Your information, what you need to know

This privacy notice explains why we collect information about you, how that information may be used, how we keep it safe and confidential and what your rights are in relation to this.

Why we collect information about you

Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received within any NHS organisation.  These records help to provide you with the best possible healthcare and help us to protect your safety.

We collect and hold data for the purpose of providing healthcare services to our patients and running our organisation which includes monitoring the quality of care that we provide. In carrying out this role we may collect information about you which helps us respond to your queries or secure specialist services. We may keep your information in written form and/or in digital form. The records may include basic details about you, such as your name and address. They may also contain more sensitive information about your health and also information such as outcomes of needs assessments.

Details we collect about you

The health care professionals who provide you with care, maintain records about your health and any treatment or care you have received previously (e.g. from Hospitals, GP Surgeries, A&E, etc.). These records help to provide you with the best possible healthcare.

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 including COVID-19
• 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.

Records which this GP Practice may hold about you may include the following:

• Details about you, such as your address and next of kin
• Any contact the surgery has had with you, such as appointments, clinic visits, emergency appointments, etc.
• Call recordings
• Notes and reports about your health
• Details about your treatment and care
• Results of investigations, such as laboratory tests, x-rays, etc.
• Relevant information from other health professionals, relatives or those who care for you

How we keep your information confidential and safe

Everyone working for our organisation is subject to the Common Law Duty of Confidence.  Information provided in confidence will only be used for the purposes advised with consent given by the patient, unless there are other circumstances covered by the law.  The NHS Digital Code of Practice on Confidential Information applies to all NHS staff and they are required to protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.  All our staff are expected to make sure information is kept confidential and receive regular training on how to do this.

The health records we use may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure.  Your records are backed up securely in line with NHS standard procedures.  We ensure that the information we hold is kept in secure locations, is protected by appropriate security and access is restricted to authorised personnel.

We also make sure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

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

Data Protection Act 2018

• General Data Protection Regulation
• Human Rights Act
• Common Law Duty of Confidentiality
• NHS Codes of Confidentiality and Information Security
• Health and Social Care Act 2015
• And all applicable legislation

We maintain our duty of confidentiality to you at all times. We will only ever use or pass on information about you if we reasonably believe that others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (such as a risk of serious harm to yourself or others) or where the law requires information to be passed on.

How we use your information

Improvements in information technology are also making it possible for us to share data with other healthcare organisations for the purpose of providing you, your family and your community with better care.  For example it is possible for healthcare professionals in other services to access your record with your permission when the practice is closed.  This is explained further in the Local Information Sharing section below.

Under the powers of the Health and Social Care Act 2015, NHS Digital can request personal confidential data from GP Practices without seeking patient consent for a number of specific purposes, which are set out in law. These purposes are explained below.

You may choose to withdraw your consent to personal data being shared for these purposes. When we are about to participate in a new data-sharing project we will display prominent notices in the Practice and on our website at least four weeks before the scheme is due to start. Instructions will be provided to explain what you have to do to ‘opt-out’ of the new scheme. Please be aware that it may not be possible to opt out of one scheme and not others, so you may have to opt out of all the schemes if you do not wish your data to be shared.

You can object to your personal information being shared with other healthcare providers but should be aware that this may, in some instances, affect your care as important information about your health might not be available to healthcare staff in other organisations. If this limits the treatment that you can receive then the practice staff will explain this to you at the time you object.

To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS.

ACR project for patients with diabetes (and/or other conditions)

The data is being processed for the purpose of delivery of a programme, sponsored by NHS Digital, to monitor urine for indications of chronic kidney disease (CKD) which is recommended to be undertaken annually for patients at risk of chronic kidney disease e.g., patients living with diabetes. The programme enables patients to test their kidney function from home. We will share your contact details with Healthy.io to enable them to contact you and send you a test kit.  This will help identify patients at risk of kidney disease and help us agree any early interventions that can be put in place for the benefit of your care. Healthy.io will only use your data for the purposes of delivering their service to you. If you do not wish to receive a home test kit from Healthy.io we will continue to manage your care within the Practice. Healthy.io are required to hold data we send them in line with retention periods outlined in the Records Management code of Practice for Health and Social Care. Further information about this is available at: https://bit.ly/3xpSq5q.

