Being Open Policy
The concept of an open approach to communication of patient safety incidents to patients, families and carers was first introduced into the NHS in 2005, and was further reviewed in 2008.
An updated “Being Open” guidance has now been issued to build on this along with a Patient Safety Alert dated 19th November 2009 which outlines actions required by the NHS.
An open dialogue with patients or their representatives following an incident can ease the impact, stress and concern. An effective method of formalised, honest, timely and open communication with patients, their families and carers is a vital part of the process of dealing with patient safety incidents in healthcare, helping patients to accept mistakes and medical errors and reach a state of forgiveness more readily. It will also:
- Ensure that the communication with patients, their families and carers has been handled in the most appropriate way.
- Enable the clinician to develop a good professional reputation for handling difficult situations well.
- Improve the clinician’s understanding of incidents from the perspective of the patient, their family and carers.
There are a number of key markers to the success of a policy of openness with patients:
- There is clear guidance on the procedure.
- Offer an immediate apology.
- The original clinicians are involved in the resolution process.
- Clinicians or staff have good communication skills and are able to relate to the patient or families.
- There is a meaningful dialogue in which the concerns of the patient are respected and listened to.
- Patients and families can have confidence in the process.
- There is careful pre-planning, responsive disclosure, a proper system of follow-up and internal, as well as independent, counselling support.
Patient safety incidents can have major consequences for patients, their families and carers, and can similarly distressing for the clinicians involved. Being open and dealing with issues in the right way can help to prevent formal complaints legal action.
Steps in Implementing an Open Policy
1. Acknowledge the incident
Patient safety incidents should be acknowledged and reported as soon as they are identified.
In cases where the patient, their family and carers inform healthcare staff when something untoward has happened, it must be taken seriously from the outset. Any concerns should be treated with compassion and understanding by all clinicians.
The recognition that a patient has suffered harm or has died as a result of a patient safety incident is a major event and rare in primary care. The incident may however arise elsewhere as a result of care in the practice. The Being Open process and the investigation and analysis of a patient safety incident should normally occur in the healthcare organisation where the incident took place, and inter-care cooperation may be required.
Take immediate action to prevent of further harm or recurrence. Where additional treatment is required this should occur whenever reasonably practicable after a discussion with the patient and with appropriate consent.
2. Investigate the incident
Investigate in an open and non-threatening way. Encourage participation and document the findings.
The multidisciplinary team, including the most senior health professional involved in the patient safety incident, should meet as soon as possible after the incident to:
- Establish the clinical and other facts.
- Assess the incident to determine the level of immediate response.
- Nominate who will be responsible for discussion with the patient, their family and carers.
- Consider the appropriateness of engaging patient support at this early stage. This includes the use of a facilitator, a patient advocate or a healthcare professional who will be responsible for identifying the patient’s needs and communicating them back to the clinical team.
- Identify immediate support needs for the staff involved.
- Ensure there is a consistent approach by all team members around discussions with the patient, their family and carers.
3. Ensure truthfulness, timeliness and clarity of communication
Information about a patient safety incident must be given to patients, their families and carers in a truthful and open manner by an appropriately nominated person with appropriate skills. Patients should be provided with a clear explanation of what happened delivered in a timely, open and honest way. Patients and their families / carers should be provided with information about what happened as soon as practicable.
Any information given should be factual as known the time, and be updated as new information may emerge as the matter is investigated. Establish one point of contact – a staff member who will communicate with them on all aspects.
4. Apologise where you need to
Provide a face-to-face apology delivered by the most appropriate member of staff to patients, their families and carers as soon as possible. Consider both seniority and the relationship to the patient, and experience and expertise in the type of patient safety incident that has occurred when nominating an individual.
This should be the most senior person responsible for the patient’s care and/or someone with experience and expertise in the type of incident that has occurred. This could either be the patient’s own clinician or senior partner.
They should be:
- Known to, and trusted by, the patient, their family and carers.
- Have a sound knowledge of the incident.
- Be senior.
- Be able to offer an apology and an explanation of the facts.
- Be able to maintain a relationship with the patient or their family where possible.
The initial discussion is the first part of an ongoing communication process.
