Infection Prevention and Control (IPC) Annual Statement 2024
Woodbrook Medical Centre

Woodbrook Medical Centre is committed to the control of infection within the building and in relation to clinical procedures carried out within it.

This statement is generated annually in April and has been produced in accordance with the Health and Social Care Act 2008 and details the practices compliance with guidelines on infection control and cleanliness.

IPC leads for the practice are Practice Nurse Emily Sumner who is supported by Business Manger Anna Ingle.

Incidents

All significant events are reviewed and discussed at the practice MDT meetings each month.

Any learning points are cascaded to all relevant staff.
In the past year there have been no significant events raised that related to Infection Control.

There have been no complaints relating to cleanliness or infection control.

Staff training

There is a planned PowerPoint presentation to staff at Woodbrook Medical Centre regarding waste management and needle stick injuries in May this year.

To be undertaken by Practice Nurses Emily and Claire. We plan to use this opportunity to undertake a hand hygiene audit with staff.

Cleaning audits

An early morning cleaning audit has been undertaken and the results have been fed back to the
cleaning company.

Monthly audit

A monthly safe management of the care environment audit is completed and the results are fed back
to the management team.

Hand hygiene audit

The last hand hygiene audit completed was 18.5.2023.
The next audit is due to take place in May 2024.

Waste and sharps audits

Waste audits are completed by Business Manager Anna Ingle.
Three monthly sharps bin audits are completed by Practice Nurse Emily Sumner.

Cold chain review

• Cold Chain Policy in place
• Vaccines close-to-expiry stock are clearly labelled and vaccines continue to be rotated in date order.
• A new vaccine fridge obtained last year to improve storage of vaccines due to capacity being too low in flu time.
• Fridges have internal temperature readings inside the fridges and information downloaded weekly.
• A medical grade Cold Box is available in the practice in case emergency transfer of vaccinations is required.
• Fridge temperatures continue to be checked once a day.

Practice annual IPC audit and actions

The last audit was undertaken in February 2023 and resulted in the following actions:

• Fabric desk chairs were replaced with wipeable seating in 8 of the clinical rooms.
• Swing waste bins in the toilets were replaced with plastic pedal bins.
• Several broken clinical waste bins were replaced.
• Curtains in clinical areas to be changed 6 monthly or if soiled.

The annual audit for 2024 is pending completion.

The practice is currently undergoing staged renovation with the consultation rooms and reception areas undergoing redecoration and new televisions in the waiting areas.

Further work is planned to include redecoration of the rest of the practice with replacement floor coverings.

Risk Assessments

In the last year the following risk assessments were carried out:

• Legionella (Water) Risk Assessments: The practice reviews its water safety risk assessment to ensure that the water supply does not pose a risk to patients, visitors or staff.
• The use of alcohol gel in waiting areas.
• Curtains: Disposable curtains are used in clinical rooms and are changed every 6 months. All curtains are regularly reviewed and changed more frequently if damaged or soiled.

Policies

Policies relating to infection prevention and control are available to all staff and are reviewed and updated annually.

Additionally, all policies are amended on an ongoing basis as per current advice, guidance and legislation changes.

Responsibility

It is the responsibility of all the staff at Woodbrook Medical Centre to be familiar with this statement and their roles and responsibilities under it.

Review

The IPC Lead and the Registered Manager are responsible for reviewing and producing the annual statement.

This annual statement will be updated on or before 17th April 2025.

Signed by Practice Nurse Emily Sumner
Infection Prevention and Control Lead
For and on behalf of Woodbrook Medical Centre

1 Introduction

1.1 Policy statement

On occasion, patients attending appointments at Woodbrook Medical Centre will be late due to circumstances beyond their control. This document provides direction for the management of patients who fail to attend appointments punctually and is to be read in conjunction with the organisation’s Did Not Attend (DNA) Policy.

1.2 Status

The organisation will aim to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the
organisation and other individuals performing functions in relation to the organisation such as agency workers, locums and contractors.

2 Policy

2.1 Patient responsibility

The NHS Constitution explains that patients should “keep appointments or cancel within reasonable time. Receiving treatment within the maximum waiting times may be compromised unless you do”. It is courtesy and expectation that patients inform this organisation as soon as possible if they are aware they will be late for an appointment.

Sometimes, patients arrive and simply take a seat in the waiting room assuming that there is no need to ‘book in’ upon arrival. To avoid any inconvenience for all, a self-check-in poster is available here to remind patients to use the self-check-in screen upon arrival.

2.2 Management of late arrivals

To adhere to the appointment schedule and to ensure all patients receive an excellent level of service, late arrivals are to be managed as follows:

• • Less than 10 minutes late – staff will:

    • • Mark the patient as having arrived, advising them that the clinician may already be seeing the next patient
    • • Explain that the patient will be seen after the clinician has finished with their current patient
    • • If appropriate, remind the patient of the importance of attending appointments on time

• • More than 10 minutes late – staff will advise the patient that they have missed their appointment and offer the following as appropriate:

    • • Offer the patient an appointment later during that session or that day (if an appointment is available)
    • • Discuss the patient with the clinician and, if in agreement, and the patient is willing to wait, advise that they will be seen at the end of that session. The patient should be made aware that this may be some time.
    • • Should the above option not be possible, the patient should rebook for another appointment

• • It should be noted that it is at the discretion of the clinician whether the patient is seen or not; there may be a valid reason for being late and each patient will advise staff accordingly. Ideally, clinicians are to be informed of any late arrivals via a screen message.

2.3 Management of waiting patients

Should staff note a patient has been waiting for more than 20 minutes, they should apologise to the patient, explaining the reason(s) for the delay. In the case of an administrative error, the administration team should advise the clinician of this and confirm the patient did not arrive
late for their appointment. Every effort should then be made to ensure the patient is seen in sequential order rather than being offered a later appointment.

If this situation occurs on a regular basis, then the management will consider conducting an audit with additional training being a consideration.

Should any patient have waited for more than 20 minutes then this should be investigated. Sometimes it may be that the patient has forgotten to check-in or that the reception team has failed to book the patient on the system as having arrived. The organisation displays a ‘Sorry to keep you waiting’ poster in all waiting areas on the TV Screens.

2.4 Recording of information

Administrative staff are to annotate the outcome of the discussion with the clinician regarding those patients who are more than 10 minutes late. Additionally, all staff are to ensure the appropriate SNOMED CT ID 401278005 is used to enable searches to be carried out accurately
and to monitor patients who are consistently late for appointments with clinicians.

2.5 Patient awareness

If a patient is late and the appointment is cancelled, then this is to be classified as a “Did not attend” as the appointment could not be reused. The patient may still expect to be seen at a later date, causing longer waiting times for all patients. To assist with patient understanding of the DNA problem, the following posters are available:

• • 3 reasons not to miss your appointment

• • Did not attend information

For further detailed information, see the organisation’s Did Not Attend (DNA) Policy.

2.6 Clinic lateness

The organisation is fully committed to running to schedule and, should this not be the case, patients will be advised at the earliest opportunity as to the reasons why and the expected duration of the delay. Reasons for delay may be, but are not limited to:

• • Medical emergencies

• • Complex routine appointments overrunning

• • Delay in staff arriving due to external factors beyond their control

• • Administrative error by a patient or staff member

In all cases, reception staff must advise patients accordingly.

Occasionally a patient may suggest that they want to make a complaint following an overrunning clinic. Should they wish to do so, then the Complaints Procedure should be referred to.

1           Introduction

1.1         Policy statement

This document has been produced to provide all staff at Woodbrook Medical Centre with the necessary information to ensure that they understand how communication works internally and externally and how they are involved in the communication process. Excellent communication is essential to deliver a service that meets the needs of those who use the organisation’s services.

This policy will explain how communication works within and outside the organisation and the responsibilities of all staff members. Furthermore, it explains the different means to communicate and the nuances that are required to effectively manage these.

1.2         Status

The organisation aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the organisation and other individuals performing functions in relation to the organisation such as agency workers, locums and contractors.

2          Communication considerations

2.1         General

Understanding and respecting patient preferences means that patients need to be aware of the range of communication options available to them, to be informed of the potential risks of each communication format and to indicate their preferences against each.

Since 2016, all organisations that provide NHS care and/or publicly funded adult social care are legally required to follow the Accessible Information Standard. Further reading can be sought in the Accessible Information Standards Policy.

There will be occasions when patients will require the services of an interpreter and/or a translator. For detailed supporting guidance, refer to the Translator and Interpreter Policy.

2.2         Significance of communication

Communication may be between clinicians, clinician and patient, clinician and non-clinical staff, non-clinical staff and patient. The several means of communication which are discussed throughout this policy.

All staff must be effective communicators as they play a key role in the provision of information to patients, carers, colleagues and external stakeholders. It is therefore pivotal that information is relayed in the most appropriate and timely manner to ensure the safe and effective care of patients and to enable the organisation to function efficiently and effectively.

The identification of patient contacts is vital and, as such, a telephone caller’s identity and credentials must be verified, ensuring that they are the patient or that they have the consent of the person they are calling about. It is also important that, as a principle, when there is communication related to patient care, an appropriate note is recorded in their clinical record by clinicians and non-clinicians alike.

2.3         Monitoring frequency

For communication to be effective, messages must be processed in an acceptable time frame. It is considered best practice for staff to check all messaging systems such as email, messenger, clinical systems, text messages, etc. at least three times daily, usually at the start of the working day, around midday and late afternoon before the organisation closes.

In the following chapters, detailed guidance is provided on each different communication method.

3          Emails and SMS

3.1         Email use

All staff will be given an NHS email address upon joining which is for the use of practice business only. NHS emails should not be used for personal use, nor should the content of any email bring this organisation into disrepute.

Emails should be written in a clear and concise manner and should be relevant to the subject heading. The organisation will establish a standard signature block and disclaimer regarding use of information contained in the email.

3.2         Contacting patients by email or SMS

Patients may actively and consistently use email or SMS text messaging as their preferred method of communication. Therefore, is imperative that the patient confirms both email address and mobile telephone number to enable this organisation to verify the accuracy of the information held. While it is the responsibility of the patient to ensure that they provide up to date contact details, we will often confirm these details when either in attendance or when contacting the practice.

Patients will be reminded that the organisation is not responsible for the protection of the information once it has been received by the patient. It is also to be recommended to the patient that they do not use a shared email address for the purpose of communicating so that confidential information will not be seen by family members. Furthermore, and specific to emails, patients are to be advised that internet email accounts are not secure and that there is a risk of their email being hacked.

This organisation will not accept any responsibility for the loss of confidential information should a patient’s email account be hacked.

3.3         Email parameters

Only appropriate matters will be dealt with using email. The clinical lead has agreed to the following being acceptable:

• Appointments
• Repeat prescription queries
• Requesting test results
• Requesting copies of medical records
• Emails containing images of a clinical condition

Requests for complex information about medical conditions or symptoms are not appropriate for email communication. Instead, the organisation will telephone the patient to ask them to make an appointment to discuss the matter with an appropriate member of the clinical team.

Additional information can be found in NHS Digital Guidance for sending secure email (including to patients) and also the Audio Visual and Photography Policy including the medico-legal expectations for receiving any intimate images.

For further guidance refer to:

• Access to Medical Records Policy
• Managing Incoming Pathology Results
• CQC GP mythbuster 46: Managing test results and clinical correspondence

3.4         Out of office function

Staff members who are often required to either send or receive emails are to ensure that they utilise the “out of office” function detailing the period of leave. An alternative contact can be added to the message.

3.5         Consent for patient communication via email or text

As consent is not used as a legal basis for data processing, messages are therefore sent on an ‘opt-out’ basis. If a patient informs this organisation that they do not wish to receive text messages, a member of staff must update their ‘notification preferences’ in the clinical system.

When a patient provides either a mobile phone number or email address, the NHS E document titled Email and text message communications deems this to be sufficient consent to then send them either an email or a SMS text message. However, this is provided that a Data Protection Impact Assessment (DPIA) has been undertaken and that all reasonable steps have been made to ensure the communication methods used are both secure and are meeting their transparency responsibilities.

NHS E is supportive of text messaging in the delivery of care and remind practices of the need to ensure that they inform patients as to how they may be contacted and what they may be contacted for, such as:

• Appointment reminders
• Appointment letters
• Individual invitations to screening, medication reviews, vaccination appointments
• Test result notifications/advice to call the practice where action is needed
• Friends and family test surveys
• Interactive messages with the ability to confirm/cancel appointments

In addition, this organisation allows patients to contact them via email and text message for the following:

• Ordering repeat prescriptions via email/online message
• Requesting appointments or non-urgent advice
• Updating them on your health and care

It should be noted that this NHS E advice does contradict the current, albeit older, advice from both the MDU and the MPS as detailed in the following documents:

• MDU – Text message communication in general practice
• MDU – Avoiding email dangers
• Medical Protection Society – Communicating with patients by test message

Under the Data Protection Act 2018 (DPA18) and the UK General Data protection Regulation (GDPR), re-consent does not need to be considered for those patients already receiving text messaging services. For more information on consent, refer to the Consent Guidance.

3.6         Compliance actions

This organisation will meet its transparency responsibilities by providing information about how it uses email addresses and mobile telephone numbers. This will be promoted via the following means:

• During registration via the New Patient Registration and Health Check Policy
• When a mobile phone or email address is recorded/confirmed or updated
• The Practice Privacy Notice that is available on the practice website
• Within posters that are placed in patient areas such as:
  • Email and text messaging poster
  • Text messaging service poster

Should a patient have a preference or wish to opt out of any communications, they can complete the form at Annex A and as detailed at Section 3.11. Should proxy action be required, then the proxy access preferences form is to be completed at Annex B and as detailed at Section 3.15.

3.7         Ensuring information is correct

Patient circumstances can change over time and these preferences should be actively maintained. The fourth Data Protection Principle adopted into UK law states that all personal data processed shall be accurate and, where necessary, kept up to date. This is commonly referred to as the accuracy principle.

When text message communication is intended to be used for test results, it is recommended that the patient’s preference is checked during each contact.

3.8         Data Protection Impact Assessment (DPIA)

To support the rationale to offer service users a text or email option, a DPIA will be undertaken. This DPIA will include all aspects of the process including retaining any information and ensure that all methods of communication used are secure.

A DPIA template can be found within the UK GDPR Policy.

3.9         Generic email address

This organisation will only communicate with patients from generic email addresses as this provides reassurance to patients that the email they have received is legitimate. Ordinarily staff should not communicate with patients from their individual @nhs.net email account.

This organisation will ensure it sends an automated response indicating that the email has been received.

3.10      Email retention

Emails are classed as records and are to be added to the patient’s healthcare record and have the appropriate SNOMED CT code included. Staff are to add a short summary of the email to the record, for example:

• “Patient emailed regarding test results; replied with results and advised patient to book an appointment with the Practice Nurse”

• “Patient emailed requesting information about symptoms they are experiencing. Advised patient to book an appointment as it is not appropriate to discuss this using email. Patient has subsequently booked an appointment”

Should any patient email contain relevant information, including image(s) regarding their ongoing clinical condition, at the clinician’s discretion, this is to be uploaded to the patient’s medical record.

To meet with the rulings of the Data Protection Act 2018, once uploaded to the clinical record there no longer remains any need to retain the email. It is the responsibility of any recipient of the email to delete the message once the action is complete.

This information should be shared with patients within the practice leaflet and upon the website.

3.11      Opting in or out of communication via email or text

For the method of being contacted, patients may request to opt-out of receiving either SMS text messages or emails. In some instances, patients may wish to only receive specific types of information. An example is when a patient prefers to receive a text appointment reminder but does not wish to be sent test results.

The form that details a patient’s wishes for being contacted by either email, text or both is at Annex A. Note that this does not need to be completed for all patients who provide their email address or mobile telephone contact number as this is then considered to be implied consent and as detailed at Section 3.3.

Should a patient wish to fully or partially opt-out, then this organisation will use alternative methods of communication. All decisions will be detailed within their clinical record to ensure that all staff know of their preference.

The following SNOMED CT codes will be used:

Patients should be free to update and change their preferences at any time and expect those changes to be effective immediately.

Further reading on both email and text messaging requirements and best practice can be found in the NHS E Template for email and text message communications

and Gov.uk Screening text message principles.

3.12      Sending SMS messages and etiquette

Convenience allows patients to receive SMS text messages that contain non-sensitive information as part of the routine advice or reminder service. Staff must refrain from using abbreviations or ‘text speak’ and ensure that messages are written in a language that is understandable and unambiguous.

Each message should include the following as the final line: “This text-messaging service is unable to receive replies. For all enquires, contact the practice on XXX”. Under no circumstances are any staff to use their personal mobile phones to send messages to patients.

When sending a text message to a patient, staff members must consider the 4c’s, that being:

• Consent
• Confidentiality
• Child/age of the recipient
• Content

Emails and text messages should not be sent to patients before 08.30 or after 20.30 unless it is felt appropriate to do so, for example a patient is awaiting an urgent prescription before their holiday.

3.13      Text message content

While this method of communication is time-efficient, improves communication and is particularly beneficial to patients with impaired hearing, the potential to breach patient confidentiality must also be a consideration.

SMS text messages should not contain sensitive information. Sensitivity is not determined solely by the type of information (clinic appointment) but requires a judgement as to the impact if the information was misused. Some information is especially sensitive, such as issues relating to sexual health and mental health.

Texts can efficiently be sent to patients to convey the following information:

• Reminder of their forthcoming appointment at the organisation

• The need to call the organisation to arrange an appointment

• A new patient health check is due

• The need to call the organisation to rearrange an appointment due to the cancellation of a clinic

• Log on details for video conference consultation

There is no way of guaranteeing that a message has been read by the intended recipient, therefore:

• Messages containing critical information should not be relied upon (e.g., abnormal blood test results requiring immediate action) unless they are followed up to ensure the information was received

• If the patient’s mobile phone number has been verified, the delivery receipt can confirm that the message has arrived on their phone.

Without consent, staff should avoid sending sensitive information as SMS messages can be overseen and therefore may be viewed by a patient’s relative, friend or colleague.

Messages should be phrased professionally but do not require the same level of formality as a letter. Text abbreviations, e.g., ‘thnx’, ‘u’, are not appropriate.

When using a template, for guidance, examples are:

All SMS messages are recorded within patients’ healthcare records.

3.14      Delivery reports

Staff can see when a message was delivered to a patient, or if the delivery failed, by reviewing ‘delivery reports’.

If an SMS text message is shown as undelivered, a further attempt will be made to send the same message again. If this is again unsuccessful, then either a telephone call will be made or a letter will be sent with the same content as used in the text message and the failure should be coded into the patient’s notes using the appropriate SNOMED CT code:

3.15      Proxy access

Consent would need to be obtained to forward an email to a carer, relative, responsible adult or partner. Proxy access may be given to both email and/or SMS text messaging services. Proxy access can be requested via the consent for proxy access to email or SMS form at Annex B.

Should the practice opt not to grant the person access to the text messaging service, the Practice Manager will contact the patient and advise them of the reasons why this decision has been reached.

3.16      Children and young people’s access

Children and young people may be keener for interaction via text message as this is more commonplace as their means to communicate. However, with this comes greater challenges as, while children and young people may refer to use SMS regarding their care, particular attention should be given to:

• Highlighting the ability for children and young persons to request that their contact details are used instead of their parents or carers

• Having the correct contact details

• What information is to be sent to them for specific episodes of care as their healthcare record may contain alternative contact numbers for both them and their parents or carers

• Children and young people may wish general care information to remain communicated to their parents, e.g., check-ups, service information etc., while wishing for a particular test result to be texted only to them

• It should not be presumed to automatically include parents or carers in any communication

It is difficult to say at what age the child will become competent to make autonomous decisions regarding their healthcare as, between the ages of 11-16, this varies from person to person.