Call Recording

We record all calls (incoming and outgoing). You are entitled to access this information should you wish to. We may use these recordings to listen back to should there be any uncertainty.

Child Health Information Services (CHIS)

South, Central and West Child Health Information Services (SCW CHIS) is commissioned by NHS England to support the monitoring of care delivered to children. Personal data is collected from the child’s GP record to enable health screening, physical examination and vaccination services to be monitored to ensure that every child has access to all relevant health interventions.

We wish to make sure that your child has the opportunity to have immunisations and health checks when they are due. We share information about childhood immunisations, the 6-8 week new baby check and breast-feeding status with NHS Oxford Health Foundation Trust health visitors and school nurses, and with NHS South Central and West Commissioning Support Unit, who provide the Child Health Information Service in Oxfordshire on behalf of NHS England.

Clinical audit

Information may be used by the CCG for clinical audit to monitor the quality of the service provided to patients with long terms conditions. Some of this information may be held centrally and used for statistical purposes (e.g. the National Diabetes Audit). When this happens, strict measures are taken to ensure that individual patients cannot be identified from the data.

Clinical Research/Patient Data

Sometimes your information may be requested to be used for research purposes – we will always ask your permission before releasing your information for this purpose.

Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your 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 www.nhs.uk/your-nhs-data-matters.

This practice is supporting vital health and care planning and research by sharing your data with NHS Digital.

For more information about this see the GP Practice Privacy Notice for General Practice Data for Planning and Research.

Direct care APIs/GP Connect

NHS Digital has been commissioned to develop and operate a series of services which support new models of care and allow health and care professionals to get the information they need to deliver the best possible care for patients. Together these services are known as the Digital Interoperability Platform, it brings together care information related to the patient at the point of care. The services support wider sharing of records along care pathways and across organisational boundaries.

The Direct Care APIs are part of the wider Digital Interoperability Platform. The GP Connect service allows GP practices and clinical staff to share GP Practice clinical information and data between IT systems, quickly and efficiently via Application Programming Interfaces (APIs). These APIs make data from clinical systems available in a standard format that can be used across different systems and be made available to clinicians who need acess to the data for direct patient care. From a privacy/data protection perspective, the service provides more secure information transfer using the APIs, removing the need to use less secure methods of information transfer, such as email or fax.

Department for Work and Pensions

Our practice is legally required to provide anonymised data on patients who have been issued with a fit note under the Fit for Work scheme. The purpose is to provide the Department for Work and Pensions with information from fit notes to improve the monitoring of public health and commissioning and quality of health services.

Healthy.io (ACR project for patients with diabetes (and/or other conditions))

The data is being processed for the purpose of delivery of a programme, sponsored by NHS Digital, to monitor urine for indications of chronic kidney disease (CKD) which is recommended to be undertaken annually for patients at risk of chronic kidney disease e.g., patients living with diabetes. The programme enables patients to test their kidney function from home. We will share your contact details with Healthy.io to enable them to contact you and send you a test kit.  This will help identify patients at risk of kidney disease and help us agree any early interventions that can be put in place for the benefit of your care. Healthy.io will only use your data for the purposes of delivering their service to you. If you do not wish to receive a home test kit from Healthy.io we will continue to manage your care within the Practice. Healthy.io are required to hold data we send them in line with retention periods outlined in the Records Management code of Practice for Health and Social Care. Further information about this is available at: Self-test for kidney disease at home.