The patient, their family and carers should be advised of the identity and role of all people attending any open discussion beforehand, allowing them to state their own preferences about which staff they would prefer to be present, or omitted. The meeting may:
- Offer genuine sympathy and an apology.
- State the facts that are known as agreed by the multidisciplinary team. Where there is disagreement this may be deferred until further investigations have taken place.
- Take patient’s or family’s views into account.
- Ensure that communication and terminology are appropriate to the needs of the family, with jargon avoided.
- Give an explanation about what will happen next in the short through to long-term treatment plan and investigation.
- Give information on likely short and long-term effects of the incident. The long term effects may have to be considered later.
- Offer support for the patient, their family and carers. This may involve getting help from third parties such as charities and voluntary organisations, as well as offering more direct assistance.
Follow up discussions with the patient, their family and carers will be required as part of the Being Open process. A written record of each discussion should be maintained, and a copy provided to the patient’s representatives.
A written apology can follow, which clearly states the healthcare organisation is sorry for the suffering and distress resulting from the incident, and what the next steps are, and should be issued quickly.
5. Recognise patient / family expectations
Patients, their families and carers can reasonably expect to be fully informed of the issues surrounding a patient safety incident in a face-to-face meeting with a representative from the practice, and this should be facilitated. Determine what expectations they have in the resolution process.
They should be treated sympathetically, with respect and consideration, and should be offered support appropriate to their needs.
6. Professional support
Practices should encourage a culture where staff feel able to report patient safety incidents without worry. Staff should also feel supported throughout the incident investigation process as they may be suffering or stressed by the events.
Staff should not be unfairly exposed to punitive disciplinary action, increased medico-legal risk or any threat to their registration, however where there is potentially a reason to believe a member of staff has committed a punitive or criminal act, they should be advised at an early stage to enable them to obtain separate legal advice and/or representation, perhaps from a defence organisation. This may be done in a supportive and sensitive way and should not be accusative.
7. Risk Management and Systems Improvement
The practice Significant Event Procedure should be used to examine the underlying causes of a patient safety incident. These investigations should focus on improving systems of care and the discussion of learning points. Document the discussions and formalise changes to procedure. Communicate changes to the patient as part of the Openness policy.
8. Multidisciplinary Responsibility
All staff in the practice involved in patient care should be aware of the incident and the issues or changes arising. Major incidents often arise from a systems failure over a period of time or a culmination of minor lapses rather than from the single action of an individual.
Investigate and correct any deficiencies in practice systems or risk control measures which may have contributed to the error.
9. Clinical governance
Being open requires the support of clinical governance frameworks through which patient safety incidents can be investigated and analysed to find out what can be done to prevent their recurrence. These findings should be treated as learning points and discussed. Incorporate the risk and the resultant actions in the practice Risk Management Framework [*]
Policies and should comply with the patient’s, their family’s and carers’ rights, and also staff rights to privacy and confidentiality. Details of a patient safety incident should be considered as confidential. The consent of the individual concerned should be sought prior to disclosing information beyond the clinicians involved in treating the patient. Rules of confidentiality apply.
11. Continuity of care
Patients are entitled to expect that they will continue to receive all usual treatment and continue to be treated with dignity, respect and compassion. If a patient expresses a reference for their healthcare needs to be taken over by another team, the appropriate arrangements should be made for them to receive treatment elsewhere.
An open culture
A culture of openness is where:
- Staff are open about incidents they have been involved in.
- Staff are accountable for their actions.
- Staff feel able to talk to their colleagues about an incident.
- Organisations are open with patients, the public and staff when things have gone wrong and explain what lessons will be learned.
- Staff are treated fairly and are supported when an incident happens.
It is important to consider the emotions bereaved relatives. The patient’s family and carers will probably need information on the processes that will be followed to identify the cause(s) of death.
Establishing open channels of communication may also allow the family and/or carers to indicate if they need bereavement counselling or assistance at any stage.
The Being Open discussion and any investigation may occur a coroner’s inquest, but consider whether it may be better to wait until after the coroner’s report, to help focus on the facts of the incident.
Relationships with the family may break down as a result of a perceived error. They may not accept information and may refuse to be involved in any discussion:
- Attempt to deal with this as soon as possible.
- Involve family where you can.