In accordance with Article 8 of UK GDPR and Part 2, Chapter 2, paragraph 9 of the DPA 2018, from the age of 13, young people are able to provide their own consent and will be able to register for text messaging services.

People aged 16 or above are assumed to be competent to make an independent and informed decision about whether to ask for someone to have proxy access to their text messaging service unless there is an indication that they are not. Care must be taken to determine who has parental rights for a child under 11 or a patient over 16 who is not competent to control access. Care must also be taken if a parent has no, or limited, legal right of access because they have been perpetrators of abuse and/or neglect.

The approach as detailed within the RCGP document titled GP Online Service Guidance: Children and Young People is to be adopted. Further reading can be found in CQC GP mythbuster 8: Gillick competency and Fraser guidelines.

A flowchart to support the access process is available at Annex C.

3.17      Continuous improvement

To fully embed text messaging as a way of working and maximise the benefits for the organisation, staff and patients, the lead who is responsible for improvement initiatives should encourage the use of SMS by:

• Presenting usage across the team by discussing at practice meetings. Those staff who regularly use SMS as a form of communication should share the benefits

• Gathering patient feedback on the service and identifying other opportunities to provide a better patient experience using text messaging. Discuss any findings and opportunities with the patient participation group (PPG)

• Developing a library of practice text templates and relating these to other practice protocols (e.g., care navigation, test results, self-care). Share these with other practices to obtain their considerations

• Completing audits to ascertain patients’ needs. This could also include types of messages sent and whether SMS is the best form of communication as the patient may have a poor signal reception

3.18      Receiving text messages

Should the organisation have a mobile telephone as an alternative method of communicating and should patients be able to send messages to this number, the administration team are responsible for ensuring that these messages are read and any appropriate action has been completed.

Details of this service are available within the practice leaflet and website along with guarantees as to how this organisation manages patient data that is forwarded by text message citing the privacy notice

To ensure that data protection considerations are met, the message, including any image, will be deleted once it has been uploaded to the patient’s clinical record although, in accordance with Article 35 of UK GDPR as detailed at Section 3.7, a DPIA will also be undertaken to reflect this method of receiving and maintaining patient data.

For further information, refer to the UK GDPR Policy and the Practice Privacy Notice.

4          Website and practice leaflet

4.1         Website

It is a contractual requirement to include the detail as listed within Part 4 of NHS E document Creating a highly useable and accessible GP website.

Note that any information on how to access GP services should remain correct and up-to-date.

4.2         Practice leaflet

The information within the practice leaflet must also reflect that which has been added to the website. Further information is detailed within the above link to Part 4 of the NHS E document.

Supporting documents can be found in the following:

• Practice Information Leaflet Guidance
• Practice Information Leaflet template
• Children’s Privacy Information Leaflet template

The Practice Manager is to be appraised of any out-of-date or incorrect information that is found on either the practice website or leaflet.

5          Internet use

5.1         Principles of acceptable use

All staff will have access to the internet, shared network drives and the intranet to enable them to perform their duties. The use of the internet facility by staff is permitted; however, it is only authorised during official breaks or when it is necessary to complete a specific task or when approved by line managers.

Staff are reminded not permitted to use the internet for any of the following purposes:

• Pornography
• Gambling
• Promotion of terrorism and/or terrorism skills
• Cult-promoting websites
• Any other website that may reasonably bring the organisation into disrepute, such as those that are likely to cause offence

To support this, remote access from CSU, the Information Governance Lead or Practice Manager all have the right to scrutinise the internet browsing history of staff members and, if it is found that staff are using the organisation’s IT facilities for such activities, disciplinary action will be taken. This may include involving the local police depending on the nature and source of the information.

6          Social media

6.1         General

Social media is a useful method to quickly disseminate information such as early closure, advertising specific clinic dates or to advertise health promotions campaigns or initiatives. However, all content that is posted onto any of the organisation’s social media pages is restricted to ensure that only appropriate comments or pictures are uploaded.

6.2         Acceptable use

Work-related issues must not be placed on any social networking site at any time as this could identify an individual and breach patient or employee confidentiality. Work content or material or contacts or connections list created by an employee during their employment on any of their authorised social networking sites shall remain the property of the organisation.

Upon termination of employment, any employee who is a social media administrator shall hand over access rights to their accounts together with any work content or material and any contacts or connections lists.

Furthermore, additional reading can be sought in:

• Patient Social Media and Acceptable Use Policy
• Confidentiality and Data Protection Handbook
• Caldicott and Confidentiality Policy

6.3         Social media platforms

Only information that has been approved by the nominated individual may be posted on the organisation’s social media platforms. Staff are not permitted to use the organisation’s social media platforms to make any unrelated posts. To prevent inappropriate usage of the platform(s), access is limited to the nominated individuals.

The monitoring of the platform(s) for comments and feedback from patients is the responsibility of the management team. The specific requirements are outlined in the individual’s Terms of Reference.

6.4         Inappropriate staff use of personal social media accounts

It is not the intention at this organisation to interact with the personal lives of staff. However, it may be considered a disciplinary offence, up to and including gross misconduct in accordance with the Disciplinary Policy and Procedure, should any staff member post an article or image upon their personal social media account that is subsequently deemed to compromise either:

• Their professional standing
• The organisation
• Another staff member
• A patient

Prior approval must be sought from the Practice Manager for any image that has been taken of any event, such as a flu clinic, to be uploaded to a personal social media account for public viewing.

The Practice Manager will review any image to ensure that it is appropriate and that the organisation is always seen favourably.

6.5         Sharing images of staff members

When an image that identifies another staff member(s) is taken, the staff member captured in the image is to be asked for their consent prior to this being uploaded to any social media account.

Failure to do so may be a breach of the staff member’s human right to enjoy the right to privacy. This includes whether the image is taken within the organisation or externally such as an organised social function.

It should be noted that particular care must be taken when capturing any image from within the workplace as this may inadvertently breach patient confidentiality. Should this occur, this may be considered as per the Disciplinary Policy and Procedure.

Further guidance is detailed in the Caldicott and Confidentiality Policy.

6.6         Instant messaging

While most staff members will have access to emails and instant messaging (IM) such as WhatsApp, unless specifically stated within the contract of employment, the joining of any organisational IM group is voluntary and not an expectation.

IM is an effective tool, particularly for communication and the rapid sharing of information, it also provides end-to-end encryption (AES 256) and as such, offers users a secure means to share information.

At this organisation, IM groups have been created to expedite the sharing of information, although staff must ensure that when they use IMs, they:

• Do not include any patient identifiable information
• Acknowledge that any IM messaging conversations may be subject to freedom of information or subject access requests
• Do not use an IM in lieu of the medical record

Staff must ensure the following security measures are put in place:

• Set up a device passcode ensuring the device is always locked
• Disable the message notifications on the device lock-screen
• Enable the remote wipe feature should the device be lost or stolen
• Never allow their device to be shared
• Enable two-step verification
• Review any links to other instant messaging apps and determine whether they need to be turned off

When using an IM for organisation related matters, staff must ensure they are considerate of their co-workers and are not to:

• Use foul or abusive language

• Send discriminatory and/or derogatory information including information based on sex, age, race, religion, politics, etc., regardless of whether the information was intended as a ‘joke’

• Share links or refer to pornography, gambling, the promotion of terrorism or terrorism skills or cult-promoting paraphernalia

Staff are reminded that, should they lose their device, this could have both personal and professional ramifications and therefore they must ensure they adhere to the requirements outlined above.

Should staff be communicated with outside of their normal working hours, ordinarily there is no expectation that this is to be responded to during non-working times. For some business-critical positions this might be a requirement.

7          Intranet and clinical system

7.1         Usage

Staff must ensure that, when accessing information on the intranet, confidentiality is always maintained, ensuring that access by unauthorised persons is prevented.

Any unauthorised access constitutes a security breach and must be reported to the Information Governance Lead immediately.

7.2         Access

Staff are not permitted to use the intranet and/or the clinical system to access any medical information relating to themselves, their families, colleagues or friends unless this has been authorised by the appropriate manager and deemed legitimate.

Unauthorised access is absolutely forbidden and will be considered to be a disciplinary offence, and the appropriate disciplinary action will be taken against offenders.

7.3         Appropriate content

As for instant messaging, staff must not access and/or send discriminatory and/or derogatory information using the organisation’s intranet or email systems.

The sending of discriminatory or derogatory information is a disciplinary offence and appropriate disciplinary action will be taken against offenders.

8          Tele and videoconference consultations

8.1         Tele and videoconferencing governance

Another form of communication can be achieved via a tele or videoconference consultation call. NHS England has established information regarding the use of this technology when supporting patient access in its detailed document titled Using video conferencing and consultation tools.

Managing the risks associated with tele and videoconferencing needs attention from both care professionals and service users and guidance to support risk assessments can be found in the Health, Safety and Risk Management Handbook.

Further information can be sought from the Audio Visual and Photography Policy.

8.2         Patient considerations

When assessing suitability for tele and videoconferencing, the following is to be considered:

• The healthcare professional will ensure that the decision as to whether tele and/or videoconferencing is a suitable form of communication will always be considered on an individual patient basis

• The healthcare professional will always assess the appropriateness of any tele and/or videoconference consultation and it will be their professional judgement regardless of any patient request

• Should there be any concern regarding risk, neglect or any other safeguarding issue, then consideration must be given to the appropriateness of tele and/or videoconferencing due to the lack of guarantee as to whether the patient is alone and is able to give a full account of the reasons for the consultation. In this instance, the patient would be offered a face to face appointment and the clinician should refer to The Safeguarding Handbook

• Tele and/or videoconferencing will not be considered for those patients when the matters to be discussed may cause the patient distress or anxiety or to discuss matters of sensitivity, such as informing an individual that they have been diagnosed with a terminal illness or potentially stigmatising condition

• Patients are to be made aware that no communication over the internet is entirely secure

• While tele and/or videoconferencing can bring benefits to both patients and this organisation, such as convenience, less travel and cost savings, it should be offered as a choice rather than a requirement. It should not be offered when care may be undermined or when service users may struggle to cope

• Patients are to be made aware that they will need to have a good quality

internet connection to achieve the most benefit out of the videoconferencing service

• The patient is to be advised that the organisation cannot provide any guarantees as to the quality or security of the service; neither can any support be provided to resolve technical issues

8.3         Patient consent to videoconferencing

Patient consent to the use of videoconferencing is required but need not be explicit. Annex D details the videoconference consent form.

9          Artificial intelligence systems

9.1      About

The use of innovative technologies such as Artificial intelligence Systems (AIS) within healthcare is becoming more prevalent. Within general practice, the likelihood is that the main use would be as a tool to support in the writing of patient consultations, or in a letter to a patient, for example following a complaint.

While the use of Artificial Intelligence (AI) aims to enhance the accuracy of documentation, reduce administrative workload and increase and improve patient engagement, consideration has to be given to the protection of patient data, upholding professional standards and ensuring compliance with legal and ethical responsibilities.

Considerations of both the pros and cons of AI are detailed at Section 9.4.

The NHS document titles All adopters guidance lists all the requirements and regulations that apply to adopters of digital technologies within any health and social care setting. Further detailed reading can be found in the NHS E guidance titled Artificial Intelligence: How to get it right.

9.2      Information governance and compliance

When considering the information governance (IG) implications, there is a need to be clear about ensuring the criteria within the Data Protection Act 2018 is being met.

In particular:

• What data is required?
• Why is it required?
• Who will be processing it and will it be shared?
• How will it processed?
• Where will it be processed?

A Data Protection Impact Assessment (DPIA) will be required to be undertaken as this would capture potential impacts, consider mitigations and enable informed risk management. A DPIA template can be found in the UK GDPR Policy.

Following a DPIA, consideration is then to be given towards having a governance plan which is detailed within the MDU guidance titled Adopting AI in healthcare. In particular, if adopting a system that is already developed, the British Standards guidelines within this MDU link are to be complied with to ensure the stringent NHS data protection standards continue to be met.

It is imperative that no patient identifiable information is provided to support any AI data search and that the NHS Confidentiality Code of Practice is being complied with.

Retention of any AI data is as for other healthcare records and as detailed within the Record Retention Schedule document.

To ensure that risks have been considered and mitigated, prior to establishing AIS at this organisation, a risk assessment will be conducted. Further guidance can be sought within the Health, Safety and Risk Management Handbook.

9.3      Staff training and guidance

The use of and signing up to any AI tools can only be used after having obtained the explicit, written consent of the Partners or management. Unauthorised use of AI services will be considered a serious breach that may result in disciplinary action. The Practice Manager will maintain a list of those who are permitted to use AI technology.

There is a continued requirement for all staff to undertake mandatory training to support data protection. Furthermore, all staff are to be aware of the various supporting policies, including the procedures for reporting confidentiality breaches or suspected misuse.

Useful guidance including staff obligations and links to the various data protection policies can be found in the following:

• Data Security and Protection Toolkit Handbook
• Confidentiality and Data Protection Handbook

9.4      Benefits and pitfalls of using AI technology

While not an exhaustive list, the following table details some of the pros and cons of using AI within a consultation:

Additional reading can be found at:

• MDU guidance titled Can I use AI to write a complaint response?
• Practice Index blog titled AI in general practice – striking the right balance

9.5      Monitoring and review

Should there be any changes in data protection regulations or advances in AI technology, this guidance will be reviewed.

When AI is used, then this will form part of any data protection audits, including the annual Data Security and Protection Toolkit (DSPT) return to confirm that the security of any technology that is being used is both appropriate and being maintained. Any shortcomings following an audit, or any incidents involving AI will be documented and reviewed to identify risks and implement improvements.

10     Telephone communications

10.1   Provision

Telephones are provided to enable staff to communicate with patients, patients’ carers and other service providers to ensure that the expected level of service is always delivered.

Further reading can be found in the Correspondence Management Policy.

10.2   Acceptable and authorised use

The practice telephones are only to be used for the purpose of the organisation’s business. Personal use is strictly prohibited except in the event of an emergency. Calls to premium-rate telephone numbers are also prohibited.

Calls to areas outside the UK are blocked; should it be necessary to call a number, Practice Manager authorisation will be required.

• Recording incoming and outgoing calls

In accordance with the UK GDPR, the lawful basis for processing data also applies to the recording of telephone calls. To conform with this in relation to the recording of telephone calls, one of the processing requirements as detailed within Article 6 must apply.

When accepting an incoming call or dialling out, staff must advise the caller or receiver that the call will be recorded and give the reason for the call being recorded. Should any call then be listened to, say for training purposes, then this detail is to be entered into a Telephone Call Recording Register.

Information that is required is:

• Who has accessed the call
• Reasons why
• What was done with the recording

A template Recordings Register can be found at Annex E.

Further guidance can be sought from the Audio Visual and Photography Policy.

At this organisation, the data controller is responsible for and must be able to demonstrate compliance with the principles relating to the processing of personal data as outlined in Article 5 of the UK GDPR.

10.4      General guidance to answering the telephone

The following sequence is standard when answering the telephone to verify the details of the caller:

• Use the appropriate salutation
• State your name and the name of the organisation
• Ask who is calling and the nature of the call
• Activate the silence button when appropriate
• Always be polite and professional

If not already within the preamble message, mention to the caller that calls are recorded with a justification such as training purposes.

10.5      Verifying a patient caller

Prior to any information being passed to a caller, the patient’s identity is to be verified. Follow the options below to do this noting that only necessary information should be provided.

• Request that the patient confirms their name, address, date of birth and either home or mobile telephone number

• If unable to remember their telephone details, suggest that you will call back on one of their listed numbers or an alternative number that is listed for a proxy or next of kin

• If neither of the above can be satisfied, then the caller should be advised that no information can be passed due to their inability to verify who they are

Guidance on verifying online patient identification can be accessed at NHS E document titled Good Practice Guidance on Identity Verification.

10.6      Communicating with a relative

Information should not be divulged to anyone other than the patient unless consent has been given and is recorded in the patient’s healthcare record on the clinical system.

Therefore, before any personal and/or sensitive information may be shared by telephone, it is the staff member’s responsibility to ensure that the caller has the legal right to that information and that the subject of the information has provided consent.

This may include confirming the whereabouts of the patient.

Staff must therefore:

• When practicable, confirm the consent of the patient has been given and confirm that this has been recorded within the clinical notes
• Check the identity of caller and the patient’s full name. This may involve telephoning the caller back to verify any listed telephone number

• Make sure the person they are talking to is entitled to the information

• If in any doubt, not provide any information until they are sure the information should be provided

• If unsure, pass the call to a senior member of staff

10.7   Communicating with a third party

Information may be provided to a third party should this be in the interest of patient care. To do this, the caller’s identity must be verified following the below procedure:

• Request the patient’s details to include three forms of identity. This could include their name, address, date of birth and either home or mobile telephone number

• Confirm the caller’s telephone number, including any switchboard extension

• To verify the caller’s identity, the number provided for the switchboard (hospital, police, social worker) should be called. Should the caller be phoning from a mobile, then ask the switchboard if this is the correct contact detail for this person prior to returning the call

• If unsure, the call should be passed to a senior member of staff

Reminder, this information can only be passed in the interest of patient care. Information should not be passed to other parties such as employers asking the whereabouts of their staff members.

10.8      Telephone messages for staff

If a call is received at the organisation for a member of staff and they are absent or busy, the person receiving the call is to record the following information:

• Name of caller
• Time of call
• Date of call
• Who they were calling/wanted to speak to
• Message (if applicable)
• The caller’s telephone number (repeat this back to the caller for confirmation)
• An appropriate time to call back

This information is to be relayed to the intended recipient as soon as practicable.

NOTE: If a patient calls to discuss a care-related issue, this must be annotated in the patient’s electronic healthcare record and the intended recipient informed.

10.9      Telephone messages for patients

To ensure that patient care is of the highest standard, information that is to be relayed to patients must be clear and comprehensible. At this organisation, the following process is to be followed:

• Clinicians are to send messages to staff using the clinical system to request that they contact the patient and relay the message while ensuring that the administrative staff have all the necessary information to give to the patient

• The clinician is to make an appropriate entry in the patient record that this has been done

• Once the member of administrative staff has relayed the message to the patient, they are to make an entry in the patient’s record stating that the message has been passed to the patient with a short summary of the information that was relayed

• Any comment made by the patient is also to be recorded
  • Abusive or aggressive patients

Unfortunately, on occasion, there may be times when a patient calls the practice and speaks to a member of staff in an abusive or aggressive manner.

Staff must ensure that they:

• Annotate the date and time of the call
• Ascertain who is calling
• Remain calm, offering empathy
• Determine the reason (if possible) for the aggression or abuse
• Offer solutions if practicable
• Advise the caller that if they persist with such an aggressive and/or abusive tone, the call with be ended
• End the call if appropriate
• Note down a summary in the patient’s healthcare record
• Inform the Practice Manager
• Report the incident in accordance with the practice incident reporting policy or significant event policy

In all circumstances, staff are to demonstrate confidence and compassion, remaining calm throughout the incident. Staff should refrain from being judgemental, instead opting to show the patient their clear intention to resolve the situation as opposed to attempting any form of reprimand.

