My Care Hub Personal Health Record (PHR) Privacy Policy

This privacy policy is for residents across the Bath and North East Somerset, Swindon and Wiltshire (BSW) Partnership.

This policy statement describes the privacy and processing arrangements for the My Care Hub PHR service commissioned by BSW ICB and provided by the BSW Integrated Care Record (ICR) solution supplier, Graphnet.

We publish this policy to ensure everyone understands how we capture, manage and use your data using My Care Hub and to explain how we use the personal information that you supply through My Care Hub.

We respect the privacy of all who use My Care Hub.

We treat all information in line with our legal responsibilities and recognise best practice standards and processes. Only the personal data that is permitted by law and necessary to support health and care and operational processes will be collected and processed.

For more information visit the Your Care Record page

References to “My Care Hub”, “we” and “us” in this privacy policy refer to the joint data controllers for the My Care Hub service commissioned by BSW ICB and provided by the BSW Integrated Care Record (ICR) solution supplier, Graphnet.

  1. What data is collected and processed

Data provided by you is stored in the BSW Integrated Care Record (ICR). This falls into the following categories:

  • your thoughts and feelings on various topics relevant to your pregnancy, for discussion with your midwife, including:
  • How are you feeling emotionally? Are you worried about anything in particular?
  • Do you need to think about finances? Need Support? Can you claim any benefits?
  • Do you feel ready for life after the birth? Do you have everything you need?
  • your preferences for the birth; things such as:
  • Where would you like to have your baby?
  • Do you know what to do if you’re worried about anything, what to look for, and who to call if this is urgent?
  • Do you know your blood group and iron levels? Do you want to be tested (again)?
  1. The legal basis for processing

The organisations providing your healthcare are required by law to collect and share data about you to ensure you receive effective care services.  The legal detail is set out below for your information.

Unless an individual has objected to the joint processing and sharing and the sharing organisation has accepted the individual’s objection to the processing the legal basis for viewing the shared records is also provided by General Data Protection Regulation:

  1. 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”; and
  2. Article 9(2)h
    “processing is necessary for the purposes of preventive … medicine, … medical diagnosis, the provision of health …or treatment or the management of …care systems and services”.

Where you are receiving maternity services and have agreed to use the My Care Hub app, then the common law of confidentiality is addressed by your engagement with the services and the understanding that confidential data about you will be used by the service through the My Care Hub app.

  1. Who may access your information

The data you enter into the My Care Hub app is made available to those clinicians caring for you. This will be mostly used by midwives, but is also available to other clinicians involved in your care, including your GP. They have committed to use the personal confidential data identified in this document solely for the purposes defined in this document

As was the case with your paper maternity notes, it is your choice if you wish to show any information to family and friends.

  1. How we use your information

We use the information that you provide to:

  1. Ensure that your care is as consistent as possible with your needs, preferences and circumstances; and
  2. Plan, monitor and adapt the health and care services we provide to you.

The privacy arrangements for the My Care Hub Personal Health Record service are considered satisfactory as:

  1. Access is for professionals with a “legitimate relationship” with you (that is, they are involved in your care). This excludes Social Care professionals
  2. There is an audit trail showing which professional users have accessed your records


  1. Right of access and right of rectification

You can see the information you have submitted using the app, simply by viewing it in the app

If any information that we hold about you that you can see through the app is inaccurate, cannot be updated using the app, and you would like it corrected, please contact the organisation that collected it from you and shared it, for example the hospital caring for you or your GP practice

If you have any other concerns about the use of your data, please raise them with the organisation providing your care


  1. Personal Health Record data controllers and processors


  1. Complaints

If you have any concerns, you can contact,

Alternatively, you can raise them with the organisations providing your care


  1. Future updates to this privacy policy statement

We may change this privacy policy statement at any time.  Where substantial changes are made to the privacy policy we will either notify you when you access the My Care Hub Personal Health Record service or send you an email with details of the updated privacy policy statement using the latest email address you have provided.

If you continue to use the My Care Hub app after changes are made, you will be agreeing to those changes.