- Provide details of support services.
- Use an alternative clinician to mediate, e.g. another partner or external PCO or PALS liaison.
- Provide details of the formal NHS complaints procedure.
Care Quality Commission
The Care Quality Commission (CQC) makes sure hospitals, care homes, dental and GP surgeries, and all other care services in England provide people with safe, effective, compassionate and high-quality care, and encourages them to make improvements where possible.
They do this by inspecting services and publishing the results on their website: www.cqc.org.uk
You can use the results to help you make better decisions about the care you, or someone you care for, receives.
Our CQC Inspection
Our practice is inspected by the Care Quality Commission (CQC) to ensure we are meeting essential standards of quality and safety.
This widget provides a summary of the results of the latest checks carried out by the CQC.
You are very welcome to be accompanied by a trusted friend or relative at your consultation if you wish, and this is all the more important if English is not your first language, or if you feel you might not be able to express what you need clearly to the doctor or nurse.
In addition, for intimate examinations, you will be offered the choice of having another professional clinician present at the examination. This is called chaperoning.
As we are a small practice this might not be possible at all times. If we cannot allocate a chaperone when you wish one to be there, then we can reschedule your examination to another time.
At times you may be asked to complete a patient questionnaire in order to maintain our record of all patients. The computer requires good discipline in maintaining accurate records which is to everyone’s advantage and holds the key too many benefits, particularly in preventative medicine.
The practice is registered under the Data Protection Act 2018 and confidentiality will remain our prime concern. For routine audit purposes, representatives from the Clinical Commissioning Group or NHS England will be required to look at patients’ medical records.
The auditors may not be medically qualified but are all bound by their contract of employment to respect confidentiality. However, if you do not wish your notes to be used in this way, please inform us at the front desk and your notes will be annotated accordingly.
Insurance companies and solicitors will ask for access to your medical records in certain circumstances, e.g. mortgage applications and accidents. We will only release this information if we have your signed authority to do so. Equally, we will only release prescriptions, letters or any other information to relatives, neighbours or friends provided you have given your consent in writing to the practice first.
Under the Data Protection Act you have the right to get a copy or have sight of the information that is held about you. This is known as a subject access request. Please check the charge for this with the receptionist by completing our Ask Reception a Question form.
Covid-19 Privacy Notice
This Privacy Notice is to run alongside our standard Practice Privacy Notice.
Due to the unprecedented challenges that the NHS and we, Clement Road Medical Centre face due to the worldwide COVID-19 pandemic, there is a greater need for public bodies to require additional collection and sharing of personal data to protect against serious threats to public health.
In order to look after your healthcare needs in the most efficient way we, Clement Road Medical Centre may therefore need to share your personal information, including medical records, with staff from other GP Practices including Practices within our Primary Care Network, as well as other health organisations (i.e. Clinical Commissioning Groups, Commissioning Support Units, Local authorities etc.) and bodies engaged in disease surveillance for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
The Secretary of State has served notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) to require organisations to process confidential patient information in the manner set out below for purposes set out in Regulation 3(1) of COPI.
Purpose of this Notice
The purpose of this Notice is to require organisations such as Clement Road Medical Centre to process confidential patient information for the purposes set out in Regulation 3(1) of COPI to support the Secretary of State’s response to Covid-19 (Covid-19 Purpose). “Processing” for these purposes is defined in Regulation 3(2) and includes dissemination of confidential patient information to persons and organisations permitted to process confidential patient information under Regulation 3(3) of COPI. This Notice is necessary to require organisations such as Clement Road Medical Centre to lawfully and efficiently process confidential patient information as set out in Regulation 3(2) of COPI for purposes defined in regulation 3(1), for the purposes of research, protecting public health, providing healthcare services to the public and monitoring and managing the Covid-19 outbreak and incidents of exposure.
Requirement to Process Confidential Patient Information
The Secretary of State has served notice to recipients under Regulation 3(4) that requires Clement Road Medical Centre to process confidential patient information, including disseminating to a person or organisation permitted to process confidential patient information under Regulation 3(3) of COPI, renewed 01 July 2022 until 31 October 2022.