Refer to the Dealing With Unreasonable Violent and Abusive Patients Policy and the Removal of Patients Policy.

10.11   Contacting the police

Should it be necessary to contact the local police, the organisation is required to notify the CQC as this is a statutory notification.

Statutory Notification – Police involvement incident notification form

11     Internal monitoring of communications and records

11.1   Monitoring electronic communications at work

For quality control and auditing purposes, all staff are reminded that a random percentage of all forms of communication will be monitored within this organisation. These audits will include correspondence between both staff to patient and staff to staff.

This measure is to support best practice and ultimately to improve upon the patient experience and any such monitoring will be logged within the Recordings Register at Annex E.

Detailed information to support this requirement, including a form that can be used to confirm understanding during the induction process can be found in the Staff Monitoring Policy.

11.2   Legitimate access of patient or staff records

Staff can access the clinical or personal employment records of patients or staff members for business purposes only. For staff employment records, strict access measures will be adopted and maintained. For clinical records, it is a breach of both the data protection legislation and common law duties of confidentiality to access any records for personal reasons.

Audits of the clinical system will be undertaken to ensure that there has been no inappropriate access to healthcare records.

Further supporting reading can be found in the following guidance documents:

• Staff Monitoring Policy
• Information Governance Breach Reporting Policy
• Confidentiality and Data Protection Handbook

12     Information from meetings

12.1      Accessibility and actions

Following internal meetings, the minutes will be written and saved within the relevant shared drive with the aim of all staff receiving an email with a hyperlink to the minutes within 48 hours of the meeting occurring.

Staff are to ensure that they access this information and read the relevant minutes in a timely manner, either the day of receiving the email or the following day or the day when they return to work following the meeting.

For reference or should staff members wish to be reminded of the outcome of a meeting, for ease, a copy of the minutes of the meeting will be available.

For meeting types and structures refer to the Practice Manager’s Handbook.

13     Maintaining security and general requirements

13.1      Standard security IT procedures

The following procedures apply to all organisation IT hardware:

• All staff are to lock their device when leaving it unattended, no matter how brief their absence may be

• Staff must log out at the end of the working day and shut down the device

• Staff should ensure that login and password information is stored securely and not shared with anyone

• Staff should not attach external hard drives (including USBs) to any organisation device

• Any organisation portable device, e.g., laptop, tablet, mobile phone, etc., must be used and stored in accordance with the Portable Device Policy

13.2      Good practice

To preserve the life of the organisation’s IT equipment, staff should adhere to the following guidance:

• Refrain from eating or drinking in the vicinity of devices

• Do not use excessive force or subject devices to severe or sudden impacts

• Ensure that portable devices are transported in the appropriate protective cases and as detailed within the Portable Device Policy

• Ensure systems are shut down at the end of the working day or when not in use for prolonged periods of time, i.e., long-weekend closure, etc.

• Conduct Display Screen Equipment assessments as detailed within the Eyesight and Display Screen Equipment Policy

• Provide access to IT as necessary

• Only use the locally approved IT department to resolve any IT related issues

13.3      Virus safeguarding

All staff must ensure that any files that are downloaded are virus checked before being used. Staff are not permitted to download/load software unless it is an officially approved software product.

Please refer to communication form here

Table of contents

1         Introduction   3

1.1     Policy statement  3

1.2     Status  3

2         Overview    3

2.1     Legislation and guidance  3

2.2     Complaints management team    4

2.3     Definition of a complaint versus a concern   4

2.4     Formal or informal?  4

2.5     Complaints information  4

2.6     A duty of candour  5

2.7     Parliamentary and Health Service Ombudsman (PHSO) 5

2.8     Complainant options  5

2.9     Timescale  6

2.10   Responding to a concern   6

2.11   Responding to a complaint  7

2.12   Meeting with the complainant  8

2.13   Verbal complaints  8

2.14   Written complaints  8

2.15   Who can make a complaint?  8

2.16   Complaints advocates  9

2.17   Investigating complaints  10

2.18   Conflicts of interest  10

2.19   Final formal response to a complaint  11

2.20   Confidentiality in relation to complaints  12

2.21   Persistent and unreasonable complaints  12

2.22   Complaints citing legal action   12

2.23   Multi-agency complaints  12

2.24   Complaints involving external staff  13

2.25   Complaints involving locum staff  13

2.26   Significant events  13

2.27   Fitness to practise  13

2.28   Staff rights to escalate to PHSO   13

2.29   Private practices and PHSO   14

2.30   Logging and retaining complaints  14

3         Use of complaints as part of the revalidation process   14

3.1     Outlined processes  14

4         CQC regulatory complaint assessment during inspection   14

4.1     Overview   15

5         Further information   15

6         Summary   15

Annex A – Patient complaint form     17

Annex B – Third party patient complaint form     18

Annex C – Complaint handling desktop aide-memoire   19

Annex D – Complaint leaflet  20

Annex E – Acknowledgement of a complaint letter (example)  23

Annex F – Final response to a complaint letter (example)  24

1            Introduction

1.1       Policy statement

The purpose of this document is to ensure all staff at Woodbrook Medical Centre understand that all patients have a right to have their complaint acknowledged and investigated properly. This organisation takes complaints seriously and ensures that they are investigated in an unbiased, transparent, non-judgemental and timely manner.

The organisation will maintain communication with the complainant (or their representative) throughout, ensuring they know the complaint is being taken seriously.

In accordance with Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Regulation 16), all staff at Woodbrook Medical Centre must fully understand the complaints process. Additionally, the BMA has released guidance titled: Responding to concerns: a guide for doctors who manage staff.

1.2       Status

The organisation will aim to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the organisation and other individuals performing functions in relation to the organisation such as agency workers, locums and contractors.

2            Overview

2.1       Legislation and guidance

Every provider of NHS healthcare is required to have a complaints procedure. This process must detail how to complain about any aspect of NHS care, treatment or service and this is a requirement that is written into the NHS Constitution.

This document follows those processes as established within the following:

• The Local Authority Social Services and National Health Services Complaints (England) Regulations 2009

• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 16

• The NHS Constitution

• PHSO – Principles of Good Complaint Handling

• PHSO – NHS Complaint Standards

• PHSO – An opportunity to improve

• Good Practice standards for NHS Complaints Handling

• CQC GP Mythbuster 103 – Complaints Management

• General Medical Council (GMC) ethical guidance

• Assurance of Good Complaints Handling for Primary Care – A toolkit for commissioners

2.2       Complaints management team

The responsible person, or complaints lead, is Dr Krishan Patel and they are responsible for ensuring compliance with the complaints regulations making sure action is taken because of the complaint.

The complaints manager is Anne Jones, Practice Manager. They are responsible for managing all complaints procedures and must be readily identifiable to service users. As recognised in A Guide to Effective Complaints Resolution (England), the responsible person and complaints manager can be the same person.

2.3       Definition of a complaint versus a concern

NHS England defines that a concern is something that a service user is worried or nervous about and this can be resolved at the time the concern is raised whereas a complaint is a statement about something that is wrong or that the service user is dissatisfied with which requires a response.

It should be noted that a service user could be concerned about something and raise this matter, however, should it not be dealt with satisfactorily, then they may make a complaint about that concern.

A poster is available here that highlights how to make a complaint or actions needed should there be a concern.

2.4       Formal or informal?

There is no difference between a “formal” and an “informal” complaint. Both are expressions of dissatisfaction.

It is the responsibility of the complaints manager to consider whether the complaint is informal and therefore early resolution of an issue may be possible. If the complaints manager believes an issue can be resolved quickly then this organisation will aim to do this in around 10 working days and, with the agreement of the enquirer, we will categorise this as a concern and not a complaint.

However, if the enquirer is clear that they wish to formalise the complaint, then the organisation will follow this complaints policy in full.

2.5       Complaints information

Woodbrook Medical Centre has prominently displayed notices in waiting rooms detailing the complaints process. In addition, the process is included on the organisation website and a complaints leaflet is also available from reception.

The information provided is written in conjunction with this policy and refers to the legislation detailed in Section 2.1 and the complaints poster is linked at Section 2.3.

2.6       A duty of candour

The duty of candour is a general duty to be open and transparent with people receiving care at this organisation.

Both the statutory duty of candour and professional duty of candour have similar aims, to make sure that those providing care are open and transparent with the people using their services whether or not something has gone wrong.

Further information can be sought from the Duty of Candour Policy and as detailed within CQC GP Mythbuster 32: Duty of Candour and General Practice (regulation 20)

2.7       Parliamentary and Health Service Ombudsman (PHSO)

The Parliamentary and Health Service Ombudsman’s role is to make final decisions on complaints that have not been resolved locally by either the organisation or the Integrated Care Board (ICB). The Ombudsman will look at complaints when someone believes there has been injustice or hardship because an NHS provider has not acted properly or has given a poor service and not put things right.

The Ombudsman can recommend that organisations provide explanations, apologies and financial remedies to service users and that they take action to improve services.

2.8       Complainant options

The complainant, or their representative, can complain about any aspect of care or treatment they have received at this organisation to this organisation via the complaints manager or directly to NHS England.

As of 1 July 2023, the patient (or their nominated representative) may now submit a complaint either to the ICB or to the organisation that has been commissioned by the NHS to provide a service.

While this was previously NHS England or the organisation, should a complainant have an ongoing complaint that was submitted to NHS England prior to 1 July 2023, they will receive a letter from explaining that their complaint will continue to be investigated by NHS England along with details of their case handler.

If NHS England receive a complaint on or after 1 July, the complainant will receive a letter advising that the ICB will be handling their complaint along with details of their case handler.

Information on how to make a complaint to Leicester, Leicestershire and Rutland ICB “LLR ICB” can be sought from its webpage Contact – LLR ICB.

As complaints also come directly to this organisation, we have adopted a patient-focused approach to complaint handling.

Complaints are not escalated to an ICB following the organisation’s response. A Stage 1 complaint is made to either the organisation or to the ICB.

If dissatisfied with the response from either ICB or the organisation, then the complainant may wish to escalate their complaint to the PHSO. This process is as detailed within the Local Authority Social Services and National Health Service Complaints (England) Regulations (2009) where it states that there should be two stages of dealing with complaints.

See below image that further explains the route of any complaint:

Stage 1

The complainant may make a complaint to either the organisation or to LLR ICB. This is classed as a local resolution

Stage 2

If dissatisfied with the initial Stage 1 response, the complainant may then escalate this to the PHSO

It should be noted that neither the organisation nor the ICB will investigate any complaint should this have been responded to by the other.

The complainant should be provided with a copy of the complaints leaflet at Annex D detailing the complaints process and they should be advised of the two-stage process.

2.9       Timescale

The time constraint for bringing a complaint is 12 months from the occurrence giving rise to the complaint or 12 months from the time that the complainant becomes aware of the matter about which they wish to complain.

If, however, there are good reasons for a complaint not being made within the timescale detailed above, consideration may be afforded to investigating the complaint if it is still feasible to investigate the complaint effectively and fairly.

Should any doubt arise, further guidance should be sought from LLR ICB by the complaints manager.

2.10   Responding to a concern

Should the complaints manager become aware that a patient, or the patient’s representative, wishes to discuss a concern, then this is deemed to be less formal and should be responded to as detailed below.

Points that should be considered are that:

• Should the patient be on the premises, then there will need to be a degree of interaction sooner than if it was a telephone call or email

• All facts need to be ascertained prior to any conversation

• Should the person be angry, contacting them too soon may inflame the situation further if they did not receive the outcome that they desired

• Consider any potential precedence that may be established, and will any future concern be expected to always be dealt with immediately should any response be given too soon

• Time management always needs to be considered

• Many of the concerns raised are not a true complaint, simply a point to note or a concern and this will still be investigated, and an answer ordinarily given within 10 working days. In doing this and with agreement with the enquirer, this would not need to be logged as a complaint as it can be dealt with as a concern.

Whilst each concern will warrant its own response, generally at Woodbrook Medical Centre the outcome will always be to ensure that the best response is always provided.

2.11   Responding to a complaint

The complainant has a right to be regularly updated regarding the progress of their complaint. The complaints manager at Woodbrook Medical Centre will provide an initial response to acknowledge any complaint within three working days after the complaint is received.

All complaints are to be added to the complaints log in accordance with Section 2.29.

There are no timescales when considering a complaint, simply that it must be investigated thoroughly, and that the complainant should be kept up to date with the progress of their complaint

At Woodbrook Medical Centre, should any response not have been provided within six months, we will write to the complainant to explain the reasons for the delay and outline when they can expect to receive the response. At the same time, we will notify the complainant that they have a right to approach the PHSO without waiting for local resolution to be completed.

The MDU advises in its document titled How to respond to a complaint that a response or decision should be made within six months with regular updates during the investigation. If it extends beyond this time, then the complainant must be advised.

CQC GP Mythbuster 103 states the following:

• The tone of a response needs to be professional, measured and sympathetic

• Patient confidentiality should be considered and timescales agreed

• A complaint can be either written or verbal, practices cannot insist that complainants ‘put their complaints in writing’

• Verbal complaints (not resolved in 24 hours) should be written up by the provider. They should share this with the complainant to agree content

2.12   Meeting with the complainant

To support the complaints process, BMA guidance suggests that a meeting should be arranged between the complainant and the complaints lead.

Whilst not a CQC requirement, having a meeting is considered as being best practice due to there often being a more positive outcome.

2.13   Verbal complaints

If a patient wishes to complain verbally and should the patient be content for the person dealing with the complaint to deal with this matter and if appropriate to do so, then complaints should be managed at this level. After this conversation, the patient may suggest that no further action is needed.

Should this be the case, then the matter can be deemed to be closed.

Having this acknowledgement of the verbal complaint will be deemed as being sufficient and therefore the complaints manager does not need to subsequently respond in writing. However, the verbal complaint must be recorded in the complaints log to enable any trends to be identified and improvements to services made if applicable. The complaints manager should record notes of the discussion (for reference only) which may be used when discussing complaints at meetings.

Further information on logging complaints can be sought at Section 2.29.

If the matter demands immediate attention, the complaints manager should be contacted who may then offer the patient an appointment or may offer to see the complainant at this stage. Staff are reminded that when internally escalating any complaint to the complaint’s manager then a full explanation of the events leading to the complaint is to be given to allow any appropriate response.

Note a verbal complaint may simply be a concern. Should this be a less formal concern and, in agreement with the enquirer, then the process at Section 2.10 should be followed.

2.14   Written complaints

Although this is not the preferred option due to the timescales involved from both parties, it is the complainant’s choice, and they may either write or verbalise their concerns.

Therefore, they are not to be persuaded or dissuaded from putting it in writing and when a complaint is received, the response is to be as per Section 2.11.

2.15   Who can make a complaint?

A complaint may be made by the person who is affected by the action, or it may be made by a person acting on behalf of a patient in any case where that person:

• Is a child (an individual who has not attained the age of 18)

In the case of a child, this organisation must be satisfied that there are reasonable grounds for the complaint being made by a representative of the child and furthermore that the representative is making the complaint in the best interests of the child.

• Has died

In the case of a person who has died, the complainant must be the personal representative of the deceased. This organisation will require to be satisfied that the complainant is the personal representative.

Where appropriate, the organisation may request evidence to substantiate the complainant’s claim to have a right to the information.

• Has physical or mental incapacity

In the case of a person who is unable by reason of physical capacity or lacks capacity within the meaning of the Mental Capacity Act 2005 to make the complaint themselves, the organisation needs to be satisfied that the complaint is being made in the best interests of the person on whose behalf the complaint is made.

• Has given consent to a third party acting on their behalf

In the case of a third party pursuing a complaint on behalf of the person affected, the organisation will request the following information:

• Name and address of the person making the complaint
• Name and either date of birth or address of the affected person
• Contact details of the affected person so that they can be contacted for confirmation that they consent to the third party acting on their behalf

The above information will be documented in the file pertaining to this complaint and confirmation will be issued to both the person making the complaint and the person affected.

• Has delegated authority to act on their behalf, for example in the form of a registered Power of Attorney which must cover health affairs

• Is an MP, acting on behalf of and by instruction from a constituent

Should the complaints manager believe a representative does or did not have sufficient interest in the person’s welfare, or is not acting in their best interests, they will discuss the matter with either Medical Defence Union or NHS Resolution to confirm prior to notifying the complainant in writing of any decision.

2.16   Complaints advocates

Details of how patients can complain and how to find independent NHS complaints advocates are detailed within the complaints leaflet at Annex D. Additionally, the patient should be advised that the local Healthwatch Contact us – Healthwatch Leicestershire can help to find an independent complaints advocacy services in the area.

Independent advocacy services include:

• POhWER – a charity that helps people to be involved in decisions being made about their care. POhWER’s support centre can be contacted via 0300 456 2370

• Advocacy People – gives advocacy support. Call 0330 440 9000 for advice or text 80800 starting message with PEOPLE

• Age UK – may have advocates in the area. Visit their website or call 0800 055 6112

• Local councils can offer support in helping the complainant to find an advocacy service.

The PHSO provides several more advocates within its webpage titled Getting advice and support.

2.17     Investigating complaints

This organisation will ensure that complaints are investigated effectively and in accordance with extant legislation and guidance. Furthermore, we will adhere to the following standards when addressing complaints:

• The complainant has a single point of contact in the organisation and is placed at the centre of the process. The nature of their complaint and the outcome they are seeking are established at the outset.

• The complaint is subject to an initial assessment, during which any necessary immediate actions are implemented. A lead investigator is then designated, typically the clinician referenced in the complaint or the one who last consulted with the patient concerning the issue at hand.

• Investigations are thorough, where appropriate obtain independent evidence and opinion, and are carried out in accordance with local procedures, national guidance and within legal frameworks

• The investigator reviews, organises and evaluates the investigative findings

• The judgement reached by the decision maker is transparent, reasonable and based on the evidence available

• The complaint documentation is accurate and complete. The investigation is formally recorded with the level of detail appropriate to the nature and seriousness of the complaint

• Both the complainant and those complained about are responded to adequately

• The investigation of the complaint is complete, impartial and fair

• The complainant should receive a full response or decision within six months following the initial complaint being made. If the complaint is still being investigated, then this would be deemed to be a reasonable explanation for a delay

2.18     Conflicts of interest

The complaints manager and/or investigating clinician must consider and declare whether there are any circumstances by which a reasonable person would consider that their ability to apply judgement or act as a clinical reviewer could be impaired or influenced by another interest that they may hold.

This could include, but not limited to having a close association, having trained or appraised the person(s) being complained about, and/or being in a financial arrangement with them previously or currently.

Should such circumstances arise, the organisation should seek to appoint another member of the organisation as the responsible person with appropriate complaint management experience.

2.19   Final formal response to a complaint

A final response should only be issued to the complainant once the letter has been agreed by Medical Defence Union.

Following this, and upon completion of the investigation, a formal written response will be sent to the complainant and will include the following as detailed within NHS Resolution document titled Responding to complaints:

• Be professional, well thought out and sympathetic

• Deal fully with all the complainant’s complaints

• Include a factual chronology of events which sets out and describes every relevant consultation or telephone contact, referring to the clinical notes as required

• Set out what details are based on memory, contemporaneous notes or normal practice

• Explain any medical terminology in a way in which the complainant will understand

• Contain an apology, offer of treatment or other redress if something has gone wrong

• The response should also highlight what the organisation has done, or intends to do, to remedy the concerns identified to ensure that the problem does not happen again

• The response should inform the complainant that they may complain to the PHSO should they remain dissatisfied

Consideration must be given to the fact that the response is likely to be read by the complainant’s family and possibly legal advisers.

