Privacy Notice – Surgery Connect Telephone System (X-on)

The Linden Medical Group

Call Recording

All inbound and outbound calls are recorded for monitoring, training, and clinical safety purposes. A message will notify you of this when you call the practice. Calls may also be recorded when we call you.

If you prefer not to be recorded, you have the right to end the call. However, under data protection law, we are not required to obtain your consent for recording.

Use of Call Recordings

– Recordings may be attached to a patient’s clinical record if relevant to care.
– Recordings are stored securely within the Surgery Connect system.
– Calls involving non-registered patients are stored securely, but not added to a medical record.

What Personal Data Is Collected?

– Audio recording of the conversation
– Telephone numbers of both parties
– Information shared during the call (e.g. name, date of birth, symptoms or concerns)
– Occasionally, sensitive data (e.g. health, ethnicity, religion) may be recorded if volunteered during the call

Payment card details are not recorded, in line with data protection regulations.

Our Legal Basis for Recording

Call recordings are processed under the following lawful bases:
– Article 6(1)(e) – necessary for a task in the public interest
– Article 9(2)(h) – for the provision of health care or treatment

We also comply with the Common Law Duty of Confidentiality, which means we will not disclose any patient information without consent unless legally required or in the public interest.

Your Rights

– You have the right to request access to your call recordings
– You may object to processing under Article 21 (please note this is not an absolute right)
– You may request corrections to inaccurate data
– Call recordings linked to clinical records are retained in line with NHS guidelines (up to 10 years after death). Other recordings are kept for 36 months.

Data Controller & DPO

– Data Controller: The Linden Medical Group
– Data Protection Officer: Paul Couldrey, PCIG Consulting Ltd – coudrey@me.com

Questions or Complaints

If you have concerns about how your data is used, you can contact the practice or raise a complaint with the Information Commissioner’s Office:

– Website: www.ico.org.uk
– Tel: 0303 123 1113