Clement Road Medical Centre is only required to process such confidential patient information:
- where the confidential patient information to be processed is required for a Covid-19 Purpose and will be processed solely for that Covid-19 Purpose in accordance with Regulation 7 of COPI
- from 01 July 2022 until 31 October 2022.
A Covid-19 Purpose includes but is not limited to the following:
- understanding Covid-19 and risks to public health, trends in Covid-19 and such risks, and controlling and preventing the spread of Covid-19 and such risks
- identifying and understanding information about patients or potential patients with or at risk of Covid-19, information about incidents of patient exposure to Covid-19 and the management of patients with or at risk of Covid-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from Covid-19
- understanding information about patient access to health services and adult social care services and the need for wider care of patients and vulnerable groups as a direct or indirect result of Covid-19 and the availability and capacity of those services or that care
- monitoring and managing the response to Covid-19 by health and social care bodies and the Government including providing information to the public about Covid-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services
- delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with Covid-19, including the provision of information, fit notes and the provision of health care and adult social care services
- research and planning in relation to Covid-19.
Recording of processing
A record will be kept by Clement Road Medical Centre of all data processed under this Notice.
Sending Public Health Messages
Data protection and electronic communication laws will not stop Clement Road Medical Centre from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.
It may also be necessary, where the latest technology allows Clement Road Medical Centre to do so, to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.
Research and Pandemic Planning
The Secretary of State has directed NHS Digital to collect, process and analyse data in connection with COVID-19 to support the Secretary of State’s response to COVID-19 and support various COVID-19 purposes set out in the COVID-19 Public Health Directions 2020, 17 March 2020 (as amended) (COVID-19 Direction) and below. This enables NHS Digital to collect data and analyse and link the data for COVID-19 purposes with other data held by NHS Digital.
The purpose of the data collection is also to respond to the intense demand for General Practice data to be shared in support of vital planning and research for COVID-19 purposes, including under the general legal notice issued by the Secretary of State under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI).
NHS Digital has therefore been requested by the joint co-chairs of the Joint GP IT Committee (JGPITC) (the BMA and RCGP) to provide a tactical solution during the period of the COVID-19 pandemic to meet this demand and to relieve the growing burden and responsibility on General Practices. On 15 April 2020 the BMA and RCGP therefore gave their support via JGPITC to NHS Digital’s proposal to use the General Practice Extraction Service (GPES) to deliver a data collection from General Practices, at scale and pace, as a tactical solution to support the COVID-19 response in the pandemic emergency period.
It is a requirement of the JGPITC that all requests by organisations to access and use this data will need to be made via the NHSX SPOC COVID-19 request process, that will triage and prioritise these requests and refer appropriate requests on to the NHS Digital Data Access Request Service (DARS). NHS Digital will consult with representatives of the BMA and the RCGP on all requests for access to the data. An outline of the process for this agreed with the BMA and the RCGP is published here. Requests by organisations to access record level data from this collection will also be subject to Independent Group Advising on the Release of Data (IGARD) consideration. Data applicants will need to demonstrate they have a lawful basis to access the data for COVID-19 purposes.
Benefits of this sharing
Organisations, including the Government, health and social care organisations and researchers need access to this vital data for a range of COVID-19 purposes, to help plan, monitor and manage the national response to the COVID-19 pandemic, which will help save lives. COVID-19 purposes for which this data may be analysed and used may include:
- understanding COVID-19 and risks to public health, trends in COVID-19 and such risks, and controlling and preventing the spread of COVID-19 and such risks
- identifying and understanding information about patients or potential patients with, or at risk of COVID-19, information about incidents of patient exposure to COVID-19 and the management of patients with or at risk of COVID-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID-19
- understanding information about patient access to health services and adult social care services as a direct or indirect result of COVID-19, and the availability and capacity of those services • monitoring and managing the response to COVID-19 by health and social care bodies and the Government including providing information to the public about COVID-19 and its effectiveness and information about capacity, medicines, equipment, supplies, services and the workforce within the health services and adult social care services
- delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with COVID-19, including the provision of information, fit notes and the provision of health care and adult social care services; and
- research and planning in relation to COVID-19
Data may be analysed and linked to other data held by NHS Digital or held by other organisations to which access to the data is granted for COVID-19 purposes, through the process described above.