A full explanation and apology may assist in avoiding a claim. However, if a patient subsequently brings a  claim for compensation, the complaint file is likely to be used in those proceedings so it is important that any response to a complaint is clear and well explained and can be supported by evidence.

The full and final response should ordinarily be completed within six months, signed by the responsible person, although should it be likely that this will go beyond this timescale, the complaints manager will contact the complainant to update and give a projected completion timescale.

* Note, it is not a mandatory requirement to forward all complaint response letters to the defence union prior to sending to the complainant. This has simply been added to reduce any potential risk of litigation. Organisations may therefore wish to continue to forward only the most significant complaints to the defence union.

A template example of the final response letter can be found at Annex F.

2.20     Confidentiality in relation to complaints

Any complaint is investigated with the utmost confidence and all associated documentation will be held separately from the complainant’s medical records.

Complaint confidentiality will be maintained, ensuring only managers and staff who are involved in the investigation know the particulars of the complaint.

2.21     Persistent and unreasonable complaints

The management of persistent and unreasonable complaints at this organisation will follow that as detailed by LLR ICB.

Further reading can be sought from the Dealing with Unreasonable, Violent or Abusive Patients Policy although advice will be sought from the ICB prior to any acknowledgment of a persistent, unreasonable or vexatious complainant.

2.22     Complaints citing legal action

Should any complaint be received and the content states that legal action has been sought then, prior to any response, consideration should be given to contacting the defence union for guidance.

• It is strongly suggested that should any organisation receive a complaint that highlights that legal action has been taken then they should be cautious

• By doing nothing with any complaint of this type, this could affect the outcome of a CQC assessment and/or the relationship with your ICB

• Should any complainant cite legal action that refers to an incident after 1 April 2019, contact NHS Resolution and they will assist under the Clinical Negligence Scheme for General Practice (CNSGP). Refer to the NHS Resolution Guidance for general practice document here

• It is strongly suggested that organisations make a record of everything involving the complaint

2.23     Multi-agency complaints

The Local Authority Social Services and NHS Complaints (England) Regulations 2009 state that organisations have a duty to co-operate in multi-agency complaints.

If a complaint is about more than one health or social care organisation, there should be a single co-ordinated response. Complaints managers from each organisation will need to determine which the lead organisation will be, and the lead organisation will then be responsible for co-ordinating the complaint, agreeing timescales with the complainant.

If a complaint becomes multi-agency, the organisation should seek the complainant’s consent to ask for a joint response. The final response should include this and, as with all complaints, any complaint can be made to the provider/commissioner but not both.

2.24   Complaints involving external staff

Should a complaint be received about a member of another organisation’s staff, then this is to be brought to the attention of their complaints manager at the earliest opportunity. The complaints manager will then liaise with the other organisation’s manager.

2.25     Complaints involving locum staff

Woodbrook Medical Centre will ensure that all locum staff, be it GPs, nurses or administrative staff, are aware of both the complaints process and that they will be expected to partake in any subsequent investigation, even if they have left the organisation (keeping in mind the 12-month time frame to complain).

Locum staff must receive assurance that they will be treated equally and that the process will not differ between locum staff, salaried staff or partners.

2.26   Significant events

When a complaint is raised, it may prompt other considerations, such as a significant event (SE). SEs are an excellent way to determine the root cause of an event and Woodbrook Medical Centre can benefit from the learning outcomes because of the SE.

It is advised that the complainant, their carers and/or family are involved in the SE process.  This helps to demonstrate to the complainant that the issue is being taken seriously and investigated by Woodbrook Medical Centre.  NHS E see too many instances where complainants are not involved in the SE process.

Further information on the significant event process can be sought from the Significant Event Policy.

2.27   Fitness to practise

When a complaint is raised, consideration may need to be given to whether the complaint merits a fitness to practise referral and advice may need to be sought from the relevant governing body.

At this organisation, the Senior Partner will be responsible for firstly discussing the complaint with the clinician involved prior to seeking any guidance from the relevant governing body if applicable.

2.28   Staff rights to escalate to the PHSO

It should be noted that any staff who are being complained about can also take the case to the PHSO. An example may be that they are not satisfied with a response given on their behalf by a commissioning body.

2.29   Private practices and the PHSO

Independent doctors are unable to use the PHSO as they have no legal requirement to have an appeals mechanism.

As it is good practice to provide independent adjudication on any complaint, therefore using a service such as Independent Sector Complaints Adjudication Service (ISCAS) should be considered.

2.30   Logging and retaining complaints

All organisations will need to log their complaints and retain as per the Records Retention Schedule.

Evidence required includes:

1. Logging, updating and tracking for trends and considerations

1. Details of all dates of acknowledgement, holding and final response letters and the timely completion of all correspondence relating to the complaint

1. Compliance with the complaints in the categories that are required to complete the annual KO14b submission to NHS Digital

This data is submitted by Anne Jones, Practice Manager to NHS E within the KO14b complaints report annually and then published by NHS Digital. Any reporting period covers the period from 1 April until 31 March.

Evidence of complaints can be compiled within the KO14b Complaints Log Toolkit.

3            Use of complaints as part of the revalidation process

3.1       Outlined processes

As part of the revalidation process, GPs must declare and reflect on any formal complaints about them in tandem with any complaints received outside of formal complaint procedures at their appraisal for revalidation. These complaints may provide useful learning.

The Royal College of General Practitioners (RCGP) has produced appraisal guidance for this purpose.

Nurses may also wish to use information about complaints as part of their NMC revalidation. This feedback can contribute towards submissions about organisation related feedback, and it can also be part of a written reflective account. Likewise, pharmacists and other healthcare professionals may wish to consider using complaints and their management as part of their revalidation process.

The General Pharmaceutical Council (GPhC) revalidation process can be sought here and information relating to the Healthcare Professionals Council (HCPC) revalidation process can be found here.

4            CQC regulatory complaint assessment during inspection

4.1       Overview

The CQC will inspect the organisation to ensure it is safe, effective, responsive, caring and well-led under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Regulation 16) and expect all staff to fully understand the complaints process.

When assessing complaints management, the CQC will seek to be satisfied of the following, as directed within the GP Mythbuster 103 – Complaints management:

• People feel comfortable, confident and are encouraged to make a complaint and speak up

• The process is easy to use so people understand how to make a complaint or raise concerns

• The practice offers help and support where necessary, using accessible information

• The complaints process involves all parties named or involved in the complaint and they have an opportunity to be involved in the response

• The complaints are handled effectively, including:

• Ensuring openness and transparency
• Confidentiality
• Regular updates for the complainant
• A timely response and explanation of the outcome
• A formal record

• Systems and processes protect people from discrimination, harassment or disadvantage

• Complaints are monitored to assess trends that are used for learning, and shared with the wider team or externally as appropriate to make changes and drive continuous improvement.

The complaints manager will advise the complaints procedure to the complainant or their representative. In many cases, a prompt response and, if the complaint is upheld, an explanation and an apology will suffice and will prevent the complaint from escalating (an apology does not constitute an admission of organisational weakness).

5            Further information

Further relevant information is available within both:

• The Data Protection Act 2018
• Public Interest Disclosure Act 1998

6            Summary

The care and treatment delivered by Woodbrook Medical Centre are done so with due diligence and in accordance with current guidelines.  However, it is acknowledged that sometimes things can go wrong.

By having an effective complaints process in place, this organisation can investigate and resolve complaints in a timely manner, achieving the desired outcome for service users whilst also identifying lessons learned and ultimately improving service delivery.

For complaints please refer to this form

1          Introduction

1.1      Policy statement

This document provides the necessary information to enable staff at Woodbrook Medical Centre to manage the death of a patient appropriately, ensuring that the required information is recorded and, where necessary, external agencies are contacted and information is shared. It also provides direction for staff to enable them to support recently bereaved family and friends.

This policy has been written in conjunction with The Medical Certificate of Cause of Death Regulations 2024, The Medical Examiners (England) Regulations 2024, The Medical Examiners (Wales) Regulations 2024, and should be read alongside CQC GP mythbuster 21: Statutory notifications to CQC.

Following the introduction of the above regulations, any death in England or Wales on or after 9 September 2024 will be independently reviewed either by a coroner where they have a duty to investigate or by a medical examiner.

It is imperative that personnel understand the actions necessary following a death, including reporting deaths, liaising with the medical examiners and/or the coroner’s office when necessary and assistance that can be given to the next of kin.

1.2      Status

Woodbrook Medical Centre aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010.  Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the organisation and other individuals performing functions in relation to the organisation, such as agency workers, locums and contractors.

2          Recording of death of a patient in medical record

2.1      Information to be recorded on deaths notified to general practices

Patient deaths can occur in several settings, such as the patient’s own home, a residential/nursing home or in a secondary care facility.

It is highly likely the death of a patient will be communicated to the organisation by either a

family member, a member of staff from the residential/nursing home, a nurse or clinician from the secondary care facility, the police or the coroner’s office.

Staff receiving this information must ensure that the details are accurate, including (but not limited to):

• The full name of the deceased
• Address
• Date of birth
• NHS number (where available)
• Details of the caller
• Date of death and location
• Arrangements/funeral director (if known)
• Location of body
• Next of kin

All the above information is to be noted in the deceased patient’s healthcare record.

2.2      Patient records

To prevent any further distress to relatives of the deceased, the clinical system must be updated at the earliest opportunity to reflect the death of a patient, using the appropriate SNOMED CT code. The initial notification is to be communicated with the patient’s named GP and the last clinician who had an interaction with the patient.

To prevent unnecessary correspondence being sent to any relatives, the organisation will ensure appropriate internal communication between staff to advise them of the death of a patient. In any communication, the subject heading will only refer to the deceased’s identifying number from the clinical system.

A review of the deceased’s healthcare record is to be undertaken to determine if he/she was:

• Referred to secondary care or was in the process of being referred
• Receiving support from community services, e.g., district nurse, CPN, etc.
• A child (health visitor team must be informed)

Should any of these be the case, this organisation is to contact the relevant team and advise them that the patient is deceased. Following this action, this information is to be recorded on the deceased’s healthcare record.

3          Verification and certification of death

3.1      Verification of death

Verification of death is the process of identifying that a person has died. It has nothing to do with providing a death certificate or identifying the cause of death. English and Welsh law allows that any competent adult may verify that someone has died but it does not place them under a legal obligation to do so.

There is no requirement for a doctor to:

• Confirm that death has occurred or that “life is extinct”
• View the body of a deceased person
• Report the fact that death has occurred

Verification of death requests should be added by reception staff to the duty list for the duty doctor to visit or appropriately delegate this task to a member of the team to complete. This should be completed on the same day the request comes in to prevent delay.

3.2      Attending Practitioner Medical Certificate of Cause of Death (AP MCCD)

NHS England states that it is a statutory requirement for an attending practitioner (AP) to complete the AP MCCD. The 2024 Regulations explain that for an AP to be able to complete the MCCD, they must have attended the deceased in their lifetime. This avoids both unnecessary referral to a coroner and unnecessary delays for bereaved people.

The process for the AP is illustrated below:

Information for the above diagram was sourced from Part 2 of The Medical Certificate of Cause of Death Regulations 2024.

3.3      Request to issue a revised AP MCCD

NHS England guidance explains that there may be occasions when, following a review of the AP MCCD by the registrar of deaths, the registrar is led to believe the cause of death stated on the MCCD needs to be revised. The registrar will consult the medical examiner to determine if they agree a revision is required.

If this is the case, the medical examiner will share the information provided by the registrar with the AP and invite them to revise the AP MCCD. In such instances, the process detailed below is to be followed:

Should the AP and medical examiner not be able to agree on the cause of death, local escalation to another medical examiner and the lead medical examiner is recommended. If the difference of opinion is irreconcilable, the coroner should be notified that the cause of death cannot be established.

3.4      Medical Certificate Cause of Death logistics

The reforms to death certification commenced 9 September 2024 and as part of these changes, a new MCCD was introduced. The Department of Health and Social Care (DHSC) was responsible for the initial issue of the new MCCD to organisations detailed on the distribution list.

The DHSC will send this organisation the following:

1. An initial six-month allocation of MCCDs
2. Guidance on how to order additional MCCDs
3. A unique passcode for ordering additional MCCDs

3.5      Reporting a child death in England

In England, when a child dies, child death review (CDR) partners (Integrated Care Boards and local authorities) must plan:

• To conduct a child death review to investigate the reasons for the death
• For the analysis of information about deaths to be reviewed

Comprehensive advice and guidance, including the immediate actions required and support from bereavement services, can be found in the Child death review: statutory and operational guidance (England) 2018. The role of the medical examiner complements this established process.

Deaths of all children normally resident in the area covered by this organisation will be reviewed by the Child Death Overview Panel (CDOP) in that local authority area and, if appropriate and agreed between partners, the deaths in that area of non-resident children.

Once established, the CDOP will be required to complete the following forms to support the CDR process with the investigation:

• Child death notification
• Child death reporting
• Child death analysis

Further information on the responsibilities of CDOPs regarding child death notifications can be sought within:

• Working together to safeguard children
• Child Death Review – Operational Guidance

3.6      Reporting a child death in Wales

Should a child die unexpectedly in Wales, procedures as detailed within the Procedural Response to Unexpected Deaths in Childhood (PRUDiC) 2018 should be commenced as this is the minimum expected standard for any response to an unexpected death in infancy and childhood within Wales. This document describes the process of communication, collaborative actions and information sharing that is required.

To commence the process of reporting a child death, the  Notification of a Child Death Form (Wales) is to be completed and forwarded to the Child Death Review team at:

Child Death Review Programme Team

Public Health Wales

5th Floor Capital Quarter 2

Tyndall Street

CARDIFF

CF10 4BQ

E-mail: ChildDeath.Review@wales.nhs.uk

The National Medical Examiner’s guidance for England and Wales advises that in the event of the death of a child, the health board medical director and/or relevant assistant medical director, along with the Child Death Review Programme Team are to be informed.

3.7      Medical examiner access to patient records

As explained in The National Medical Examiner’s guidance for England and Wales, medical examiners have a specific statutory right of access to records of deceased patients that they consider relevant when carrying out their duties. The Regulations require medical examiners to make whatever enquiries appear to be necessary to confirm or establish the cause of death.

If the records are not made available and the medical examiner is unable to establish the cause of death, they are obliged to notify the death to the coroner.

4          Guidance

4.1      Cremations

The Cremation (England and Wales) Regulations 2008 Guidance to medical practitioners completing Form Cremation 4 provides detailed advice for clinical staff at this organisation covering the completion of Form Cremation 4, right of inspection and other matters.

Form Cremation 4 can be completed and submitted electronically. Electronic signature includes being sent from the secure email account of the person completing the form.

4.2      DoLS and MCA

Under the Mental Capacity Act (MCA) 2005, a person who lacks capacity and is residing in either a care home or in a hospital to enable treatment to be given may be detained in conditions that amount to deprivation of liberty. This will not be permitted without the authorisation given under the statutory scheme otherwise it would be classed as false imprisonment.

The Chief Coroner issued Guidance No 16a in relation to Deprivation of Liberty Safeguards (DoLS). For deaths to which section 48(2A) applies, there is no mandatory and automatic requirement for a coroner’s investigation on “state detention” grounds if the person was subject to a deprivation of liberty authorised under the MCA 2005.

In accordance with the Coroners and Justice Act 2009, any person subject to a DoLS is deemed to be in “state detention”. The GP still has a responsibility to issue a MCCD. Further reading on DoLS and LPS can be found in the Mental Capacity Act Policy and a Governmental easy read guide can be found here.

4.3      Notifying the CQC

For English practices only:

CQC GP mythbuster 21: Statutory notifications to CQC explains that this organisation is legally obliged to notify the CQC about certain changes, events and incidents that affect service delivery, or the people who use it, including notification of certain deaths.

CQC (Registration) Regulations 2009: Regulation 16 states that the CQC should be informed “without delay” for a number of notifications, including patients who have died. Additional guidance can be found at Primary Medical Services – Guidance on statutory notifications.

4.4      Religious requirements

Information for the main religions and their specific requirements can be found at Annex A.

4.5      Bereavement support

Guidance for relatives and carers can be found at Annex B, an example bereavement letter that can be sent by the practice is at Annex C and a bereavement guide is at Annex D.

4.6      Suicides

When the cause of death is suicide, the coroner will be informed. Furthermore, should the patient have been seen within the previous two weeks by a practice in England, then the practice should notify the CQC as this meets the statutory requirements.

4.7      Suicide and self-harm reduction planning

This organisation follows current national self-harm and suicide prevention guidance in support of both understanding and management.

For referral pathways, support and guidance, further reading can be sought at Annex E.

Annex A – Religious beliefs, practices and rituals after death

The following section outlines the religious beliefs, practices and rituals after death relating to the six major faiths in England and Wales.

This information is provided as a guide and should not be used to make assumptions about any individual’s needs and wishes. It is important that healthcare professionals explore the religious needs and wishes of each individual for whom they care.

Further reading can be sought within the following links:

• PHE publication titled Faith at end of life: public health approach resource for professionals

• Religion Media Centre factsheet: Death and funerals in world religions

Buddhism

Family members may request that the body is not touched during this time and that it is available to them to perform religious rites. All requests should be negotiated carefully to fully support the bereaved family members.

Following death, Buddhists normally cremate the body, but funeral traditions may vary across the different types of Buddhists.

In particular, funeral services may include a picture of the deceased, chanting and praising their qualities. There are unlikely to be objections to post-mortems and organ donation although some Far Eastern Buddhists may object.

Christianity

Patients are likely to request support from their own local church community and those who belong to a church or are religious may have their own needs appropriate to their religious beliefs.

Christians do not usually have any religious objection to a post-mortem.

Funeral services will vary according to the patient’s beliefs and both the family and church ministers will need to be approached regarding the patient’s wishes.

Disposal of the body is by burial or cremation.

Hinduism

Following death, family members may congregate where the body is to pay their respects, offer prayers and chant the name of God. It is important the family is consulted to ascertain if they wish to carry out last rites as distress can be caused if the body is touched by non-Hindus.

When the family is unavailable, it is important that the eyes of the deceased are closed and their limbs straightened, ensuring that jewellery and religious objects are not removed. The body should also be wrapped in a plain sheet without religious emblems.

Cremations are usual for Hindus except for children (in some traditions under the age of 27 months and in others under the age of five years) when burials may be preferred.

Islam

After death, Muslims may request that the deceased body faces Mecca with their eyes and mouth closed and the limbs straightened.

Religious requirements dictate that the body should be buried as soon as possible and therefore those involved in processing the death certificate should be sensitive to this and do so as soon as possible.

Islam directs that the body of the deceased should be handled as gently as possible. The body will commonly be washed by family or friends. A white shroud will be used to wrap the body and prayers will be recited. Family members may feel uncomfortable for the body to be touched by professionals so contact should be kept to a minimum and ideally handled by professionals of the same sex as the deceased person.

The majority of Muslims would not want a post-mortem to be performed on the deceased unless required by law.

Muslims are always buried, and a quick burial is usual although it needs to be recognised that it is not always possible, e.g., there may be a delay in being able to register the death and the death certificate being issued, a post-mortem requirement and difficulties with burials at the weekend and over public holidays.

Judaism

After death is confirmed, the eyes are to be closed and the body should be covered with a

white sheet as a sign of respect. Some families may wish to practice certain customs such as placing the body face up and positioning the feet to face the door.

