Retention Policy

ABOUT THIS POLICY
1. This is the Retention Policy of GP Care Now Limited. In this document, “we”, “our”, or “us” refer to GP Care Now Limited.
2. We are required to retain certain records for our operational and administrative purposes and to demonstrate compliance with our statutory or regulatory requirements. Some records may be automatically destroyed after a specified period. Other records, because of their nature, will be reviewed at intervals.
SCOPE OF POLICY
1. This Policy covers all data that we hold or have control over. This includes both physical data and electronic data such as documents, patient information and correspondence with other health care providers or patient notes. This Policy applies to both personal data including special category data and non-personal data. In this Policy, we refer to this information and these records collectively as "data".
GUIDING PRINCIPLES
1. Through this Policy, and our data retention practices, we aim to meet the following commitments:
  1. we will comply with legal and regulatory requirements to retain data.
  2. we will comply with our data protection obligations, in particular to keep personal data no longer than is necessary for the purposes for which it is processed (storage limitation principle).
  3. we will handle, store and dispose of data responsibly and securely.
  4. we will create and retain data where we need to, in order to provide our patients with medical care and advice, but we do not create or retain data without good business reason.
  5. we will allocate appropriate resources, roles and responsibilities to data retention.
  6. we will regularly monitor and audit compliance with this Policy and update this Policy when required.
OUR RESPONSIBILITIES
1. We are responsible for identifying the data that we must or should retain, and determining, the proper period of retention. We are also responsible for the proper storage and retrieval of data and for destroying or deleting the data where applicable at the end of the relevant retention period.
2. We are responsible for ensuring that a medical record is maintained in relation to each patient, which includes details of all treatment provided, details of medical history and a record of all other notes prepared by health care professionals.
STORAGE OF MEDICAL RECORDS
1. We will ensure that:
  1. the medical records of our patients are kept in a secure place in our establishment; and
  2. the medical records of our previous patients are stored securely and can be located if required.

RETENTION PERIODS

Generally, the following periods of retention apply to the data we hold:

Type of patient	Minimum period of retention
Patient who was under the age of 17 at the date on which the treatment to which the records refer was concluded.	Until the patient’s 25th birthday.
Patient who was aged 17 at the date on which the treatment to which the records refer was concluded.	Until the patient’s 26th birthday.
Patient who died before attaining the age of 18.	A period of 8 years beginning on the date of the patient’s death.
Patient who was treated for a mental disorder during the period to which the records refer.	A period of 20 years beginning on the date of the last entry in the record.
Patient who was treated for a mental disorder during the period to which the records refer and who dies whilst receiving that treatment.	A period of 8 years beginning on the date of the patient’s death.
Patient whose records relate to treatment by a general practitioner.	A period of 10 years beginning on the date of the last entry.
Patient who has received an organ transplant.	A period of 11 years beginning on the date of the patient’s death or discharge whichever is the earlier.
All other cases.	A period of 8 years beginning on the date of the last entry in the record.

Records maintained for inspection
1. We are required to maintain a record of the information set out in this Policy at clauses 7.2 to 7.5 inclusive and we will ensure that they are:
  1. kept up to date;
  2. at all times available for inspection in our establishment by any person authorised by the National Care Standards Commission to enter and inspect our establishment; and
  3. retained for a period of not less than three years beginning on the date of the last entry.
2. A register of patients which includes:
  1. the name, address, telephone number and date of birth
  2. the name, address and telephone number of the patient’s next of kin or any person authorised by the patient to act on his, hers or their behalf;
  3. the name, address and telephone number of the patient’s general practitioner;
  4. the name and address of any body which arranged the patient’s treatment;
  5. the date on which the patient first received treatment;
  6. the nature of the treatment which the patient received;
  7. if the patient has been transferred to a hospital (including a health service hospital), the date of the transfer, the reasons for it and the name of the hospital to which the patient was transferred;
  8. if the patient dies whilst in an establishment or during treatment provided for the purposes of an establishment or agency, the date, time and cause of his death.
3. A register of all surgical operations performed in our establishment
4. A register of any of the following events:
  1. the death of a patient;
  2. any serious injury to a patient;
  3. any outbreak of any infectious disease;
  4. any allegation of misconduct resulting in actual or potential harm to a patient by us.
EXPIRY OF THE RETENTION PERIOD
1. At the expiry of the relevant retention period of a record, we will either:
  1. destroy or delete the record;
  2. retain the record (and we will document our justification for doing so); or
  3. permanently preserve the record.
2. In deciding how to proceed, we will consider whether we have a justifiable reason for extending the retention period, which may include (but shall not be limited to) any of the following:
  1. Ongoing use. We may need to keep the record longer than the minimum period for care, legal or audit reasons.
  2. Classification of diseases. We may need to keep the record for longer than the minimum period if the record relates to a specific health condition which requires a longer period of retention.
  3. Operational delivery. We may need to keep the record for longer than the minimum period for the benefit of medical innovation that may justify a longer retention period or long term preservation.
  4. The way care is delivered. The records may be reflective of health or care policy at the time.
  5. Recall. If it is likely that we will need to recall the record due to ongoing use.
WHERE TO GO FOR ADVICE AND QUESTIONS
1. If you have any questions about this Policy, please contact: 0333 772 0722 or reception@gpcarenow.com