Data will be collected nationally from all GP Practices by NHS Digital every fortnight. All requests to access this data will be triaged through the NHSX SPOC COVID-19 request process and assessed and fulfilled by NHS Digital through DARS. This will significantly reduce the burden on General Practice at a time when demand on resources is high, enabling General Practice to focus on delivering health care and support to patients. It will also reduce compliance burden and risk for General Practice associated with sharing data and complying with the terms of the general legal notice issued under COPI, which applies to General Practices.
Legal Basis for this collection
NHS Digital has been directed by the Secretary of State under section 254 of the 2012 Act under the COVID-19 Direction to establish and operate a system for the collection and analysis of the information specified for this service: GPES Data for Pandemic Planning and Research (COVID-19). A copy of the COVID-19 Direction is published at: www.digital.nhs.uk – COVID-19 Public Health Directions 2020.
Details of the information to be collected can be found on the NHS Digital website – Specification of this DPN. Type 1 objections will be upheld in collecting this data from General Practices and therefore the data for those patients who have registered a Type 1 objection with their GP will not be collected. The Type 1 objection prevents an individual’s personal identifiable confidential information from being shared outside of their GP Practice except when it is being used for the purposes of their direct care. The National Data Opt-Out will not apply to the collection of the data, as this is a collection which is required by law.
This information is required by NHS Digital under section 259(1)(a) of the 2012 Act to comply with the COVID-19 Direction. In line with section 259(5) of the 2012 Act, all organisations in England that are within the scope of this Notice, as identified below under Health and Social Care Bodies within the scope of the collection, must comply with the requirement and provide information to NHS Digital in the form, manner and for the period specified in this Notice. This Notice is issued in accordance with the procedure published as part of NHS Digital’s duty under section 259(8) of the 2012 Act.
In August 2020, the NHS announced that the seasonal national flu immunisation programme criteria for 2020 – 2021 will be expanded to include patients on the SPL. Therefore, to provide information that will support the identification of patients at moderate or high risk of complications from flu, a revision to the weekly extract of data has taken place. This, version three of the extract for the purpose of maintaining and updating the SPL, will continue until the expiry of the COVID-19 Direction. This is currently 30th June 2022. The frequency of the data collection may change in response to demand.
|Data collection extracted on a weekly basis week commencing 13 April 2020
|Revised weekly data collection. The first collection is due week commencing 28 September 2020
|All patients with defined long-term medical conditions which pose a COVID-19 risk, identified as clinically extremely vulnerable to that risk and/or on certain drug treatments as below:
|All patients with defined long-term medical conditions which pose a COVID-19 risk, identified as clinically extremely vulnerable/potentially clinically vulnerable to that risk and/or on certain drug treatments as below:
|Medical Conditions that provide information on clinically vulnerable patients
|Medical Conditions that provide information on clinically vulnerable patients
|Patients with a COVID-19 activity code
|Patients with a COVID-19 activity code
|Clinically vulnerable patients (eligible for seasonal flu vaccination)
Other Potentially clinically Vulnerable patients
|Additional Data items for Patients from the above groups
The Secretary of State has directed NHS Digital to collect, process and analyse data in connection with COVID-19 to support the Secretary of State’s response to COVID-19 and support various COVID-19 purposes set out in the COVID-19 Public Health Directions 2020, 17 March 2020 (COVID-19 Direction) (as amended) (COVID-19) Direction) and below. This enables NHS Digital to collect data and analyse and link the data for COVID-19 purposes with other data held by NHS Digital. The rationale for changing the data extraction is that the initial data collection was based on an existing specification for flu vaccination eligibility. This data extraction was then refined in order to more accurately reflect the patients who are clinically extremely vulnerable to COVID-19 and also to minimise the data we are collecting. A further refinement of the data extraction has taken place leading to the inclusion of new data being extracted. This will provide information to inform vaccination programmes.
