In the UK, data protection is governed by the General Data Protection Regulation (GDPR) 2018, and the Data Protection Act (DPA) 2018.
This legislation, together with the Access to Health Records Act 1990, entitles individuals to access personal data such health records (or that of another individual with explicit consent/evidence of lawful authority).
A request for copies of health records is commonly known as a Subject Access Request (SAR) however, it should be remembered that all patients, alive or deceased, and irrespective of age, are entitled to a duty of confidentiality of their health records.
We therefore have stringent protocols in place to ensure we do not make a disclosure of confidential patient health records to someone who cannot verify their identity or authority to be in receipt of these records.
Whilst a SAR can be made verbally or in writing, and no specific form is required, SAR’s must be supported by valid ID for the requestor. In addition to this, a SAR made for access to another individuals health records also requires evidence of the requestors lawful authority to be in receipt of that individual’s confidential health records.
We therefore recommend that you complete the appropriate form as explained below to prevent a SAR being rejected, or incurring any delays in our ability to assist you.
Once we are in receipt of a completed SAR, which must include the appropriate ID and supporting evidence of lawful authority as necessary, we have 30 days/one calendar month to disclose the requested health records. However, if the SAR is complex, this period can be extended by up to two further months. If this should be necessary, we will contact you within the statutory timeframe to advise of this.
Please note we can only disclose health records for which we are the Data Controller (i.e. they are our health records to share); for example, we cannot disclose GP records or the health records of care and treatment you received from another healthcare provider. In those instances, you must make a SAR directly to those organisations.
We are required to process a SAR free of charge, but a reasonable fee may be applied to cover administration costs if the SAR is excessive or repetitive. We disclose the requested health records via our secure portal; once disclosed, you have 30 days to download the records and then they will be removed. If you do not download the records within this timeframe, you will need to make a new SAR.
If you would prefer to have the requested health records posted to you instead, ensure this is clearly stated in your SAR and that you have given us your full postal address; however, please note we do not post copies of radiology images as these maybe significant in volume and printing radiology images affects their quality.
