patient Data and Research Leaflet

Communicating With You

By providing the CLPCN with your contact details, we will communicate with you about your healthcare. This could be in a variety of ways, including:

• Post

• Telephone (landline or mobile number)

• Text Message (mobile number)

• Secure Email

• Approved Patient Website / Apps (i.e. the NHS App)

You are responsible for ensuring you provide the PCN with correct contact details. You must inform the PCN of any changes. This will ensure you don’t miss any information.

You may inform the PCN of your preferred communication methods and specify any means by which you do not wish to be contacted, such as text messages. Your preferences will be recorded, ensuring that PCN staff are aware of how you prefer to be reached. You can change your preferences at any time by notifying the PCN.

Closed Circuit TV (aka CCTV)

CLPCN has installed and uses Closed Circuit TV (CCTV) within its premises to help reduce the fear of crime for patients, staff, and visitors to our site(s) and to protect our premises and assets from criminal activity. In addition, CCTV may be used to monitor difficult-to-observe areas where patient or public safety could be compromised. If an incident occurs, the CCTV footage may be shared with the police for the purposes of investigating a crime. The PCN ensures that the use of CCTV complies with all relevant regulatory acts of law.

CLPCN, typically, retains CCTV recordings for a period of 30 days.

The CLPCN is located within premises which are not owned by the PCN. The premises are managed by 'Re:volve Property Services Ltd'. CCTV is installed within the building and located within areas of the building used by the CLPCN; however, the PCN is not the data controller for the CCTV. Any queries in relation to the CCTV or for subject access requests involving CCTV, please contact Re:volve Property Services Ltd, No: 2, 50A Alderley Road, Wilmslow SK9 1NT.

Transferring Outside Of The UK

The CLPCN does not routinely transfer information outside of the UK; however, if there is a need to do so, it will be done in a way that ensures the security of the information is to an equivalent standard as that used internally by the PCN when processing your information.

Use Of Third-Party Companies

When we use a third-party service provider to process data on our behalf, we will always have an appropriate agreement in place to ensure that they keep the data secure, that they do not use or share information other than in accordance with our instructions, and that they are operating appropriately. Examples of functions that may be carried out by third parties include, but are not limited to:

• companies that provide IT services and support, including our core clinical system

• systems which manage patient-facing services such as our website

• systems which facilitate appointment bookings or electronic prescription services

• document management services

Automated Decision Making (Use Of AI Systems)

CLPCN does not use AI for patient care or carry out any "automated decision-making" where AI solely decides what care or treatment a person should receive. Healthcare professionals will always make the final decision. The PCN may use instances of AI that use automated decision-making to improve efficiency, which do not use personal data.

Your Rights

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

1. To be informed why, where and how we use your information
This is detailed in this Privacy Notice.

2. To ask for access to your information
You have a legal right to access the personal information held about you by the PCN. You can obtain this information at any time by making a Subject Access Request. The PCN has one calendar month to provide the information to you. However, you do not have the right to access information that:

• has been provided in confidence by someone else without consenting for you to see it

• relates to serious criminal offences

• could cause physical or mental harm to you or someone else

Parents/carers/legal guardians can make a request with respect to their child’s data where the child is not considered mature enough to understand their rights over their own data (usually under the age of 12), or where the child has provided consent.

Anyone requesting access to records will be asked to provide copies of identification documents to verify the lawfulness of their request.

To request access to records the PCN holds, please contact the PCN by emailing CLPCN.Admin@livgp.nhs.uk

Another way to access your records is through the NHS App (or other approved patient-facing services apps). For further information on this, please visit: Access to patient records through the NHS App

3. To ask for your information to be corrected if it is inaccurate or incomplete
You have the right to have any inaccuracies in the data we hold about you corrected. However, if the data we hold is accurate, but you disagree with it, you should note that there is no right to have accurate medical records deleted except when ordered by a court of law.

For further information about correcting inaccuracies, please see the guidance on Requesting Amendments to Health and Social Care Records or contact the PCN by emailing CLPCN.Admin@livgp.nhs.uk

4. To ask for your information to be deleted or removed where there is no need for us to continue processing it
You have the right to ask for your information to be removed, but if we require this information to provide you with appropriate medical services and diagnoses for your healthcare, then removal may not be possible. Please contact the PCN to discuss this further.

5. To ask us to restrict the use of your information
You have the right to ask the PCN to restrict information processing.

6. To ask us to copy or transfer your information from one IT system to another safely and securely, without impacting the quality of the information
You have the right to request your information be transferred to another organisation. Please contact the PCN to discuss further.

7. To object to how your information is used
Staff who have access to your information will only have access to that which they need to fulfil their roles. You have the right to object to the PCN sharing your data in these circumstances, but the PCN has an overriding responsibility to do what is in your best interests and could still share the information even if you have objected. This will only be done with a valid legal justification.