This General Practice Extraction Service (GPES) data will be extracted weekly and be used to assist in producing a weekly update of the SPL. The objective of this collection is on an ongoing basis to identify patients registered at General Practices who may be:
- clinically extremely vulnerable if they contract COVID-19
- at moderate or high risk of complications from flu or COVID-19
The data collected will be analysed and linked with other data NHS Digital or other organisations hold to identify:
- a list of clinically extremely vulnerable patients who will be advised to take shielding measures to protect themselves. Advice given to these patients has been published by Public Health England and is available at: www.gov.uk – Guidance for people previously considered clinically extremely vulnerable from COVID-19
- a list of patients at moderate or high risk of complications from flu to inform the flu call/recall vaccination programme
Further information on the flu programme can be found at: Coronavirus (england.nhs.uk).
The extract may also be used for future direct care purposes relating to the COVID-19 outbreak. The methodology NHS Digital has used to produce the SPL is explained in detail and is published on the NHS Digital SPL website page at: www.digital.nhs.uk – Shielded Patient List.
Patients added to the SPL will be contacted by post, email (and/or SMS message where this is necessary) by the NHS on behalf of the Chief Medical Officer, Chris Whitty, to:
- advise of the measures they can take to reduce their risk of contracting the virus and sign-post them to the Extremely Vulnerable Persons service operated by gov.uk at www.gov.uk/coronavirus-extremely-vulnerable.
- offer a flu vaccination or to contact non-responders who remain unvaccinated (as per NHS England specifications for the service). The SPL will also be used to inform GPs of their individual patients on the SPL, by flagging those patient records on GP patient record systems. The SPL will be shared with a variety of other organisations involved in the care and support of those patients and for planning, commissioning and research purposes associated with COVID-19. Full details of those with whom information has been shared can be found on the NHS Digital SPL website at: www.digital.nhs.uk – Dissemination of the Shielded Patient List.
Requests by organisations to access record level data from this collection will be subject to Independent Group Advising on the Release of Data (IGARD) consideration. Data applicants will need to demonstrate they have a lawful basis to access the data for COVID-19 purposes.
Benefits of the Collection
Organisations, including Government, health and social care organisations need to access this vital data for a range of COVID-19 purposes, to help plan, monitor and manage the national response to the COVID-19 pandemic, which will help save lives. COVID-19 purposes for which this data may be analysed and used may include:
- understanding COVID-19 and risks to public health, trends in COVID-19 and such risks, and controlling and preventing the spread of COVID-19 and such risks
- identifying and understanding information about patients or potential patients with, or at risk of COVID-19, information about incidents of patient exposure to COVID-19 and the management of patients with or at risk of COVID-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID-19.
Data will be analysed and linked to other data held by NHS Digital or held by other organisations to which access to the data is granted for COVID-19 purposes, through the process described above. Data will be collected nationally from all General Practices by NHS Digital every week. All requests to access this data will be through Data Access Request Service (DARS). This will significantly reduce the burden on General Practice at a time when demand on resources is high, enabling General Practice to focus on delivering health care and support to patients. It will also reduce compliance burden and risk for General Practice associated with sharing data and complying with the terms of the general legal notice issued under the National Health Service (Control of Patient Information Regulations) 2002 (COPI), which applies to General Practices Patients facing the greatest risk if they contract COVID-19 and/or are in the moderate to high risk of complications from flu:
- will be identified and known to health organisations
- will have a greater awareness of the recommended preventative shielding measures
- will be able to follow clear advice
- will be able to ask for help and support, including social care support and essential food supplies, through the Extremely Vulnerable Persons service operated by gov.uk.
It will enable the SPL to be updated weekly to identify new patients and changes to patients on the List and will enable support provisions to be more dynamic and responsive to both social and clinical need.
It will also enable vital planning, commissioning, and research to be carried out for COVID-19 purposes. If patients facing the greatest risk follow advice, it is hoped that this will contribute to the delay and mitigation of the spread of COVID-19 and save lives.
Visitors to The Practice
We have an obligation to protect our staff and employees’ health, so it is reasonable for staff at Clement Road Medical Centre to ask any visitors to our practice to tell us if they have visited a particular country, or are experiencing COVID-19 symptoms. This must only be in pre-approved circumstances and we would also ask all patients to consider government advice on the NHS 111 website and not attend the practice.
Where it is necessary for us to collect information and specific health data about visitors to our practice, we will not collect more information than we need, and we will ensure that any information collected is treated with the appropriate safeguards.