Depending on the sex of the deceased, fellow men or women will prepare the body for burial and three members of the community will be present. The body is washed and shrouded before being placed in a coffin for burial.

Cremation is forbidden in orthodox Judaism. It is customary for Jewish families to arrange a ‘watcher’ to guard the body after death as it is not permitted for the body to be left until the burial.

Sikhism

At the time of death, Sikhs may wish to repeat the word ‘Waheguru’, meaning the Wonderful Lord. In Sikh tradition, wailing and howling is discouraged. If the patient passes away when family is not present it is important for professionals to contact the family immediately because they may wish to perform recitations and prayers. These prayers are important in accepting that death is an act of God.

Cremation is the norm for most Sikhs. It is important that this takes place as soon as possible so professionals should aim to release the body promptly.

Health and care professionals

Health and care professionals are recommended to:

• Be sensitive to any spiritual and faith needs and whether this needs to be reflected in their end-of-life care

• Understand and record any spiritual needs related to end-of-life care

• Determine whether a visit from the patient’s local religious leader or a faith representative would be appropriate

• Signpost the patient and their family to appropriate spiritual and faith support

• Identify the role of the family in the decision-making process of the end-of-life care plan

• Ensure all end-of-life care and support services information are provided in the language of choice for the patient and their family

• Seek advice and support, as required, from the patient’s local religious leader or faith representative to ensure a positive encounter

Organisations

This organisation will:

• Ensure all staff involved in bereavement support are trained in faith sensitivity and effective communication

• Ensure care plans record faith and the individual’s specific requirements

• Understand what support is available within local communities

• Ensure there is collaboration with local places of worship and faith when recognising community development approaches to end-of-life care

Annex B – Helping those who are bereaved

Helping families and carers

Relatives and carers will understandably be distressed following a death and staff are to ensure that no unnecessary contact is made although empathy and support must be offered to relatives and carers of the deceased when the opportunity presents itself.

A bereavement letter template can be found at Annex C.

When a member of a family asks their GP or a member of staff as to what to do when someone dies, governmental guidance and support is available to assist with any advice including:

• Registering the death (the MCCD in respect of the deceased will be required)

• Arranging a funeral

• Telling the relevant government departments about the death (one notification)

• Checking if there are bereavement benefits and:

• Dealing with their own benefits, pension and taxes
• Checking if an application must be made to stay in the UK

• Dealing with the estate of the deceased

A bereavement guide can be found at Annex D.

Bereavement support

In England, there are several organisations supporting bereavement including some that offer specific support dependent on the nature of the loss.

• childbereavementuk.org
• ataloss.org
• cruse.org.uk
• suicidebereavementuk.com
• ssafa.org.uk

Wales:

• wales.nhs.uk/encyclopaedia/b/article/bereavement
• cruse.org.uk/wales
• samaritans.org/samaritans-cymru

Annex C – Example of a bereavement card

Next of Kin of <Patient Name>

<Patient Address>

<Today’s date>

Sending our sincere condolences at this sad time.

Kind regards,

Woodbrook Medical Centre

Letter included in card:

Bereavement Advice

On behalf of Woodbrook Medical Centre, we wish to convey our deepest sympathy for your recent bereavement and loss. At this very distressing time there are often many decisions and arrangements which need to be made. The below is some useful information and contact details to help you. If you need any further help or support, please do not hesitate to contact us on 01509 239166. For further bereavement support, please visit the National Bereavement Service https://ardens.live/National-Bereavement-Service

5       Registering the Death

You will normally need to register the death within 5 days. A booked appointment with the registrar is usually required, but a death can also be registered by post. To register a death, you will need the Death Certificate and various documents confirming the identity and details of the deceased individual.

6       Tell Us Once

A service who will contact all government and local council departments to notify them of a death, for example council offices, libraries, blue badge, electoral service, housing departments, passport office, pension & DVLA

7       Arranging the Funeral

A burial or cremation can only take place after the death’s registered. There are many things to consider when arranging a funeral. Most people use a funeral director, though you can arrange a funeral yourself.

8       Cruse

Offering support to you after the death of someone close

9       Survivors of Bereavement by Suicide

Offering support to those bereaved by a suicide

10   Age UK

National charity to support those in later life, including those who have suffered recent bereavement

11   Citizens Advice

Offer free, independent, confidential and impartial advice to help people resolve bereavement issues

12   Moodjuice

A self-help guide for people suffering from bereavement

Annex D – Bereavement guide

Woodbrook Medical Centre

Guidance on what to do following a death

Part 1 – Practical matters

Introduction

Following a death, it is often the person who was closest to the deceased who is responsible for organising matters.  As they will also be very emotionally distressed it is advised that they have a relative or friend to help them to make the necessary arrangements.

Notes:

In this leaflet, the term “relative” is used to refer to those close to the deceased, be they a member of the family, partner, friend or significant other.

Whilst this leaflet is easiest to use in its electronic format since it has links to webpages that contain relevant and useful information, it can still be used as a guidance booklet as it covers the main points contained in those relevant webpages.

Throughout this bereavement guidance, all information has been extracted from the UK Government Guidance: What to do when someone dies. This guidance outlines how to register the death, notify government departments and manage financial matters.

Step 1

Register the death

In England and Wales, the death must be registered within five days. This is the total number of days inclusive of bank holidays and weekends.

To find the nearest register office, use the webpage Find a register office and enter your postcode.

To register the death a Medical Certificate of Cause of Death (MCCD) is required and the doctor who attended during the last illness will issue this.  More than one GP may have been involved in the care of the patient and therefore any one of them is able to certify the death.

If the GP(s) is/are unable to be found, the death may be referred to the coroner.

When a death is reported to a coroner, different documents may be needed to register the death and the coroner will decide either one of the following:

1. Should the cause(s) of death be clear, the coroner will:

• Request the doctor signs the MCCD
• Direct you to take the MCCD to the registrar to register the death
• Issues a certificate to the registrar stating that a post-mortem is not needed

1. Should a post-mortem be required to find out how the deceased died, this will be conducted at a hospital or a mortuary. Please be advised that you cannot object to a post-mortem but, if asked, the coroner must inform you and the deceased’s GP where the examination will take place

Once the post-mortem has been completed and no further examinations are required, the coroner will release the body for a funeral.

If there is no inquest required, then the body will be released, and the coroner will send the following:

• Form100B (or the Pink Form) to the registrar stating the cause of death
• Certificate of Coroner – Form Cremation 6 if the body is to be cremated

1. The coroner must hold an inquest if:

• The cause of death is unknown
• The person may have died a violent or unnatural death
• The person might have died in prison or police custody

If an inquest is to be held, to enable you to inform the registrar, you will need to request an interim death certificate from the coroner.  The interim death certificate can also be used to apply for probate either yourself or using a solicitor to enable the deceased’s estate to be administered. 

Once the inquest has been completed, you can request a final death certificate from the registrar.  The registrar will be able to advise you if the Government’s Tell Us Once Service is available in your area.

Step 2

Arrange the funeral

The funeral can only take place once the death has been registered and the registrar has issued the certificate stating that no post-mortem or inquest is required.

If you wish to organise a funeral yourself then contact your local council’s Cemeteries and Crematorium Department T: 01530 454595  Funerals and cremation in Loughborough – Charnwood Borough Council

Some local councils also run their own funeral services, although these are usually non-religious.

A funeral expenses payment is available if you are on certain benefits and need help to pay for a funeral you are arranging. Funeral expenses claimant forms and notes are available to download and all claims must be made within six months of the funeral.

Should any assistance be required to complete the forms, the Bereavement Service helpline, 0800 731 0469, may help. Alternatively, should you not be able to hear or speak on the phone then use Relay UK.

Most people use a funeral director’s services who is a member of either:

• National Association of Funeral Directors or
• The National Society of Allied and Independent Funeral Directors

Step 3

Tell the government about the death

The Tell Us Once service allows you to report a death to most government departments with one communication.

These are:

• HM Revenue and Customs (HMRC) to deal with personal tax (you need tocontact HMRC separately for business taxes such as VAT)

• The Department for Work and Pensions (DWP) to cancel benefits and entitlements, for example universal credit or state pension

• The Passport Office to cancel a British passport

• The Driver and Vehicle Licensing Agency (DVLA) to cancel a licence and remove the person as the keeper of up to five vehicles (contact DVLA separately if you keep or sella vehicle or keep a personalised number plate)

• The local council to cancel housing benefit, council tax reduction (sometimes called council tax support) or a blue badge, to inform council housing services and to remove the person from the electoral register

• Veterans UK to cancel Armed Forces Compensation Scheme payments

If the registrar confirms that the service is available, then you will be given the contact telephone number and a unique reference code which must be used within 84 days.

Before contacting the Tell Us Once service, you will need the following details of the person who died:

• Date of birth
• National Insurance number
• Driving licence number
• Vehicle registration number
• Passport number

and any:

• Benefits or entitlements they were receiving – for example, a state pension
• Local council services they were receiving – for example, a blue badge
• Details of any public sector or armed forces pension schemes they were receiving or paying into

as well as:

• The name, address, telephone number and the National Insurance number or date of birth of any surviving spouse or civil partner

• The name and address of their next of kin – if there is no surviving spouse or civil partner or their spouse or civil partner is not able to deal with their affairs

• The name, address and contact details of the person or company dealing with their estate (property, belongings, and money), known as their ‘executor’ or ‘administrator’

Should the Tell Us Once service not be available in your area or you do not wish to use it then you will have to inform the various government departments yourself. This is in addition to banks, building societies, insurance companies, television companies, utility companies and landlords or housing associations.

Step 4

Check if you can receive bereavement benefits

The following financial assistance may be available:

1. Bereavement Support Payment (BSP) claims must be made within three months of a partner’s death to receive the full amount. Claims may be made up to 21 months after their death, but fewer monthly payments will be made.

To be eligible, your partner must:

• Have paid National Insurance contributions for a least 25 weeks in any one tax year
• Died because of an accident or a disease caused at work, e.g., asbestosis
• Be under state pension age
• Be living in the UK or a country that pays bereavement benefits

However, there are exceptions to the 21 months rule, e.g., the cause of death was confirmed more than 21 months after the death.   Speak to the Bereavement Service helpline on 0800 731 0469

You cannot claim BSP if you are in prison.

Bereavement claim forms are available on line along with BSP notes. Alternatively, applications can be made by phone on 0800 731 0469 or forms can be collected from the nearest Jobcentre Plus

1. Guardian’s Allowance if you are bringing up a child whose parents or one of whose parents have died.

To receive Guardian’s Allowance all the following must apply:

• You are bringing up someone else’s child

• The child’s parents are dead (see conditions for one surviving parent below)

• You qualify for Child Benefit

• One of the parents was born in the UK (or was living in the UK since the age of 16 for at least 52 weeks in any two-year period)

• If you adopt a child, you may still receive Guardian’s Allowance if you were receiving it before you adopted the child

If there is one surviving parent, you could receive Guardian’s Allowance if one of the following is true:

• You don’t know where the surviving parent is

• The parents were divorced, or their civil partnership has been dissolved

• The surviving parent does not have custody and is not maintaining the child and there is not a court order in place saying that they should

• The parents were not married, the mother has died, and the father is unknown

• The surviving parent will be in prison for at least two years from the date of the death of the other parent

• The surviving parent is in a hospital by court order

Deal with your own benefits, pension and taxes

Depending on your relationship with the person who died, your tax benefit claims, and tax may change.

For details see Your benefits, tax and pension after the death of a spouse

Check if you need to apply to stay in the UK

If your right to live in the UK depended on your relationship with someone who has died, you may have to apply for a new visa. You should check the rules if:

• You are in UK as the partner of a British citizen or someone with indefinite leave to remain. You may be eligible to apply for settlement

• Your partner who died served as a member of the HM Forces. See guidance HM forces: partners and children

For other rules on visas, check UK Visas and Immigration.

Step 5

Deal with their estate

You may have to deal with the will, money and property of the person who died if you are a close friend or relative or the executor of the person’s will.

Check if you need to apply for probate

By applying for probate you are applying to acquire the legal right to deal with someone’s estate, i.e., their property, money and possessions.  If the person:

• Left a will you will receive a “grant of probate”
• Did not leave a will, you will be given a “letter of administration”

Value the estate

To value the person’s estate involves three main tasks:

1. Contact organisations

Contact banks, building societies and/or utility providers about the person’s assets and debts. Follow this link to find out which organisations to contact and what letters to write.

2. Deal with the estate

If you already have the right to deal with the person’s estate, i.e., you have been granted probate, you can begin dealing with their estate.  You may wish to hire the services of a professional to help with some or all the tasks of dealing with the estate.

See Money Advice Service on how and when to use a solicitor or probate specialist

Many who have dealt with an estate themselves find that it is not as complicated as they imagined, and they may save many thousands of pounds by so doing. The table below shows examples of charges of 1% and 5% of an estate valued at £100,000.

3. Update property records

How you update the property records when someone dies depends on whether they were the joint or sole owner of a property.

This guidance will help you to do this.

Part 2 – Emotional matters

This section offers some support which we hope will help you to come to terms with the emotions of losing a loved one.

Grief and other difficult feelings

Whoever has died, your loss is unique to you, and you will cope with it in your own way. However, although bereavement is a highly personal and often traumatic event, many people go through a range of recognisable reactions and emotions when someone they are close to dies.

Sometimes people are shocked and upset by their changing and violent emotions when they are bereaved.  Realising that these feelings are quite normal may help.

Grief

Grief knocks you off balance emotionally, physically, and mentally.

If the death had been expected, you tell yourself you should be able to cope, but you can’t.  You think you’re over it, and you’re not.  You think you should feel all right because you have family and friends looking out for you, but you don’t feel all right because no one can replace the person who has died.

When you are bereaved, you have to cope with a world that seems to have fallen apart.  In practical terms, your life may have changed dramatically.  You may have much less money, or you may be better off financially.  You may be eating and sleeping alone for the first time or be faced with household jobs that you used to share with the person who died.  Losing a close family member or an old friend can mean that you have no one who shares your childhood memories or family jokes.

Yet the biggest changes are probably inside you.  When someone close to you dies, it can seem as though everything you took for granted has gone, that you have lost your sense of identity and self-worth.  You may feel you have lost almost everything and haven’t much left to fall back on or to look forward to.  And you may feel like this even if you have loving friends and family around you.

Your feelings

At first you may be too shocked to feel anything much, even if the death had been expected.  Many bereaved people say that, in their initial shock, they felt a sense of numbness and disbelief.

As you get over the shock and begin to grasp the reality of what has happened you may go through some of the most powerful feelings you have ever had, feeling high or excitable one minute, in despair the next.  You may think you are going mad because you can’t control your emotions, can’t concentrate, can’t organise yourself to make a phone call or make a cup of tea.  It may seem as though everything you knew has gone and that nothing will ever make sense again.

You may feel that you don’t care whether you live or die because the person who died was so important to you that you cannot imagine existing without them.  Your loss may feel overwhelming, and you are likely to be reminded of it constantly.  You are likely to miss the person who died in all sorts of ways, physically as well as emotionally.

Your thoughts

You are likely to find it hard to concentrate and may feel confused and forgetful.  Your thoughts may constantly return to the person who died, with painful questions and fears running through your mind.  Alongside this, you may have a sense of relief if they died at what seemed the right time for them.

As you think more about the person and your relationship with them, as you talk about them and listen to what relatives, friends and acquaintances say, you are likely to start building a fuller picture of them than you had before.  As it grows, you will probably find this picture becomes a part of your life, a source of comfort which is more than just a memory.

Your body

You will probably notice physical changes.  You may have difficulty getting to sleep and your sleep may be disturbed by vivid dreams and long periods of wakefulness.  You may lose your appetite.

People react physically in many ways, some feel tense and short of breath, others feel edgy and restless, others feel very slow and lethargic.

You are likely to feel exhausted, especially if you had been providing care for the person who died or had been through an anxious time before they died.  Strong emotions and dealing with all the things that need to be done after a death can also make you feel tired and drained.

The stress of grief makes enormous physical demands upon you.  You may be more susceptible to colds or other infections or become more accident-prone. It is very important to take extra care of yourself, so try to eat well and take extra rest even if you can’t sleep.  Take some gentle exercise if you can.

Be kind to yourself and do not try to do too much while you are grieving.

Getting used to the death

Getting used to a death seems to happen in fits and starts and is often not as simple as it sounds, especially if you had shared your life with the person who died or had known them since childhood.  Or you may have lost a younger relative, perhaps your daughter or son, or grandchild.  When a young person dies it reverses the natural order of life and death and can seem particularly unjust.

You may switch between talking rationally about the death, the illness, the will, then have a surge of hope as you think you see the person who has died in the street or hear them whistling their favourite song.

Allowing your feelings to come out can help you to get used to your loss.  Talking about the death and about the person who died, dealing with the practicalities of your new situation, and trying to think of the present as well as the past can all help you get used to the reality of the death and get through some of the anguish you may feel.

As you do this you will probably, slowly, begin to find a way of living without the person alongside you but very much with you in your thoughts and memories.

Emptiness and depression

Feelings of depression and meaninglessness can hit you when the reality of the death begins to bite, and you realise that the person who has died will not come back.  And just when you think you have started to move on and are feeling better, you may hit rock bottom and life can seem endlessly bleak and empty.

Surprisingly, although it may feel almost unbearable at the time, this seems to be a period when some inner healing takes place.  Afterwards, people generally say they feel lighter, more in control of their lives and better able to look forward.

Depression is a natural response to a bereavement, and usually lifts of its own accord.  But if it doesn’t, and life seems an endless, pointless struggle, you could be clinically depressed.  Clinical depression can be treated and there are different ways of getting through periods of depression, both with and without antidepressant medication.

Ask your doctor for help and advice.

If you have any thoughts of suicide, do talk to your doctor or someone you trust.  Remember you can phone The Samaritans, day or night, on 0845 790 9090.

Anger

Some people don’t feel angry after a bereavement, but if you do it can be the hardest feeling to cope with.  You may feel anger at the injustice of your loss; anger at the lack of understanding in others; anger at the person who died because of what they are putting you through.

Bereaved people are usually angry because they feel hurt and unhappy.  You probably feel angry at yourself and at the person who died i.e., the person you need most, who has left you to feel abandoned, frightened, and alone.

These feelings are normal, and you can probably get rid of your anger in a way which doesn’t hurt you or someone else.  Some people have a shouting session, dig the garden, or write their thoughts on paper and then destroy the pages.

Try not to bottle up your feelings, think about the reasons for your anger.  If you do not do this, whatever is upsetting you will almost certainly continue to trouble you and will not disappear.  It can help to talk about your feelings with someone who is not emotionally involved in your own loss.

Fear

You are likely to feel fearful and anxious.  This is very natural as your familiar world has been turned upside down and you are likely to feel you have little control over your life or over the thoughts and feelings churning inside you.  Feeling out of control is likely to leave you feeling vulnerable and afraid.  But you will probably notice that as you get used to coping, and start to get on top of life again, you will become more confident and less afraid.

You may also have fears about important practical issues.  How will you cope with less money coming in?  How will you manage household tasks?  If you have worries like this, it usually helps to get some practical advice.  The organisations listed at the end of this leaflet may be able to help you.

Mixed feelings

It is usual to have mixed feelings when someone dies.  You may find yourself thinking of times you wish had been different, or wondering what might have happened if you, or the person who died, had made different decisions.  Mixed feelings of regret, guilt or anger are not easy to deal with.