IGPR Data Processor

We use a processor, iGPR Technologies Limited (“iGPR”), to assist us with responding to report requests relating to your patient data, such as subject access requests that you submit to us (or that someone acting on your behalf submits to us) and report requests that insurers submit to us under the Access to Medical Records Act 1988 in relation to a life insurance policy that you hold or that you are applying for.

iGPR manages the reporting process for us by reviewing and responding to requests in accordance with our instructions and all applicable laws, including UK data protection laws. The instructions we issue to iGPR include general instructions on responding to requests and specific instructions on issues that will require further consultation with the GP responsible for your care

Improving Diabetes Care

Information that does not identify individual patients is used to enable focussed discussions to take place at practice-led local diabetes review meetings between health care professionals. This enables the professionals to improve the management and support of these patients.

Individual Funding Request

An ‘Individual Funding Request’ is a request made on your behalf, with your consent, by a clinician, for funding of specialised healthcare which falls outside the range of services and treatments that CCG has agreed to commission for the local population. An Individual Funding Request is taken under consideration when a case can be set out by a patient’s clinician that there are exceptional clinical circumstances which make the patient’s case different from other patients with the same condition who are at the same stage of their disease, or when the request is for a treatment that is regarded as new or experimental and where there are no other similar patients who would benefit from this treatment. A detailed response, including the criteria considered in arriving at the decision, will be provided to the patient’s clinician.

Invoice Validation

Invoice validation is an important process. It involves using your NHS number to check which CCG is responsible for paying for your treatment. Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for invoice validation purposes. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

Local Information Sharing

Your GP electronic patient record is held securely and confidentially on an electronic system managed by your registered GP practice. If you require attention from a local health or care professional outside of your usual practice services, such as in an Evening and Weekend GP Access Clinic, GP Federation Service, Emergency Department, Minor Injury Unit or Out Of Hours service, the professionals treating you are better able to give you safe and effective care if some of the information from your GP record is available to them.

Where available, this information can be shared electronically with other local healthcare providers via a secure system designed for this purpose. Depending on the service you are using and your health needs, this may involve the healthcare professional accessing a secure system that enables them to view parts of your GP electronic patient record (e.g. Oxfordshire Care Summary or your Summary Care Record) or a secure system that enables them to view your full GP electronic patient record (e.g. EMIS remote consulting system).

In all cases, your information is only accessed and used by authorised staff who are involved in providing or supporting your direct care. Your permission will be asked before the information is accessed, other than in exceptional circumstances (e.g. emergencies) if the healthcare professional is unable to ask you and this is deemed to be in your best interests (which will then be logged).

Local Population Health Management Thames Valley Shared Care Record

Health and social care services are developing shared systems to share data efficiently and quickly.  It is important for anyone treating you to be able to access your shared record so that they have all the information they need to care for you. This will be during your routine appointments and in urgent situations such as going to A&E, calling 111 or going to an Out Of Hours appointment.  It is also quicker for staff to access a shared record than to try to contact other staff by phone or email.

Only authorised staff can access the systems and the information they see is carefully checked so that it relates to their job.  Systems do not share all your data, just data which services have agreed is necessary to include.

For more information on the TVS Shared Care Record and HIE, you can visit their website at www.thamesvalleysurreycarerecords.net.

If you wish to opt out from this data sharing, you will need to let the practice know so they can change your record sharing settings. Please contact the surgery and ask us to record a GDPR and that you have refused to upload to local shared electronic record.

Processors: Graphnet, Cerner

Mind 

We have a partnership with MIND, who deliver a Social Prescribing service for our patients. We may share your medical records with MIND once a referral has been completed to enable them to provide better care for you.  You will be asked to consent to this sharing before this occurs. Mind have their own Privacy policy, which can be found at Privacy policy – Mind

My Care Record

Often, only health and care professionals within the same organisation can see this information. This means it can be difficult for them to work together to deliver the best care. My Care Record is an approach to improving care by joining up health and care information. Wherever possible, health and care professionals will be able to access your records from other services when it is needed for your care. This will make it easier and faster for them to make the best decisions. For example, a doctor treating you in hospital or a nurse working in the community could view the information they need from your GP record.

Several different secure computer systems are used across the region. These allow health and care professionals to digitally access your records held by other services. In some areas systems are already in place, in other areas more work is underway to invest in the technology needed.