Review and Expiry of this Notice
This Notice will be reviewed on or before 31 October 2022 and may be extended by The Secretary of State. If no further notice is sent to Clement Road Medical Centre by The Secretary of State this Notice will expire on 31 October 2022.
Freedom of Information
The practice complies with Information Commissioner’s Office stipulations. Before requesting information, patients are asked to consult the ICO’s website and consider whether this information is already or more easily available elsewhere.
For more information please visit the ICO website.
All GP practices are required to declare the mean earnings (e.g. average pay) for GPs working to deliver NHS services to patients at each practice.
However, it should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time doctors spend working in the practice, and should not be used to form any judgement about GP earnings, nor to make any comparison with any other practice.
The average pay for GPs working in the Clement Road Surgery in the last financial year was £88,762 before tax and National Insurance.
This is for 2 full time GPs and 3 part time GPs who worked in the practice for more than six months.
All patients have been allocated a named GP at the practice and where a preference is expressed reasonable efforts will be made to accommodate this. Our accountable GP’s are Dr Keith Chan and Dr Royce Chan. Whilst these doctors have been designated as having overall responsibility for the care and support that our surgery provides for you, this does not prevent you from seeing any other doctor in the practice.
If you do not know the name of your allocated GP, please complete our contact the practice form or you may contact the surgery.
This privacy notice lets you know what happens to any personal data that you give to us, or any information that we may collect from you or about you from other organisations.
What is Proxy Access?
Proxy access was developed to allow someone other than the patient to access and manage parts of their GP online services account. The person acting on behalf of the patient for example a parent or carer (the proxy) is given their own online access account (rather than using the patient’s login details).
To obtain proxy access a person must be registered for online access at the practice where the patient they are acting for is registered. Proxy access is the recommended alternative to sharing login details. Every practice is required to verify patient identity documentation, or individually vouch for each patient requesting access to online services.
Please contact the practice who will advise how to request Proxy Access.
Suggestions, Comments and Complaints
We welcome your comments and suggestions on the facilities and services provided by the Practice. If you are pleased with the service you receive or feel that there could be an improvement please let us know.
If you have a complaint or are concerned about the service you have received from the doctors or the staff working in this practice, please let us know by completing our Feedback and Complaints Triage. We operate a practice complaints procedure are part of a NHS system for dealing with complaints. Our complaints procedure meets national criteria.
How to complain
We hope that most problems can be sorted out easily and quickly, often at the time they arise and with the person concerned. If your problem cannot be sorted out in this way and you wish to make a complaint, we would like you to let us know as soon as possible or at the most within a few weeks – this will enable us to establish what happened more easily. If it is not possible to do that please let us have the details of your complaint:
- Within 12 months of the incident that caused the problem
- Within 12 months of discovering that you have a problem, provided this is within 12 months of the incident
Complaints should be addressed to practice manager the designated complaints officer, or any of the doctors. Alternatively, you may ask for an appointment with the practice manager in order to discuss your concerns. She will explain the complaints procedure to you and will make sure that your concerns are dealt with promptly. It will be a great help if you are as specific as possible about your complaint.
We hope that if you have a problem, you will use our complaints procedure. We believe this will give us the best chance of putting right whatever has gone wrong and an opportunity to improve our practice.
Taking your complaint further
If you want to make a complaint about primary care services to the commissioner, you will now contact the Black Country Integrated Care Board instead of NHS England.
You can do this by:
Telephone: 0300 0120 281
Email: [email protected]
Writing to us at: Time2Talk, NHS Black Country Integrated Care Board (ICB) Civic Centre, St Peter’s Square, Wolverhampton, WV1 1SH
Who can complain?
- The patient
- Anyone with the patient’s written consent
- Anyone on behalf of someone too ill or too old to complain for themselves
- Where the patient is a child, by either parent or in the absence of both parents, the guardian or other adult who has care of the child
- Normally the next of kin where the patient has died
Complaining on behalf of someone else
Please note that we keep strictly to the rules of medical confidentiality. If you are complaining on behalf of someone else we have to know that you have his or her permission to do so. A note signed by the person concerned will be needed, unless they are incapable (because of physical or mental illness) of providing this
What shall we do
We shall acknowledge your complaint within three working days beginning with the day on which the complaint was made or, where that is not possible, as soon as reasonably practicable, and aim to have looked into your complaint within seven working days of the date when you raised it with us. We shall then be in a position to offer you an explanation, or a meeting with the people involved.