The important thing is to try to reach a point where you are realistic about the past and can accept it for what it was.  This can be hard if the relationship had turned sour or was always a mixture of good and bad.

When a difficult relationship ends with death the problem is that any chance of mutual understanding or reconciliation has gone.  But if you try to avoid dealing with upsetting thoughts and feelings you run the risk of becoming angry, bitter, or depressed.  In a situation like this it usually helps to get a better understanding of the relationship you had with the person who died, of what was good about it and what was not, to work out what each of you contributed to it.

Don’t be too hard on yourself or anyone else. No one is perfect and most people try to do the best they can with the situation they are in.  Eventually you are likely to reach some acceptance of the past and move towards a more fruitful present.

Memories of other losses

A bereavement may trigger memories of earlier losses which you thought you had got over.  Perhaps you did not realise at the time how much you were affected, or circumstances made it difficult for you to talk about your feelings.  You may now remember these unhappy times with great clarity, and this can be extremely distressing.

For example, some people are only now beginning to grieve for losses that happened in the war years.  Similarly, people who had a stillborn baby or a miscarriage, or a child who died, or whose brother or sister died young, may only now start to grieve openly.

In years past, it was often customary not to talk much about such deaths and children’s feelings were often overlooked, so you may have gone through life with an unspoken burden of sorrow.  You may feel that you need to mourn for these losses, and talk about your experiences, before you can come to terms with your more recent loss.

Grief in children and adolescents

Most children do not understand the meaning of death until they are three or four years old.  Even so, they feel the loss of a close friend or relative in much the same way as adults.  Even in infancy it is known that children grieve and feel great distress.

Children experience the passage of time differently to adults and can therefore appear to overcome grief quite quickly.  It is important that the grief of a young person is not overlooked

Part 3 – Sources of help and support

At the time of publication these contact details were correct. If you find any errors, please do let us know.

Age UK

Tel: 0800 678 1602

Web: www.ageuk.org.uk

Age UK is a national network of groups providing services for older people. Some Age UK groups offer bereavement counselling.  Look in your phone book to find your local group, or ring the national office listed above.

Bereavement Advice Centre

Helpline: 0800 634 9494

Web: www.bereavementadvice.org

The Bereavement Advice Centre offers practical advice on what to do when someone dies.

Citizens Advice Bureau

Look in your phone book to find your nearest Citizens Advice Bureau, or go to their website: www.citizensadvice.org.uk

The Compassionate Friends (For bereaved parents)

Helpline: 0845 123 2304

Web: www.tcf.org.uk

The Compassionate Friends is a charitable self-help organisation.  Parents who have been bereaved themselves offer friendship and support to other bereaved parents, grandparents, and their families.

Cruse Bereavement Care

Helpline: 0808 808 1677

Web: www.cruse.org.uk

Cruse Bereavement Care offers free information, advice, and support to bereaved people. Cruse runs a helpline, and can supply a wide range of books, leaflets, and a newsletter for bereaved people.

Facing Bereavement

Web: www.facingbereavement.co.uk

Facing Bereavement contains articles offering advice and guidance on facing and dealing with bereavement.

Institute of Civil Funerals

Tel: 01480 861411

Web: www.iocf.org.uk

The Institute of Civil Funerals can help you find someone to conduct a non-religious funeral.

Lullaby Trust

Web: www.lullabytrust.org.uk/bereavement-support/when-a-baby-dies/

Support for parents and carers of a child under 18 who has died

Natural Death Centre

Tel: 01962 712 690

Web: www.naturaldeath.org.uk

The Natural Death Centre offers advice on arranging a funeral with or without using a funeral director.

Probate and Inheritance Tax Helpline

Tel: 0300 123 1072

Web: www.gov.uk/government/organisations/hm-revenue-customs

Samaritans

Tel: 116123

Email: jo@samaritans.org

Web: www.samaritans.org

Samaritans are ordinary people from all walks of life who offer a sympathetic listening ear to despairing and suicidal people of all ages. Lines are open 24 hours a day, 365 days a year; all calls are charged at the local rate.

Service Personnel and Veterans Agency

General Helpline: 0808 1914 218

Bereavement number and minicom line: 0800 169 3458

Web: www.veterans-uk.info

The Service Personnel and Veterans Agency can offer support and advice to war pensioners, war widows, their dependants and carers.

War Widows Association of Great Britain

Tel: 0845 241 2189

Web: www.warwidows.org.uk

The War Widows Association gives advice, help and support to war widows and dependants.

Annex E – Self-harm and suicide prevention

Area plans to support national suicide and self-harm strategies will be formed at ICB level and will incorporate guidance, treatment pathways and regional resources.

Understanding suicidal feelings

Suicide is the act of intentionally ending your life. Should anyone discuss that they have suicidal thoughts about taking their own life, it is important that they discuss their feelings and ask for help. Suicidal thoughts sometimes start because people feel overwhelmed by their problems or their situation. When people get overwhelmed, it can be hard to see a way out, thoughts become very negative and narrow and it becomes difficult to get perspective and find solutions.

People can become suicidal if they have really difficult or upsetting things to deal with or if they have lots of smaller worries that pile up and make them feel overwhelmed. Telling someone how they feel can be frightening. However, talking to someone is the first step to getting help, staying safe and developing a sense of hope. With the right support, things can get better.

Referral pathways

Suicide is complex and has a devastating impact on families, friends and the wider community. It can affect anyone, anywhere at any time and there is no single cause or solution, but it is often preventable.

Everyone within the organisation can play a role in preventing suicide and self-harm.

The Leicestershire County Council Suicide Prevention Strategy objectives are aligned to the National Suicide Prevention Strategy (NSPS) and aim to reduce the suicide rate in the population of individuals that encounter our services and to provide better support for those bereaved or affected by suicide.

Supporting guidance from LLR ICB will detail the priority areas for action to support the local supporting actions to align to the NSPS:

• Improve data and evidence to ensure that effective, evidence-informed and timely interventions continue to be adapted

• Provide tailored, targeted support to priority groups, including those at higher risk. At a national level, this includes:
• Children and young people
• Middle-aged men
• People who have self-harmed
• People in contact with mental health services
• People in contact with the justice system
• Autistic people
• Pregnant women and new mothers

• Address common risk factors linked to suicide at a population level by providing early intervention and tailored support. These are:
  • Physical illness
  • Financial difficulty and economic adversity
  • Gambling
  • Alcohol and drug misuse
  • Social isolation and loneliness
  • Domestic abuse

• Promote online safety and responsible media content to reduce harms, improve support and signposting and provide helpful messages about suicide and self-harm

• Provide effective crisis support across sectors for those who reach crisis point

• Reduce access to means and methods of suicide when this is appropriate and necessary as an intervention to prevent suicides

• Provide effective bereavement support to those affected by suicide

• Make suicide everybody’s business so that we can maximise our collective impact and support to prevent suicides

Further reading and guidance on LLR Suicide Prevention Strategy, referral pathways and supporting information from both suicide and self-harm within this region can be found at Cabinet report template

Suicide prevention

When someone is contemplating suicide, their words and actions can give you clues that they are at risk for hurting themselves. These may include:

If someone you know is showing these high-risk warning signs, then the pathways is to be followed as detailed alert the duty doctor for a same day review or signpost to central access point ran by Leicestershire Partnership Trust or call 999. Other signposting could include to local wellbeing café, up to date information can be found on their website Home Page | The Wellbeing Cafe Project at Loughborough Wellbeing Centre (Mental Health Sevice) (Leicestershire)).

Other indications that someone is not okay could include the following suicide warning signs:

These signs may not always be easy to spot and these emotions are often different between people.

It should be noted that the above may not apply to everyone who is struggling, but they can be a useful guide to what to look out for.

Should any member of the organisation come across any of these warning signs in those that they know, or have spoken to, then they are to be encouraged to talk about how they are feeling with a healthcare professional. Additionally, the staff member should share their concerns with either a clinician or a colleague.

Guidance to support any referral to mental health services can be found via the following referral pathway (Prism Central Access Point).

For specialist support and guidance, the following charities and support groups can assist:

• CALM
• Child Bereavement UK
• Cruse Bereavement Care
• Facing the Future Groups (run by the Samaritans)
• Finding The Words booklet
• Harmless
• Help is at Hand booklet
• Hub of Hope
• PAPYRUS Prevention of Young Suicide
• Samaritans
• Self-Injury Support
• Stay Alive App
• Survivors of Bereavement by Suicide
• Young Minds

Legislation and guidance

eLearning resources and videoclips

Other resources

NHS E/Grassroots Suicide Prevention Stay Alive App

A suicide and self-help poster is available here.

For further guidance on how to access mental health services refer to:

• NHS England
• Public Health Wales

For statistics on both suicide and self-harm, refer to Fingertips.

How we use your personal information

This practice handles medical records in-line with laws on data protection and confidentiality.

We share medical records with those who are involved in providing you with care and treatment. In some circumstances we will also share medical records for medical research, for example to find out more about why people get ill.

We share information when the law requires us to do so, for example, to prevent infectious diseases from spreading or to check the care being provided to you is safe.

You have the right to be given a copy of your medical record.

You have the right to object to your medical records being shared with those who provide you with care.

You have the right to object to your information being used for medical research and to plan health services.

You have the right to have any mistakes corrected and to complain to the Information Commissioner’s Office.

Please see the practice privacy notice or speak to a member of staff for more information about your rights.

COVID-19 response transparency notice

Confidentiality

Everyone working for the NHS has the legal duty to keep information about you confidential.

We ask for information so that you can receive proper care and treatment. You may be receiving care from other people as well as the NHS. By working together for your benefit some information may need to be shared about you. The information about you is only ever passed on in times of genuine need.

Whenever we can, details will be removed which may identify you. The sharing of some types of very sensitive personal information is strictly controlled by law. Anyone who receives information from us is also under a legal duty to maintain confidentiality.

Freedom of Information

The Freedom of Information Act 2000 obliges the practice to produce a Publication Scheme.

A Publication Scheme is a guide to the ‘classes’ of information the practice intends to routinely make available.

This scheme is available from reception.

1 Introduction

1.1 Policy statement

The purpose of this document is to detail the procedures that Woodbrook Medical Centre has implemented to identify and record carers, ensuring that such individuals are appropriately referred for a Carer’s Assessment to Adult Care Services who will provide further advice and support.

Carers form a diverse group and provide services for individuals who need assistance or support with day-to-day living. This document provides information that is applicable to all members of staff at Woodbrook Medical Centre. It is the responsibility of all staff to give accurate, relevant information to those individuals identified as carers whilst also recognising and signposting those individuals who are
providing a service but who are not registered as a carer.

1.2 Status

The organisation aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have with regard to the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment.

2 Policy

2.1 Who are carers?

A carer is a person of any age (including children) who provides unpaid support to a partner, relative, friend or neighbour who could not cope without their help. This could be due to old age, frailty, disability, a serious health condition, mental ill health or substance misuse. Parents of children who are disabled or who have a serious health condition are also considered to be carers.

There is a difference between a carer and care professionals who are paid to provide care. Some carers receive statutory payments or a direct payment for their caring role. Even when carers do not receive such payments, they are still considered to be carers.

Many carers may not identify themselves as a carer. Instead, they see themselves as someone’s partner, relative or friend who is simply ‘doing their best’ to help someone they care about. For this reason, asking ‘do you look after someone?’ can be a more effective opening question than ‘are you a carer?

2.2 Significance of identifying carers

By identifying, assessing and supporting carers’ needs, Woodbrook Medical Centre, will be effectively
reducing:

• Avoidable demand on services
• Carer ill health
• Carer and family breakdown
• Unwarranted variations in carer support

Furthermore, by effectively identifying and appropriately supporting carers, Woodbrook Medical Centre can make sure carers are able to lead a positive life outside of their caring role.

2.3 Mechanisms for identifying carers

At Woodbrook Medical Centre there are two methods used for identifying carers:

Self-identification

Organisation identification

Self-identification is reliant on individuals informing organisation staff that they are carers. In order to raise awareness of the support available to individuals, Woodbrook Medical Centre has devised a number of methods aimed at identifying carers such as:

• Displaying posters in the waiting room and clinical areas
• Including a carer section on new patient registration forms
• Promoting carer information on the organisation website and other social media
• Generating carer-based discussions at Patient Participation Groups, including visits from local organisations
• Placing carer registration forms at reception (see Annex A)
• Holding carer campaigns and events using local media, social media and a range of other opportunities.
• When an individual is collecting a prescription on behalf of someone else
• During a discussion with patients in consultation or other opportune times

All staff have a responsibility to try to identify, support and signpost carers.

2.4 Recording carer details

At Woodbrook Medical Centre as soon as an individual is identified as being a carer, this fact will be annotated on the individual’s clinical record using SNOMED CT code: Caregiver (person) SCTID:

Furthermore, the individual will be added to the carers’ register and an alert added to the clinical system to ensure the whole organisation team is able to see that the individual is a carer.

2.5 Support to carers

To ensure carers are identified and supported effectively, Woodbrook Medical Centre will adhere to the framework of quality markers which covers six key areas as illustrated below.

Detailed guidance explaining how to apply the framework of quality markers can be found at Appendix A of the Supporting carers in general practice: a framework of quality markers document.

2.6 Carers’ champion

At Woodbrook Medical Centre our carers’ champion is Karen Silk-Moore. It is their responsibility to take the lead on all carer-related matters, providing advice and direction to staff and patients as required. Furthermore, they will gather evidence and complete the declaration at Appendix B of the framework of quality markers. Having this evidence can be used both for carers to know that Woodbrook Medical Centre is a supportive organisation and for CQC inspection purposes.

2.7 Additional resources for carers

Additional services and agencies to which carers can be signposted are:

• Care
• Carers UK
• Carers Trust
• Age UK
• Healthwatch
• Adult Social Care resources

Further support is also available from www.carersweek.org.

2.8 The Carers Toolkit

An integrated approach to identifying and assessing carer health and wellbeing is detailed in The Carers Toolkit which offers a formal mechanism for organisations to collaborate with partners to agree ways of identifying and supporting carers.

3 Summary

There is a responsibility for all staff to try to identify those patients who are carers. At Woodbrook Medical Centre, all staff are aware of the effects that caring for someone can have on an individual. Therefore, it is essential that carers are given the necessary support to enable
them to provide care effectively.

1          Introduction

1.1      Policy statement

The purpose of this document is to detail the procedures that Woodbrook Medical Centre has implemented to identify and record carers, ensuring they are appropriately referred for a carer’s assessment for further advice and support. It is the responsibility of all staff to give accurate, relevant information to those individuals identified as carers while also recognising and signposting those individuals who are providing a service but who are not registered as a carer.

1.2      Status

The organisation will aim to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the organisation and other individuals performing functions in relation to the organisation such as agency workers, locums and contractors.

2          Policy

2.1      Who are carers?

CQC GP Mythbuster 44: Caring for carers explains that a carer is a person of any age (including children) who provides unpaid support to a partner, relative, friend or neighbour who could not cope without their help. This could be due to old age, frailty, disability, a serious health condition, mental ill health or substance misuse. Parents of children who are disabled or who have a serious health condition are also considered to be carers.

There is a difference between a carer and care professionals who are paid to provide care. Some carers receive statutory payments or a direct payment for their caring role. Even when carers do not receive such payments, they are still considered to be carers.

Many carers may not identify themselves as a carer. Instead, they see themselves as someone’s partner, relative or friend who is simply ‘doing their best’ to help someone they care about. For this reason, asking ‘do you look after someone?’ can be a more effective opening question than ‘are you a carer?^’

2.2      Significance of identifying carers

This organisation will use the NHS England Carers toolkit which provides detailed guidance on how the organisation can identify and support the wellbeing of carers and their family. Furthermore, by effectively identifying and appropriately supporting carers, this organisation can make sure carers are able to lead a positive life outside their caring role.

2.3      Mechanisms for identifying carers

This organisation uses two methods to identify carers – self-identification and organisational identification. Self-identification is reliant on individuals informing staff that they are carers.

Organisational identification uses the following methods to raise awareness of the support available to individuals:

• Displaying posters in the waiting room and clinical areas
• Including a carer section on new patient registration forms
• Promoting carer information on the organisation website and other social media
• Generating carer-based discussions at Patient Participation Groups, including visits from local organisations
• Placing carer registration forms at reception (see Annex A)
• Holding carer campaigns and events using local media, social media and a range of other opportunities.
• When an individual is collecting a prescription on behalf of someone else
• During a discussion with a patient in consultation or other opportune times

All staff have a responsibility to try to identify, support and signpost carers.

2.4      Recording carer details

Staff are to ensure that carers are correctly coded on the clinical system using SNOMED CT code: Caregiver (person) SCTID: 133932002. Furthermore, individuals identified as carers will be added to the carers’ register and an alert added to the clinical system to ensure whole team awareness.

2.5      Support to carers

To ensure carers are identified and supported effectively, this organisation will adhere to the NHS England Supporting carers in general practice: a framework of quality markers.

2.6      Carers Champion

There is a nominated Carers Champion at this organisation and it is their responsibility to take the lead on all carer-related matters, providing advice and direction to staff and patients as required. Furthermore, they will gather evidence and complete the declaration at Appendix B of the framework of quality markers.

2.7      Additional resources for carers

Additional services and agencies to which carers can be signposted are:

• Care
• Carers UK
• Carers Trust
• Age UK
• Healthwatch
• Adult Social Care resources

Further support is also available from www.carersweek.org.

our health records contain a type of data called confidential patient information. This data can be used to help with research and planning.

What is confidential patient information?

Confidential patient information is when 2 types of information from your health records are joined together.

The 2 types of information are:

• Something that can identify you
• Something about your health care or treatment

For example, your name joined with what medicine you take.

Identifiable information on its own is used by health and care services to contact patients and this is not confidential patient information.

How we use your confidential patient information

Your individual care

Health and care staff may use your confidential patient information to help with your treatment and care. For example, when you visit your GP they may look at your records for important information about your health.

Research and planning

Confidential patient information might also be used to plan and improve health and care services research and develop cures for serious illnesses.

Your data your choice

You can stop your confidential patient information being used for research and planning. This is referred to as an opt-out. Any choice you make will not impact your individual care. If you set an opt-out choice, it is recorded against your NHS number on the Spine. It will remain unless you change your mind.

If you’re happy with your confidential patient information being used for research and planning you do not need to do anything.

Who must comply with the national data opt-out policy?

When you set a national data opt-out, organisations covered by the opt-out policy must make sure your opt-out choice is respected.

The national data opt-out covers confidential patient information collected about care in England. This includes:

• Publicly-funded, commissioned or coordinated health and adult social care
• Private care given in NHS settings

All organisations providing or coordinating publicly-funded health or adult social care in England will need to comply with the opt-out, even if the organisation’s headquarters are outside England. This includes private, voluntary sector and independent organisations and adult social care. Children’s social care services are not within scope of the policy.

For more information visit www.nhs.uk/your-nhs-data-matters

How do I opt-out?

Online

To change your consent preference online you must:

• Be aged 13 or older
• Have access to your email or mobile phone
• Have your NHS number or your postcode registered with your GP surgery

If you need your NHS number please contact us on 01509239166. You will be asked some questions to confirm your identity before we release this information to you.