The approach also provides an agreement between all the health and care organisations involved. This means they commit to sharing information in a secure way to help improve your care. The My Care Record approach is in line with General Data Protection Regulation (GDPR) which provides the legal basis to share information between health and care services when it is needed to deliver care.

All your information will be held securely. Certain information – that doesn’t identify you – will also be used to help improve services and plan for the future. For example, it will help us plan for the number of doctors, nurses and care workers needed to look after you in the future.

You can object to your record being shared between services. To do this, speak to the person delivering care to you at each organisation such as your GP, specialist or social worker. It is important to understand that not allowing access to your information may affect the quality of the care you receive.

In many situations it is necessary to share information between services to deliver care. However, it may be possible to request that specific or sensitive information is not made available. There may also be some situations where information still needs to be made available. For example, if there is a serious concern about an individual’s safety.

Please see the My Care Record website www.mycarerecord.org.uk for more information. Your records will include information as detailed below, but is not exclusive to:

• Name, address, NHS number and phone number
• Medical Conditions
• Treatment provided and contact the individual has had with the organisation
• Care Plans
• Emergency department treatment
• Discharge Summaries
• Medication Reviews
• Medical Reports
• Care and Support plans
• Care plans reviews – adult social care assessments
• Results of investigations, such as x-rays, scans, and laboratory tests.

Each partner organisation participating is responsible for the information they share/access within the shared environment, including personal and special category data incorporated from individual records held by partner organisations. The information that can be accessed from your record from each service or organisation will depend on the system that is used. All partners are subject to a number of legal obligations to ensure that the processing of personal information remains lawful. This includes, legislation, standard, statutory and non-statutory guidance.

National Fraud Initiative – Cabinet Office

The use of data by the Cabinet Office for data matching is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 2018. Data matching by the Cabinet Office is subject to a Code of Practice. For further information see: www.gov.uk/government/publications/code-of-data-matching-practice-for-national-fraud-initiative

National Registries

National Registries (such as the Learning Disabilities Register) have statutory permission under Section 251 of the NHS Act 2006, to collect and hold service user identifiable information without the need to seek informed consent from each individual service user.

Risk Stratification

‘Risk stratification for case finding’ is a process for identifying and managing patients who have or may be at-risk of health conditions (such as diabetes) or who are most likely to need healthcare services (such as people with frailty). Risk stratification tools used in the NHS help determine a person’s risk of suffering a particular condition and enable us to focus on preventing ill health before it develops.

Information about you is collected from a number of sources including NHS Trusts, GP Federations and your GP Practice. A risk score is then arrived at through an analysis of your de-identified information.  This can help us identify and offer you additional services to improve your health.

Risk-stratification data may also be used to improve local services and commission new services, where there is an identified need. In this area, risk stratification may be commissioned by the Oxfordshire NHS Clinical Commissioning Group (OCCG). Section 251 of the NHS Act 2006 provides a statutory legal basis to process data for risk stratification purposes. Further information about risk stratification is available from: https://www.england.nhs.uk/ourwork/tsd/ig/risk-stratification

If you do not wish information about you to be included in any risk stratification programmes, please let us know. We can add a code to your records that will stop your information from being used for this purpose. Please be aware that this may limit the ability of healthcare professionals to identify if you have or are at risk of developing certain serious health conditions.

Safeguarding

To ensure that adult and children’s safeguarding matters are managed appropriately, access to identifiable information will be shared in some limited circumstances where it’s legally required for the safety of the individuals concerned.

Summary Care Record (SCR)

The NHS in England uses a national electronic record called the Summary Care Record (SCR) to support patient care. It contains key information from your GP record. Your SCR provides authorised healthcare staff with faster, secure access to essential information about you in an emergency or when you need unplanned care, where such information would otherwise be unavailable.

Summary Care Records are there to improve the safety and quality of your care. SCR core information comprises your allergies, adverse reactions and medications. An SCR with additional information can also include reason for medication, vaccinations, significant diagnoses / problems, significant procedures, anticipatory care information and end of life care information. Additional information can only be added to your SCR with your agreement.