You have the right to object to some or all of your information being processed. However, please note that this is a right to raise an objection, which is different from having an absolute right to have your wishes granted in every circumstance. In certain circumstances, the PCN will need to continue to process your information in order to provide you with the care you need.

 8. To challenge any decisions made without human intervention (automated decision making)
See Automated Decision Making section above.

National Data Opt-Out

Whenever you use a health or care service, such as attending Accident & Emergency or using Community Services, important information about you is collected in a patient record for that service. Collecting this information helps to ensure you get the best possible care and treatment.

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

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your identifiable confidential patient information isn’t needed.

You have a choice about whether you want your confidential patient 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 patient information will still be used to support your individual care.

To find out more or to register your choice to opt out, please visit the NHS's 'data matters' page

You can also find out more about how patient information is used by visiting:

The NHS's General Practice Data for Planning and Research (GPDPR)

Understanding Patient Data's page 'introducing patient data' (which covers how and why patient information is used, the safeguards, and how decisions are made)

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.

CLPCN has systems and processes in place to be compliant with the national data opt-out service, and apply your choice to any confidential patient information we use or share for purposes beyond your individual care. CLPCN is compliant with the national data opt-out policy.

You can also opt out of some of the national screening programmes; for further information, please visit this link.

Type 1 Opt Out

The data held in your GP medical records is shared with other healthcare professionals for your individual care. It is also shared with other organisations to support health and care planning and research.

If you do not want your personally identifiable patient data to be shared outside of the GP Practice for purposes except your own care, you can register an opt-out with your GP Practice. This is known as a Type 1 Opt-out. You can contact your GP Practice to:

• Register a Type 1 Opt-out, for yourself or for a dependent (if you are the parent or legal guardian of the patient)

• Withdraw an existing Type 1 Opt-out, for yourself or a dependent (if you are the parent or legal guardian of the patient) if you have changed your preference and would like to opt-in

How Long Do We Retain Your Records?

All our records are retained and destroyed in line with the NHS Records Management Code of Practice, which sets out the appropriate length of time each NHS record is held for. We do not keep your records for longer than necessary.

All records are destroyed confidentially once their retention period has been met and the CLPCN has made the decision that the records are no longer required.

Website Policy

Website Privacy Policy Information

Central Liverpool Primary Care Network (CLPCN) is responsible for the management of this website and take the privacy of information provided by visitors to this website extremely seriously.

We do not capture or store personal information about individuals who browse this website, except where this information is given voluntarily, such as through our online forms. We do however collect statistical information, such as the number of visits to the website, which is not personally identifiable.

If you are using CLPCN LARC self-referral form, please see LARC Privacy Notice (PDF) for more details.

What Do We Do With The Information We Collect?

Where you choose to complete any of our online forms, the personal information you give us is used only by CLPCN to enable us respond to any request, suggestion or comment that you have made.

CLPCN will endeavour to safeguard your information and will not pass it on to any third party without the express permission of the individual or unless required to do so by lawful authority.

How Do We Use The Information We Collect To Improve Our Website?

CLPCN may collect and store the following information each time you visit our site: the date and time, the originating IP, the type of browser and operating system used, the URL of the referring page, the object requested, and the completion status of the request.

Visitors to our public website remain anonymous as none of the data collected is linked to any personal information. The information allows us to assess the popularity of the pages on the website, so that we can continue to improve our site and access to information.

Cookies

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.

These pieces of information are used to improve services for you through, for example:

• Enabling a service to recognise your device so you don't have to give the same information several times during one task.
• Recognising that you may already have given a username and password, so you don't need to do it for every web page requested.
• Measuring how many people are using services, so they can be made easier to use and there's enough capacity to ensure they are fast.

You can manage these small files yourself and learn more about them through Internet browser cookies - what they are and how to manage them.

For further information, please see www.clpcn.co.uk/cookies

Notification Of Changes

Notification Of Changes - Privacy Policy

Central Liverpool Primary Care Network (CLPCN) reserves the right to update or amend this Privacy Policy at any time, including where CLPCN intends to further process your personal information for a purpose other than that for which the personal information was collected or where we intend to process new types of personal information. We will update this Privacy Policy when we make significant additions or amendments. We may also notify you about the processing of your personal information in other ways.

CLPCN may revise this Website Privacy Policy at any time. You will not receive notification of these changes; however, they will be published on this page.

Right to Complain

Users 'Right-to-Complain'

Central Liverpool Primary Network aims to make sure that the services it delivers are provided to the highest standard. If you have any concerns about the way the PCN has handled data, you can raise your concerns or make a complaint by emailing CLPCN.Admin@livgp.nhs.uk

Alternatively, you can complain to the Information Commissioner’s Office by emailing casework@ico.org.uk or phoning 0303 123 1113.

The policy information on this page was last updated: 22/07/2026