Complete an online opt-out form

By Phone

You can also make or change a choice for yourself by phone – phone 0300 303 5678 on Monday to Friday, 9am to 5pm (excluding bank holidays)

By Post

Print a form to post (EXTERNAL PDF DOWNLOAD)

For someone else by post

Print a form to post (EXTERNAL PDF DOWNLOAD)

Make or change a choice for your children under the age of 13

Print a form to post (EXTERNAL PDF DOWNLOAD)

Make or change a choice for someone you can legally make decisions for

Print a form to post (EXTERNAL PDF DOWNLOAD)

1          Introduction

1.1         Policy statement

Woodbrook Medical Centre will ensure there is equitable access for all patients who wish to register with the organisation and will follow the GP Patient Registration Standard Operating Principles for Primary Medical Care outlined in the NHS Primary Medical Care Policy and Guidance Manual (PGM) (v4).

The registration process must be followed diligently. As detailed in the PGM, a patient does not need to be ordinarily resident in the country to be eligible for NHS primary medical care. Therefore, anybody in England may register and consult with a GP without charge and without producing any form of identity.

As stipulated in the PGM, it is a contractual requirement that, once registered, all patients must be invited to participate in a new patient health check. However, neither registration nor clinical appointments should be delayed because of the unavailability of a new patient health check appointment.

1.2         Status

The organisation aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the organisation and other individuals performing functions in relation to the organisation such as agency workers, locums, and contractors.

2          Patient registration

2.1         Registering the patient

Patients wishing to register with this organisation are to complete a GMS1 form or complete the online registration process which is detailed on the organisation’s website. Should the patient complete the online registration process, a supporting signed letter from the patient, posted or emailed to the organisation, is acceptable to complete the registration (i.e., patient signature).

Note, NHS Digital have developed Register with a GP surgery which enables this organisation to take patient registrations online quickly and easily. This standardises the online registration process throughout England.

2.2         Requesting documentary information from patients

Section 4.9.1 of the PGM explains that this organisation cannot refuse an application to join its list on the grounds of race, gender, social class, age, religion, sexual orientation, appearance, disability or medical condition.

Additionally, there is no regulatory requirement to provide identity, address, immigration status or the provision of an NHS number to register with the organisation. However, there are practical reasons why this organisation might need to be assured that people are who they say they are, or to check where they live. Seeing some form of ID will help to ensure the correct matching of a patient to the NHS central patient registry, thereby ensuring any previous medical notes are transferred.

Should this organisation request documentation to verify a patient’s identity or immigration status, then the organisation must ensure the same process is applied to all patients requesting registration. This organisation must not expect a patient to present a photograph as this could be discriminatory.

It must be acknowledged that while most patients will not find it difficult to produce ID, there will be some patients who live in the practice area but are legitimately unable to produce any documentation. Examples are detailed within the PGM at section 4.9.6.

2.3         Declining applications

The organisation is permitted to decline a patient’s application to join the practice if:

• The commissioner agrees that the organisation list may be closed to new patients

• There are reasonable grounds to do so, e.g., the patient has previously been removed from the organisation list

Any refusals will be confirmed in writing to the patient, with the reasons fully stated, within 14 days of the refusal. The date and reason for refusal will be recorded along with the name of the patient and this information will be made available to commissioners if requested.

2.4         Practice areas

The PGM explains that all organisations are required to have agreed an inner boundary with their commissioner. Anyone residing within this area is entitled to apply to register for primary medical services and the organisation boundary must be clearly advertised to patients on the organisation’s information leaflet and/or website.

The organisation has also agreed an outer boundary. Patients who move from the inner boundary area but still reside in the outer boundary area may be able to remain registered with the organisation should they so wish and the organisation agrees.

The PGM further advises that this organisation may register new patients who live outside the organisation area, without any obligation to provide home visits or services out of hours. It is for the organisation to decide, at the point of registration, whether it is clinically appropriate and practical to register the individual patient in that way.

2.5         Registering for online services

It should be noted that while there is no requirement for ID when initially registering at this organisation, this should not be confused with those patients who wish to have access to online services.

2.6         Registering children

The same registration process should be followed when registering children (0 – 18 years of age). However, there are certain circumstances that this organisation should be aware of in relation to safeguarding guidance.

As detailed in the PGM, if a child under the age of 16 attempts to register alone, or with an adult who does not have parental responsibility, the safeguarding lead should be alerted.

It is recommended that the organisation gains assurance by:

• Obtaining proof of identify for each child (i.e., birth certificate)

• Ensuring that an adult with parental responsibility is present at registration (and that the adult can prove they have parental responsibility)

• Offering the child a new patient health check

• Obtaining supporting documentation from official sources, e.g., previous GP, social workers, etc.

When doubt exists, the organisation’s safeguarding lead is to be informed and appropriate actions taken.

2.7         Registration of those previously registered with Defence Medical Services

When service personnel leave the armed forces, they become veterans and their primary healthcare reverts to the responsibility of the local NHS. Veterans will be provided with copies of their medical records which they will give to their new practice during registration.

Armed Forces veterans are entitled to priority treatment if their injury or condition came about because of their service (subject to clinical need). This is regardless of whether they receive a war pension. Further guidance can be found here and within the Priority treatment for veterans document. Prior service should be recorded on registration and allocated the correct SNOMED code:

Military veteran SCTID: 753651000000107. Having this code will enable access to specialist care or charity support as necessary for the patient.

2.8         Registration of civil servants, their dependants and the dependants of members of the Armed Forces returning from overseas service

Comprehensive guidance regarding the registration of civil servants posted overseas, their relevant family members who accompanied them on their posting and relevant family members who have accompanied a member of the Armed Forces posted overseas is detailed within the PGM at section 4.15. This includes enabling such individuals to register as a permanent or temporary patient in advance of or upon their return to the UK.

2.9         Registering Commonwealth, Gurkha or Nepali veterans

NHS England advises the following veterans are not entitled to receive free healthcare from the NHS after their discharge date from the UK Armed Forces:

• A citizen of a member of the Commonwealth
• A Gurkha citizen
• A Nepali citizen

In order to receive free healthcare through the NHS after this date, these groups must gain indefinite leave by using the immigration rules and process.

2.10       Registering asylum seekers, refugees and other migrants

As detailed in CQC GP Mythbuster 36: Registration and treatment of asylum seekers, refugees and other migrants, this organisation has a contractual duty to provide emergency and immediately necessary treatment free of charge for everyone.

This includes groups of patients whose circumstances may make them vulnerable such as asylum seekers, refugees and other vulnerable migrants. It should be noted that the CQC will inspect the organisation to ensure that the fundamental standards relating to patient equality are being upheld within both:

• Regulation 10 – treating people with dignity and respect
• Regulation 13 – protecting people from abuse and improper treatment

Additional guidance is available from NHS England on how to improve access for specific groups and how to register with a GP surgery.

PCSE provides guidance on patient registration and re-registration, including advice on how to register a refugee from Afghanistan. Furthermore, Public Health England has published the online migrant health guide which covers entitlement and other health issues.

2.11       Registering a homeless patient

This organisation will adhere to the guidance outlined in CQC GP Mythbuster 29: Looking after homeless patients in General Practice and allow any homeless patient to register by using either a temporary address such as a friend’s address or a day centre. Furthermore, this vulnerable group can also use the practice address to register as a method of contact is required, for example, should they need to be advised of a secondary care appointment or test results.

This organisation will consider the homeless community and has established the following:

• Provision of double appointments
• Reducing prescriptions to as short a duration as possible
• Promoting clear boundaries for consultations
• Providing fast access to a named GP
• Waiving normal charges for housing letters or medical reports

2.12       Duty to refer a homeless patient

The Homelessness Reduction Act (2017) places renewed emphasis on homelessness prevention and Section 10 requires public authorities in England to notify a local housing authority (LHA) of service users who they think may be homeless or at risk of becoming homeless.

While it is not mandatory for any GP practice to have any duty to refer to a LHA for further support, it would be beneficial to do so.

Any referrals to a LHA must include:

• The service user’s name
• Any contact details
• An agreed reason for referring the user

It should be noted that organisations can refer without consent to safeguard children and vulnerable adults.

For further advice, refer to the governmental guidance titled A guide to the duty to refer. Additionally, further resources for healthcare professionals on homelessness can be found within GP Mythbuster 29.

2.13       Registering under the Mental Capacity Act

The Mental Capacity Act 2005 is designed to protect and empower people aged over 16 who are unable to make decisions about their care and treatment.

If a person is unable to register with a GP because they cannot make decisions about their care, registration can be done by:

• A relative
• The main carer
• A lasting power of attorney
• A person appointed by a court under the Mental Capacity Act

Further reading can be sought from the NHS document titled Mental Capacity Act and the Mental Capacity Act Policy.

2.14       Rights to treatment and services

People who are not ‘ordinarily resident’ may be charged for some NHS services and the NHS (Charges to Overseas Visitors) Regulations 2015 apply to all courses of treatment commenced on or after 6 April 2015.

As detailed in the PGM at 4.4.5, this organisation is required to provide all new patients with a revised GMS1 form which includes supplementary questions to determine a patient’s eligibility for healthcare.

For those patients who self-declare that they hold either a non-UK issued EHIC or a S1 form, the organisation is required to manually record that the patient holds either a non-UK issued EHIC or S1 form in the patient’s medical record and then email the form and supplementary questions to NHS Digital (for non-UK issued EHIC cards) or the Overseas Healthcare Team (for S1 forms). Non-UK EHIC: nhsdigital.costrecovery@nhs.net and S1 forms OHT.overseasvisitorsteam@dwp.gsi.gov.uk

Further information can be sought from the following Gov.uk documents:

• Healthcare for visitors to the UK from the EU
• Pay for UK healthcare as part of your immigration application
• How to access NHS services in England if you are visiting from abroad

This organisation will refer overseas visitors when a referral is clinically appropriate.

If it is considered that a charge will apply for treatment following a referral, the referral should still be made to enable the secondary care clinical teams to decide if treatment is urgent and therefore should be provided in advance of payment.

This organisation will ensure that patients are made aware that they may be charged for treatment for which they are to be referred by using the Overseas NHS visitors: implementing the charging regulations.

2.15       Temporary residents

The PGM explains that patients should be offered the option of registering as a temporary resident if they are resident in the practice area for more than 24 hours but less than three months.

In some cases, a prospective patient may not know how long they will reside in an area, for example, destitute asylum seekers housed in temporary Home Office commissioned “initial” accommodation. Generally, in such cases when there is uncertainty over the length of time that a patient may be residing in an area but this is likely to be months rather than weeks, NHS England advises that the patient should be registered as a permanent patient.

Further information regarding temporary residents can be found in the useful NHS patient document titled How do I register as a temporary resident with a GP?

2.16    Immediately necessary treatment

As detailed in the PGM, this organisation is under a duty to provide emergency or immediately necessary treatment, when clinically necessary, irrespective of nationality or immigration status. The organisation is to provide 14 days of further cover following the provision of immediate and necessary treatment.

2.17    Registering patients released from prisons, immigration centres or children’s secure facilities

Patients who do not have a registered GP or who are being released to this area, have the ability to register with this organisation prior to leaving the detained estate. This agreement includes the transfer of clinical information, including medication history and substance misuse management plans to this organisation, to enable the appropriate level of care to be delivered when the patient first presents at this organisation.

3          New patient health check

3.1         Overview

It is a contractual requirement that this organisation invites newly registered patients to participate in a new patient health check. The purpose of this is to discuss any existing conditions with the patient while also taking the opportunity to review the patient’s lifestyle and make recommendations through evidence-based advice to improve the lifestyle of the patient.

3.2          Patient invitation

Patients will be invited to attend a new patient health check when they register with the organisation. Ideally, this appointment will be arranged for a date within one month of the patient registering at the organisation.

Patients are to be advised that they can be seen by a GP or nurse prior to this check but will still need to attend the original appointment for the check as planned. All staff are to ensure that they accurately record invitations and use the appropriate SNOMED/read code for a new patient health check in each patient’s healthcare record.

4          The NHS Health Check

4.1         Overview

The NHS Health Check best practice guidance document explains that the NHS Health Check is a prevention programme that aims to reduce the chance of a heart attack, stroke or developing some forms of dementia in people aged 40-74. It achieves this by assessing the top seven risk factors driving the burden of non-communicable disease in England, and by providing individuals with behavioural support and, where appropriate, pharmacological treatment. All eligible patients are to be offered an NHS Health Check once every five years.

Full guidance on eligibility, tests, risk assessments, clinical risk management and communication, including marketing and branding for the checks can be found in the hyperlinked guidance document. Health questionnaire templates can be found at Annex A for adults and Annex B for children.

4.2         Increasing uptake of the NHS Health Checks

Ideas for increasing the uptake of NHS Health Checks are to be found in Public Health England’s Top tips for increasing the uptake of NHS Health Checks.

There is also a useful guide regarding low-cost ways to increase NHS Health Check attendance as a result of a randomised trial which personalises the invitation letter and the use of text messages to support it. The template for the National NHS Health Check invitation letter can be found here.

Should a patient not respond, a follow-up letter is to be sent one week later. Again, this is to be recorded in the individual’s healthcare record and the appropriate SNOMED/read code used. Patients are to receive three recall letters and, should they fail to respond, this should be recorded within the patient’s healthcare record and SNOMED/read coded accordingly.

Staff may invite patients for the NHS Health Check via telephone or text (if applicable). All invitations are to be recorded in the patient’s healthcare record and coded with the appropriate SNOMED/read code.

4.3         Additional resources

Further resources such as appointment cards, flyers and templates can be found here.

Please refer to the Health Questionnaire form here

1 Introduction

1.1 Policy statement

The purpose of this policy is to provide staff at Woodbrook Medical Centre with guidance and rules regarding the following:

• a. Understanding what to do when an unacceptable social media post has been placed by a patient about either the practice or its staff
• b. The acceptable use of mobile phones and other portable electronic devices within Woodbrook Medical Centre

This document has been produced to help all staff and patients to recognise the need to understand and uphold obligations as deemed appropriate and in accordance with the NHS Constitution. Whilst all persons have a freedom to express their opinion, staff have an
obligation to ensure that concerns regarding unsafe practice, fraud or wrongdoings are managed as per the Freedom to Speak Up Policy and Procedure. Additionally, all staff have a fiduciary duty to their employer, and that loyalty is expected when placing any social media
post. This is further detailed within the Communication Policy.

Should there be any concerns regarding the level of care or treatment received, patients may only complaint via the Complaints procedure and in a manner that conforms to extant guidance in common with other NHS organisations. Raising any grievance via social media
does not conform to the legislation and as such will not be considered to be a complaint.

In addition to the above linked policies, this document is to be read in conjunction with the following:

• Access to Medical Records Policy
• Audio, Visual and Photography Policy
• Caldicott and Confidentiality Policy
• Dealing with Unreasonable, Violent and Abusive Patients Policy
• UK General Data Protection Regulation (UK GDPR) Policy

1.2 Status

Woodbrook Medical Centre aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been
given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of Woodbrook Medical Centre and other individuals performing functions in relation to Woodbrook Medical Centre such as agency workers, locums and contractors.

2 Principles of social media posts

2.1 Patient access to information

At Woodbrook Medical Centre, we wish to ensure that our patients have access to current and relevant information. Therefore, in addition to our website, we post information on social media platforms.

Staff are not permitted to use any of Woodbrook Medical Centre’s social media platforms to make any unrelated posts. To prevent inappropriate usage of the platform(s), access will be limited to named persons, with any post having been approved prior to publishing.
Furthermore, Woodbrook Medical Centre will also monitor social media platforms for comments and feedback

Any information posted is to be specific to Woodbrook Medical Centre. Under no circumstances is clinical information to be transmitted on any social media site, even if responding to a specific question that has already outlined any diagnosis or treatment.

Detailed guidance can be sought from the BMA guidance titled Social media, ethics and professionalism regarding the ethics and use of social media.

2.2 Social media ‘friend’ request by a patient

Should any patient send a ‘friend’ request over a social media platform then the above BMA advice should be considered.

Guidance can be sought within the GMC document titled Doctors’ use of social media, and although this section is written with GPs in mind, all staff should be cautious when accepting a ‘friend’ request from a patient, and be mindful that professionalism and high standards are expected from all, regardless of whether they are at work or not.

Refer to the Communication Policy for further advice on this subject.

2.3 Inappropriate postings by a patient

All staff are requested to remain vigilant whilst visiting any social media site especially surrounding any detrimental comment being placed about Woodbrook Medical Centre or any of our staff.

The BMA provides advice on this subject in their document titled Dealing with abuse of practice staff on social media from patients.

To protect reputations, should there be an instance of inappropriate information upon a social media site, then a member of the management team is to be informed at the earliest opportunity.

The following links provide information on how some inappropriate posts can be deleted:

• Facebook (post)
• LinkedIn (feed)
• X (post)
• Instagram (post)

Should it not be possible to remove a post, such as when the post has been added from a patient’s social media account, then Woodbrook Medical Centre will contact the author of the post to request that the post or feed be removed.

Legislation to support this subject can be found within:

• Protection from Harassment Act 1997
• Malicious Communications Act 1988
• Communications Act 2003

2.4 Should the patient not be willing to remove the post

Should the patient not be willing to remove an inappropriate or factually incorrect post, then the Partners and the Practice Manager will consider the options. This may include contacting the Defence Union both for advice and to confirm the process to be followed. Note,
Woodbrook Medical Centre could bring a claim on the basis that the publication amounts both to a misuse of their private information and a breach of Article 5 of the UK General Data Protection Regulations (UK GDPR) and as detailed within the UK General Data Protection
Regulation (UK GDPR) Policy.

If the person is not prepared to remove the post, and should this be unfounded, malicious or unreasonable against Woodbrook Medical Centre or any staff member, then they should be advised that, whilst Woodbrook Medical Centre welcomes feedback, comments such as this are not considered to be constructive. The patient should also note that this also explicitly compromises their requirements as detailed within the NHS Constitution – Patients and the public: your responsibilities.

Should the above actions have been taken, but the patient(s) continues to be unwilling to remove any unfounded, malicious or unreasonable social media post against Woodbrook

Medical Centre or its staff, it could be suggested that the patient-doctor relationship has broken down in accordance with the GMC’s guidance within Good Medical Practice.

In addition to the GMC guidance, additional resources to manage the removal of a patient can be found within the following:

• MDU: Managing patients for a GP practice list
• Dealing with Unreasonable, Violent and Abusive Patients Policy
• Removal of Patients Policy
• Respect our staff poster

It should be noted that, justifiably, patients should not be removed due to a complaint. Should the post be a complaint in nature, or should it refer to an ongoing complaint, the Complaints Lead will contact the patient to give them the opportunity to follow the correct complaint
pathway within the Complaints procedure. A complaint leaflet will also be offered outlining the process.

At this stage, it should be agreed that the patient removes the offending post, as failing to do so is detrimental to the patient/doctor relationship as detailed above.

All staff have a responsibility to be aware of the expectations placed upon our patients, and that unacceptable behaviour will not be tolerated and will be managed accordingly.

3 Patient recordings within the practice

3.1 Patients requesting to record their consultation

Whilst it is acceptable for a patient to overtly record the consultation if permission has been sought, should this not have been sought, then the BMA guidance above can be followed. Should a patient request to make a recording, then the following is to be agreed to enable the
recording:

• All recordings are requested and carried out in an open and honest manner and do not interfere with the consultation or treatment
• At the end of the consultation, the clinician might suggest that the patient provides a copy of the recording to be added to their healthcare record and form a permanent record of the consultation
• An entry will be made within the patients’ health record, with the SNOMED CT code:
  Audio recording of subject interview 431315003 being used. The entry should state that the patient has recorded the consultation or care being provided
• The patient should be reminded of the private and confidential nature of the recording and that it is their responsibility to keep it safe and secure
• The recording is only made for personal use. Patients are to be made aware that the misuse of a recording may result in criminal or civil proceedings

3.2 Overt patient recordings

A patient wishing to covertly record a consultation or conversation with any healthcare professional raises concerns as to the reason or intentions for doing so.