Please be aware that if you choose to opt-out of SCR, NHS healthcare staff caring for you outside of this surgery may not be aware of your current medications, allergies you suffer from and any bad reactions to medicines you have had, in order to treat you safely in an emergency. Your records will stay as they are now with information being shared by letter, email, fax or phone. If you wish to opt-out of having an SCR please return a completed opt-out form to the practice.

Supporting Medicines Management

Oxfordshire ICS and some Oxfordshire GP Federations operate pharmacist and prescribing advice services to support local GP practices with prescribing queries, which may require identifiable information to be shared. These pharmacists work with your usual GP to provide advice on medicines and prescribing queries, and review prescribing of medicines to ensure that it is appropriate for your needs, safe and cost-effective. Where specialist prescribing support is required, the CCG medicines management team may order medications on behalf of your GP Practice to support your care.

Supporting Locally Commissioned Services

ICSs support GP practices by auditing anonymised data to monitor locally commissioned services, measure prevalence and support data quality.  The data does not include identifiable information and is used to support patient care and ensure providers are correctly paid for the services they provide.

Suspected Cancer

Data may be analysed in cases of suspected cancer by Nuffield Department of Primary Care Health Sciences, Oxford University to facilitate the prevention, early diagnosis and management of illness.  Measures are taken to ensure the data for analysis does not identify individual patients.

Data Retention

We manage patient records in line with the Records Management NHS Code of Practice for Health and Social Care which sets the required standards of practice in the management of records for those who work within or under contract to NHS organisations in England, based on current legal requirements and professional best practice. If you transfer to another GP and we are asked to transfer your records we will do this to ensure your care is continued. Currently the NHS is required to keep GP records for 10 years after a patient has died.  Exceptions to these rules are detailed in the code of practice.

Who are our partner organisations?

We may also have to share your information, subject to strict agreements on how it will be used, with the following organisations:

• NHS Trusts
• Specialist Trusts
• GP Federations
• Independent Contractors such as dentists, opticians, pharmacists
• Private Sector Providers
• Voluntary Sector Providers
• Ambulance Trusts
• Clinical Commissioning Groups
• Social Care Services
• Local Authorities
• Education Services
• Fire and Rescue Services
• Police
• Other ‘data processors’

We will never share your information outside of health partner organisations without your explicit consent unless there are exceptional circumstances such as when the health or safety of others is at risk, where the law requires it or to carry out a statutory function.

Within the health partner organisations (NHS and Specialist Trusts) and in relation to the above mentioned themes – Risk Stratification, Invoice Validation, Supporting Medicines Management, Summary Care Record – we will assume you are happy to for your information to be shared unless you choose to opt-out (see below).

This means you will need to express an explicit wish to not have your information shared with the other organisations; otherwise it will be automatically shared. We are required by law to report certain information to the appropriate authorities. This is only provided after formal permission has been given by a qualified health professional. There are occasions when we must pass on information, such as notification of new births, where we encounter infectious diseases which may endanger the safety of others, such as meningitis or measles (but not HIV/AIDS), and where a formal court order has been issued.  Our guiding principle is that we are holding your records in strictest confidence.

Your right to withdraw consent for us to share your personal information (Opt-Out)

If you are happy for your data to be extracted and used for the purposes described in this privacy notice then you do not need to do anything.  If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. We will respect your decision if you do not wish your information to be used for any purpose other than your care but in some circumstances we may still be legally required to disclose your data.

There are several forms of opt- outs available at different levels:

Type 1 opt-out:

If you do not want personal confidential information that identifies you to be shared outside your GP practice you can register a ‘Type 1 opt-out’ with your GP practice. This prevents your personal confidential information from being used except for your direct health care needs and in particular circumstances required by law, such as a public health emergency like an outbreak of a pandemic disease. If you do not want your information to be used for any purpose beyond providing your care you can choose to opt-out. If you wish to do so, please let us know so we can code your record appropriately to stop your records from being shared outside of your GP Practice.