When we look into your complaint we shall aim to:
- Find out what happened and what went wrong
- Make it possible for you to discuss the problem with those concerned, if you would like this
- Make sure you receive an apology, where this is appropriate
- Identify what we can do to make sure the problem will not happen again.
What happens next
First of all you will be invited to an informal discussion with the complaints officer who may be able to provide you with a satisfactory answer at that stage, if not you will be advised that the matter with be fully investigated and a further meeting arranged to discuss the outcome of this investigation.
The practice will agree an appropriate timescale with the complainant to resolve the complaint depending on the complexities and complainants expectations of response time, but we try to resolve with a 10 to 25 working days however, this timescale will depend upon the complexities of the complaint and the complainant’s expectation of response times.
If you still remain dissatisfied after the above you may then refer to the parliamentary and Health Service Ombudsman (PHSO) at the following address.
Parliamentary and Health Service Ombudsman (PHSO)
Alternatively they are available by email at [email protected]
You can contact them by telephoning their helpline on 0345 015 4033. Calls are charged at a local rate from wherever you are in the United Kingdom, and the helpline is open from 08:30 to 17:30, Monday to Friday.
The PHSO carry out independent investigations into complaints about UK government departments and their agencies, and the NHS in England – and help improve public services as a result.
The practice would comment however, that within the NHS there is great emphasis on resolving complaints at a local level, and that the PHSO may refer a complaint back to the surgery for further review if it is felt that all measures to resolve your concerns have not been taken.
Should you remain dissatisfied therefore, we find that a face to face meeting with the doctors can be helpful to identify and address any outstanding issues, and if you wish, the complaints officer would be happy to arrange this for you. Please contact the surgery and ask for the practice manager if you feel such a meeting would be of benefit to you.
Thank you once again for bringing your concerns to our attention.
Dated March 2018
Revision date March 2021
GP registrars work as part of the team. GP registrars are fully qualified doctors with at least 2 year’s experience of working in hospitals and who wish to specialise in general practice. GP registrars have daily surgeries (often with longer appointment times), undertake home visits and help with on-call doctor duties.
Their placements with us vary in length, depending on their stage of training, from 4 months to over 12 months. They are supervised and assessed on a regular basis. Patients may, on occasion, be asked whether they mind having their consultation videoed for assessment purposes and/or to complete patient satisfaction questionnaires.
Foundation doctors are fully qualified doctors who are rotating around various specialities to increase their experience. Some of them may choose to go on to do further training to become a GP.
Each foundation doctor will be with us for a 4 month placement. They will be closely supervised and assessed throughout their time with us. They will have longer appointment times.
The surgery provides placements for medical students who are training to become doctors. Patients may be made aware of students sitting in with GPs, observing a surgery or may sometimes be asked if they mind being interviewed by a student as part of their training.
Patients do, of course, have the right to decline in helping with assessment and training. However, we hope that most will feel happy to assist in the education and training of our future health professionals.
Department of Health Connecting Programme
To understand the needs of patients and the pressures NHS staff face, every Department of Health civil servant will be expected to gain first hand experience of life in health or social care for at least 1 month every year.
A key recommendation in the Francis report was changing the culture of the department to make sure the needs of patients are always the first priority.
As an important step, the Health Secretary Jeremy Hunt announced in 2013 that he wants his staff to lead the way across Government, by gaining a personal understanding of life on the front line and using that experience to shape policies that serve patients and their families. The surgery supports this programme by participating and placements are overseen by our practice manager.
We all have bad days, and when we feel ill we may feel ‘down’ and a little more irritable than normal. All our staff are here to help you.
Reception staff are following procedures that help the practice to function efficiently. Staff have the right to work in a safe and secure environment and we, as employers, have the legal responsibility to provide that safe and secure environment.
The practice will not tolerate:
- Verbal abuse to staff which prevents them from doing their job or makes them feel unsafe.
- Threats of violence or actual violence to a GP or a member of his or her staff.
The GPs have the right to remove from their list with immediate effect any patient who behaves in the above manner.