Should it become apparent that a covert recording is occurring, then the patient will be discouraged from doing so by the following actions being taken:

• An open and honest recording of consultations will be promoted where a patient deems this to be absolutely necessary
• To avoid a patient feeling the necessity to record any consultation, we will highlight the fact that we will always take proactive steps to investigate and address any issues regarding any patient’s treatment and care
• Clinical staff should consider providing patients with a written summary of their consultation for their own personal use
• Patients are advised that they are entitled to see their medical record and, if they wish to do so, they should request this through a Subject Access Request (SAR) made under the Data Protection Act 2018 in accordance with the Access to Medical Records Policy
• Patients are given information about how they can complain if they have an issue with their treatment and care. The complaints leaflet can be found within the Complaints procedure

Further advice can be sought from:

• MDU: Patients recording consultations
• Pulse: Can I stop a patient recording our consultation?
• BMJ: My patient wants to record our consultation, what should I do?

Requirements are detailed within the Patient Social Media Guidance at Annex A.

3.3 Patients posting their consultation recording online

Should any consultation be posted online, then the BMA has produced a letter template requesting its removal.

3.4 Use of audio-visual recording within public areas of the practice

Patients should not photograph, video or use sound recording that captures any other patient that could identify that they have been at the practice, as this affects their right to confidentiality as detailed within the Caldicott and Confidentiality Policy.

It should be noted that all patients have privacy rights, and no recording of other patients can be made without their explicit consent. Likewise, no member of the public can photograph or make either a video or audio recording of any member of staff without the express permission of that person.

Any such recording is likely to be an interference with their privacy rights under Article 8 of the European Convention on Human Rights and this may constitute a criminal offence or a data breach depending on the context of the disclosure.

Further information can be found in the BMA document titled Patients recording consultations and the Audio, Visual and Photography Policy.

1           Introduction

1.1      Policy statement

The purpose of this policy is to provide staff at Woodbrook Medical Centre with guidance and rules regarding the following:

1. Understanding what to do when an unacceptable social media post has been placed by a patient about either the practice or its staff

1. The acceptable use of mobile phones and other portable electronic devices within Woodbrook Medical Centre

This document has been produced to help all staff and patients to recognise the need to understand and uphold obligations as deemed appropriate and in accordance with the NHS Constitution. Whilst all persons have a freedom to express their opinion, staff have an obligation to ensure that concerns regarding unsafe practice, fraud or wrongdoings are managed as per the Freedom to Speak Up Policy and Procedure. Additionally, all staff have a fiduciary duty to their employer, and that loyalty is expected when placing any social media post. This is further detailed within the Communication Policy.

Should there be any concerns regarding the level of care or treatment received, patients may only complaint via the Complaints procedure and in a manner that conforms to extant guidance in common with other NHS organisations. Raising any grievance via social media does not conform to the legislation and as such will not be considered to be a complaint.

in addition to the above linked policies, this document is to be read in conjunction with the following:

• Access to Medical Records Policy
• Audio, Visual and Photography Policy
• Caldicott and Confidentiality Policy
• Dealing with Unreasonable, Violent and Abusive Patients Policy
• UK General Data Protection Regulation (UK GDPR) Policy

1.2      Status

Woodbrook Medical Centre aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of Woodbrook Medical Centre and other individuals performing functions in relation to Woodbrook Medical Centre such as agency workers, locums and contractors.

2          Principles of social media posts

2.1      Patient access to information

At Woodbrook Medical Centre, we wish to ensure that our patients have access to current and relevant information. Therefore, in addition to our website, we post information on social media platforms.

Staff are not permitted to use any of Woodbrook Medical Centre’s social media platforms to make any unrelated posts. To prevent inappropriate usage of the platform(s), access will be limited to named persons, with any post having been approved prior to publishing. Furthermore, Woodbrook Medical Centre will also monitor social media platforms for comments and feedback

Any information posted is to be specific to Woodbrook Medical Centre. Under no circumstances is clinical information to be transmitted on any social media site, even if responding to a specific question that has already outlined any diagnosis or treatment.

Detailed guidance can be sought from the BMA guidance titled Social media, ethics and professionalism regarding the ethics and use of social media.

2.2      Social media ‘friend’ request by a patient

Should any patient send a ‘friend’ request over a social media platform then the above BMA advice should be considered.

Guidance can be sought within the GMC document titled Doctors’ use of social media, and although this section is written with GPs in mind, all staff should be cautious when accepting a ‘friend’ request from a patient, and be mindful that professionalism and high standards are expected from all, regardless of whether they are at work or not.

Refer to the Communication Policy for further advice on this subject.

2.3      Inappropriate postings by a patient

All staff are requested to remain vigilant whilst visiting any social media site especially surrounding any detrimental comment being placed about Woodbrook Medical Centre or any of our staff.

The BMA provides advice on this subject in their document titled Dealing with abuse of practice staff on social media from patients.

To protect reputations, should there be an instance of inappropriate information upon a social media site, then a member of the management team is to be informed at the earliest opportunity.

The following links provide information on how some inappropriate posts can be deleted:

• Facebook (post)
• LinkedIn (feed)
• X (post)
• Instagram (post)

Should it not be possible to remove a post, such as when the post has been added from a patient’s social media account, then Woodbrook Medical Centre will contact the author of the post to request that the post or feed be removed.

Legislation to support this subject can be found within:

• Protection from Harassment Act 1997
• Malicious Communications Act 1988
• Communications Act 2003

2.4      Should the patient not be willing to remove the post

Should the patient not be willing to remove an inappropriate or factually incorrect post, then the Partners and the Practice Manager will consider the options. This may include contacting the Defence Union both for advice and to confirm the process to be followed. Note, Woodbrook Medical Centre could bring a claim on the basis that the publication amounts both to a misuse of their private information and a breach of Article 5 of the UK General Data Protection Regulations (UK GDPR) and as detailed within the UK General Data Protection Regulation (UK GDPR) Policy.

If the person is not prepared to remove the post, and should this be unfounded, malicious or unreasonable against Woodbrook Medical Centre or any staff member, then they should be advised that, whilst Woodbrook Medical Centre welcomes feedback, comments such as this are not considered to be constructive. The patient should also note that this also explicitly compromises their requirements as detailed within the NHS Constitution – Patients and the public: your responsibilities.

Should the above actions have been taken, but the patient(s) continues to be unwilling to remove any unfounded, malicious or unreasonable social media post against Woodbrook Medical Centre or its staff, it could be suggested that the patient-doctor relationship has broken down in accordance with the GMC’s guidance within Good Medical Practice.

In addition to the GMC guidance, additional resources to manage the removal of a patient can be found within the following:

• MDU: Managing patients for a GP practice list
• Dealing with Unreasonable, Violent and Abusive Patients Policy
• Removal of Patients Policy
• Respect our staff poster

It should be noted that, justifiably, patients should not be removed due to a complaint. Should the post be a complaint in nature, or should it refer to an ongoing complaint, the Complaints Lead will contact the patient to give them the opportunity to follow the correct complaint pathway within the Complaints procedure. A complaint leaflet will also be offered outlining the process.

At this stage, it should be agreed that the patient removes the offending post, as failing to do so is detrimental to the patient/doctor relationship as detailed above.

All staff have a responsibility to be aware of the expectations placed upon our patients, and that unacceptable behaviour will not be tolerated and will be managed accordingly.

3          Patient recordings within the practice

3.1      Patients requesting to record their consultation

Whilst it is acceptable for a patient to overtly record the consultation if permission has been sought, should this not have been sought, then the BMA guidance above can be followed. Should a patient request to make a recording, then the following is to be agreed to enable the recording:

• All recordings are requested and carried out in an open and honest manner and do not interfere with the consultation or treatment

• At the end of the consultation, the clinician might suggest that the patient provides a copy of the recording to be added to their healthcare record and form a permanent record of the consultation

• An entry will be made within the patients’ health record, with the SNOMED CT code: Audio recording of subject interview 431315003 being used. The entry should state that the patient has recorded the consultation or care being provided

• The patient should be reminded of the private and confidential nature of the recording and that it is their responsibility to keep it safe and secure

• The recording is only made for personal use. Patients are to be made aware that the misuse of a recording may result in criminal or civil proceedings

3.2      Overt patient recordings

A patient wishing to covertly record a consultation or conversation with any healthcare professional raises concerns as to the reason or intentions for doing so.

Should it become apparent that a covert recording is occurring, then the patient will be discouraged from doing so by the following actions being taken:

• An open and honest recording of consultations will be promoted where a patient deems this to be absolutely necessary

• To avoid a patient feeling the necessity to record any consultation, we will highlight the fact that we will always take proactive steps to investigate and address any issues regarding any patient’s treatment and care

• Clinical staff should consider providing patients with a written summary of their consultation for their own personal use

• Patients are advised that they are entitled to see their medical record and, if they wish to do so, they should request this through a Subject Access Request (SAR) made under the Data Protection Act 2018 in accordance with the Access to Medical Records Policy

• Patients are given information about how they can complain if they have an issue with their treatment and care. The complaints leaflet can be found within the Complaints procedure

Further advice can be sought from:

• MDU: Patients recording consultations
• Pulse: Can I stop a patient recording our consultation?
• BMJ: My patient wants to record our consultation, what should I do?

Requirements are detailed within the Patient Social Media Guidance at Annex A.

3.3      Patients posting their consultation recording online

Should any consultation be posted online, then the BMA has produced a letter template requesting its removal.

3.4      Use of audio-visual recording within public areas of the practice

Patients should not photograph, video or use sound recording that captures any other patient that could identify that they have been at the practice, as this affects their right to confidentiality as detailed within the Caldicott and Confidentiality Policy.

It should be noted that all patients have privacy rights, and no recording of other patients can be made without their explicit consent. Likewise, no member of the public can photograph or make either a video or audio recording of any member of staff without the express permission of that person.

Any such recording is likely to be an interference with their privacy rights under Article 8 of the European Convention on Human Rights and this may constitute a criminal offence or a data breach depending on the context of the disclosure.

Further information can be found in the BMA document titled Patients recording consultations and the Audio, Visual and Photography Policy.

Annex A – Patient social media guidance

Patient Social Media Guidance

At Woodbrook Medical Centre we have a Facebook and Instagram page which provides a range of useful information for our patient population.

This practice has a duty to maintain patient confidentiality and to safeguard vulnerable patients. You can help us to achieve this by adhering to the code of conduct outlined in this guidance.

Patients at Woodbrook Medical Centre are expected to always adhere to the following code of conduct:

1. Woodbrook Medical Centre requires all users of portable devices to use them in a courteous and considerate manner, respecting their fellow patients. Portable devices are not to be used during consultations, except when agreed with your clinician.

2. Patients are not permitted to disclose any patient-identifiable information about other patients unless they have the express consent of that patient.

3. Whilst not encouraged, patients may record their consultation but this should be agreed with your clinician. This recording will solely be for your own purpose.

4. Patients must not post any material that is inaccurate, fraudulent, harassing, embarrassing, obscene, defamatory or unlawful. Any such posts on the Woodbrook Medical Centre Facebook and Instagram pages will be deleted and the post reported.

5. Patients are not permitted to take photographs in the waiting room or areas where other patients are present, nor are photographs of staff permitted to be taken.

6. Patients must not post comments on social media that identify any staff.

7. Patients can leave a review about the practice and the following Woodbrook Medical Centre can enable the practice manager to respond appropriately.

8. Defamatory comments about our team are not to be shared on any social media platform. Legal advice may be sought and the appropriate action taken against any patient who posts defamatory comments.

Patient complaints on social media

We have a separate complaints policy which patients are to use should they wish to make a complaint. We will only respond to complaints made to the Woodbrook Medical Centre in accordance with the Woodbrook Medical Centre’s policy.

If a complaint is made on the Woodbrook Medical Centre’s Facebook and/or Instagram page, it will be deleted.

We aim to maintain and improve the quality, quantity and effectiveness of services to our patients, providing access to a high standard and comprehensive primary health care.

We aim to improve the quality of life of our patients by providing screening, education and promotion of good health allowing patients to influence their own future. Our fully computerised service will provide a regular recall system for all preventative care and aid evaluation of all aspects of health care.

We shall continually assess our service making innovative changes in response to patients needs and views our aim is to improve the quality and range of our services to reduce reliance on secondary care eg hospital and community care, but when this is needed, to ensure adequate and improved access to these services.

We shall ensure that the elderly and disadvantaged receive the community and health care needed to maximise their ability to remain independent preferably in their own homes.

These services will be delivered by the primary health care team of doctors, health visitors, nurses and surgery staff. They will communicate at regular team meetings and are supported by practice policy and protocols. Requirements of the primary health care team for rest, recuperation and education are of prime importance and contribute to the satisfactory running of the practice as a whole.

Language Difficulties

If patients require the use of an interpreter, this can be arranged. This service may be conducted in person or by telephone. Please note it can take up to a week to find a suitable interpreter, so please contact us in plenty of time if this service is required.

GP Earnings

The average pay for GPs working in Woodbrook Medical Centre during the previous financial year was £90,228 before tax and national insurance. This is for 0 full time GPs, 7 part time GPs and 1 locum GP who worked in the practice for more than 6 months.

Appointment punctuality policy (V1.2)

Identification of carers policy (V1.5)

1 Introduction

1.1 Policy statement

This policy details the requirements that Woodbrook Medical Centre has to consider prior to the removal of a patient from the organisation list in line with extant legislation, including The National Health Service (General Medical Services Contracts) Regulations 2015 (Part 2, Para 23-25), NHS England’s Primary Medical Care Policy and Guidance Manual, and the referenced publications.

1.2 Status

The organisation aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have regarding the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are non-contractual and may be modified or withdrawn at any time. For the avoidance of doubt, it does not form part of your contract of employment. Furthermore, this document applies to all employees of the organisation and other individuals performing functions in relation to the organisation such as agency workers, locums and
contractors.

2 Death of a patient

2.1 Patients who have died

PCSE explain that when a patient dies, their death is recorded by the General Registry Office. This generates a deduction on the organisation’s clinical system.

Further information can be found in the organisation’s Death of a Patient and Bereavement Policy.

3 Patient moving from practice area

3.1 Choice of GP practice

When the patient has made a choice to move to another organisation, a notification of deduction will be received from PCSE. Notifications will be acted on in line with PCSE guidance and the patient deducted from the organisation list.

3.2 Out of area – request to remain registered

When a patient has moved out of the organisation’s outer boundary area but wishes to remain registered with this organisation, and the organisation remains content to treat them as an out of area patient, PCSE guidance is to be adhered to.

When continued registration is declined, the patient will be notified. A template letter detailing such notification can be found at Annex A.

3.3 Patients within the secure and detained estate

Patients detained within adult, child and young persons’ secure estates can register at their place of detention as detailed here, as this allows records to transfer via the GP2GP transfer policy.

It is accepted that this organisation may not be informed of a patient being imprisoned or the length of their sentence but, if this information is provided, the organisation has a duty to act by informing NHS England and moving to deduct the patient from the list.

3.4 Armed forces personnel

Medical care for serving personnel and mobilised reservists is provided for by the Defence Medical Services (DMS). The patient will still be entitled to treatment as a temporary resident should they find themselves residing too far away from a DMS GP.

When it is known that a patient has joined the armed forces on a full-time basis, the organisation will inform NHS England and deduct the patient from the organisation list as per PCSE guidance.

Armed forces reservists, who usually retain their civilian role for most of the year, are to remain on the organisation list as they only serve for limited periods of time.

NHS England provides additional information relating to Healthcare for the armed forces community.

3.5 Patients who are abroad for more than three months

When it is known that a patient has been absent from the UK for a period of more than three months, the organisation must exercise caution when deciding to apply to NHS England to have the patient removed from its list.

The organisation should determine if the patient has retained a sufficient connection to the UK to continue to be habitually resident here, thereby justifying that they remain on the organisation list. For example, it could be considered inappropriate to remove a patient from the organisation list who spends three months abroad but nine months of the year in the UK.

Patients will be referred to Planning your healthcare abroad for further guidance relating to eligibility for healthcare.

3.6 Movement of at-risk patients

At this organisation, the Safeguarding Lead for both adults and children will be responsible for ensuring that a register of all at-risk children, young people and adults is maintained. For further guidance, refer to The Safeguarding Handbook.

4 Patient not contactable – assumed moved

4.1 ‘Ghost’ patients

When, as part of their normal working, PCSE are made aware that the patient might no longer reside at the registered address, a FP69 flag will be raised on the National Health Application and Infrastructure Services (NHAIS) system and the organisation will be notified via the clinical system.

The organisation will attempt to contact the patient to confirm their address directly. When the patient has moved out of area, the patient will be advised to register with an alternative closer organisation and the patient deducted as per PCSE guidance.

Should PCSE not receive any confirmation from this organisation to confirm residence within six months of the FP69 flag being raised, the patient will be removed from the organisation list. When a letter is returned to PCSE or the organisation stating that the patient has ‘moved abroad’ or ‘deceased’, the appropriate action would be to confirm this status then deduct the patient.

For further guidance refer to PCSE’s Patient Removals.

5 Patient requesting to leave the practice

5.1 Patient registering with another practice

NHS England is compelled to deduct a patient from the organisation list if the patient registers with another GP practice in the UK.

5.2 End of temporary residence

If a patient has been a temporary resident for three months, they can be deducted from the organisation list without any further reason being given to NHS England.

6 Irretrievable breakdown in a relationship

6.1 Breakdown in a relationship

When removals due to a breakdown in a relationship are considered, reference should be made to the Dealing with Unreasonable, Violent and Abusive Patients Policy for full guidance and example template letters.

6.2 Requests for 8-day and immediate removal

A breakdown in a relationship would ordinarily require a request to PCSE for an 8-day removal. However, should any patient have been aggressive or violent resulting in the police having been called, then PCSE can be contacted and a request made that the patient is immediately removed to the Special Allocations Scheme (SAS).

For detailed information see PCSEs Patient Removals guidance.

7 Non-justified reasons for removal

7.1 Overview

This organisation will never remove a patient for any of the following reasons:

The patient has made a complaint

Medical conditions

Cost of treatment

Any of the protected characteristics

7.2 Removing family members

BMA guidance suggests that should the behaviour of one patient lead to their removal, this does not mean that the removal of other family or household members should automatically follow. An explicit discussion with other family members, while protecting the patient’s confidentiality, should take place.

However, where this leaves only minors registered at the practice, it is the practice’s policy to request that the minors are registered at their parent(s)’s new GP Practice.

Also, should there be a need to visit any patient at home where the excluded violent or threatening patient resides, to protect the welfare of our staff, we may require removing all family members who are within the household from the list. The process will consider whether it would be reasonable to exclude an entire household from the list following a disagreement with a single family member.

1          Introduction

1.1      Policy statement

This organisation must be able to demonstrate compliance at all times with the UK General Data Protection Regulation (UK GDPR herein), which is incorporated in the Data Protection Act 2018 (DPA18) at Part 2, Chapter 2. All staff must understand their responsibilities when accessing and processing personal data, ensuring they adhere to the data protection principles. A UK GDPR a checklist is available here