National data opt-out:

The national data opt-out was introduced on 25 May 2018 and replaces the previous ‘type 2’ opt-out.  NHS Digital collects information from a range of places where people receive care, such as hospitals and community services.  The new programme provides a facility for individuals to opt-out from the use of their data for research or planning purposes.  For anyone who had an existing type 2 opt-out, it will have been automatically converted to a national data opt-out from 25 May 2018 and you will receive a letter giving you more information and a leaflet explaining the new national data opt-out.

The national data opt-out choice can be viewed or changed at any time by using the online service at www.nhs.uk/your-nhs-data-matters

Website link: https://digital.nhs.uk/services/national-data-opt-out

GDPR opt out:

Where an individual does want any of their health and social care data shared for direct care. The practice would apply correct clinical coding to ensure that no leaves the practice. Please request your GP practice adds the GDPR code is added to your records to stop your records from being shared outside of your GP Practice.

Access to your information

Under the Data Protection Act 2018 everybody has the right to see, or have a copy, of data we hold that can identify you, with some exceptions.  You do not need to give a reason to see your data. Under special circumstances, some information may be withheld.  We may charge a reasonable fee for the administration of the request in certain instances (e.g. where a duplicate copy is requested).

If you wish to have a copy of the information we hold about you, please contact our reception team on 01993 702911.

Change of Details

It is important that you tell the person treating you if any of your details such as your name or address have changed or if any of your details are incorrect in order for this to be amended. Please inform us of any changes so our records for you are accurate and up to date.

Mobile telephone number

If you provide us with your mobile phone number we may use this to send you reminders about your appointments or other health screening information. Please let us know if you do not wish to receive reminders on your mobile.

Email address

Where you have provided us with your email address we will use this to send you information relating to your health and the services we provide.  If you do not wish to receive communications by email please let us know.

Data Protection Officer
Should you have any data protection questions or concerns, please contact our Data Protection Officer Kate Tregale, Regional Information Governance Lead and GP Data Protection Officer

GP-igenquiries.SCWCSU@nhs.net

lindsay.blamires@nhs.net

or Hattie Clay hattie.clay@nhs.net within the medical practice.

Notification

The Data Protection Act 2018 requires organisations to register a notification with the Information Commissioner to describe the purposes for which they process personal and sensitive information.

We are registered as a data controller and our registration can be viewed online in the public register at:  http://ico.org.uk/what_we_cover/register_of_data_controllers

Any changes to this notice will be published on our website and in a prominent area at the Practice.

Complaints

If you have concerns or are unhappy about any of our services, please contact the Practice Manager, Hattie Clay.

Email: hattie.clay@nhs.net

For independent advice about data protection, privacy and data-sharing issues, you can contact:

The Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Phone: 0303 123 1113

Website: www.ico.gov.uk

Further Information

Further information about the way in which the NHS uses personal information and your rights in that respect can be found here:

The NHS Care Record Guarantee:

The NHS Care Record Guarantee for England sets out the rules that govern how patient information is used in the NHS, what control the patient can have over this, the rights individuals have to request copies of their data and how data is protected under the Data Protection Act 2018.

http://systems.digital.nhs.uk/infogov/links/nhscrg.pdf

The NHS Constitution:

The NHS Constitution establishes the principles and values of the NHS in England. It sets out the rights patients, the public and staff are entitled to.  These rights cover how patients access health services, the quality of care you’ll receive, the treatments and programmes available to you, confidentiality, information and your right to complain if things go wrong.

https://www.gov.uk/government/publications/the-nhs-constitution-for-england

NHS Digital:

NHS Digital collects health information from the records health and social care providers keep about the care and treatment they give, to promote health or support improvements in the delivery of care services in England.

http://content.digital.nhs.uk/article/4963/What-we-collect

Reviews of and Changes to our Privacy Notice

We keep our Privacy Notice under regular review.

This notice was last reviewed in March 2023