In accordance with the Data Protection Act 1998 and Access to Health Records Act, patients may request to see their medical records.

Such requests should be made through the site manager and may be subject to an administration charge.

No information will be released without the patient consent unless we are legally obliged to do so.

What is a complaint?

Its’ recognised that this is not always easy to determine, however, it is usually when someone voices their dissatisfaction with the service provided and where a response is required.

Common causes of Complaint:

• Clinical care and treatment
• Failure to diagnose
• Attitude of health professional and/or staff
• Delay to visit/Unable to get an appointment/Not being seen on time
• Failure to refer
• Poor communication
• Breach of Confidentiality
• Practice Administration

What do Patients Want?

• To be listened to, to have their concerns taken seriously
• An apology
• An explanation of the events
• Reassurance that things will be put right

Who Can Complain?

• Anyone who is receiving or has received NHS treatment or services including minors i.e. under 16.

What to do if a patient makes a complaint:

Some complaints can be dealt with on the spot e.g. prescription not ready or sent to chemist in error, forms or letters not ready for collection etc.

Apologise to the patient and show empathy (let them know that you understand how they feel). Remember to stay calm and speak softly even if the patient is abusive.

Collect as much information as you can about the patient (name address telephone etc.) and their problem. Confirm the information with the patient.

Investigate the problem in an effort to try to identify possible solutions and if possible provide the patient with an explanation.

Agree with the patient a way forward.  This can sometimes be difficult if patients are very upset and are not happy with any of your suggestions in which case it may useful to ask the patient how they would like to see the matter resolved.

Ensure that you follow through any agreed action and check that the patient is happy with the solution.

If you are unable to satisfy the patient please make the patient aware of the PALS (Patient Advice and Liaison Service) who may be able to help, particularly useful for patients who do not wish to make a formal complaint.

Provide the patient with a copy of the NHS Complaints Procedure, which can be located in the red complaints/suggestions file in reception.

Record the incident in the red complaints/suggestions file.

We can learn from our mistakes.  The complaints will be reviewed and used as a tool to improve our services.

Complaints that are Not Easy to Resolve:

These include more serious complaints such as, complaints against a GP or member of staff, breach of confidentiality, clinical matters etc.  These patients should be given a copy of the NHS complaints procedure and referred to the Practice Manager. If the complaint is about the practice manager, please refer to the Senior Partner.

Complaints Procedure

The practice operates an internal complaints procedure known as local resolution.  The practice aims to give you a quick but thorough response to your complaint.

Anyone who is receiving or has received NHS treatment or services can make a complaint.

If you are unable to make your complaint yourself, then someone else such as a relative or a friend can complain for you.  If you are aged 16 or over your representative will need your written consent.

If you are complaining on behalf of a patient that has died you will need to provide a letter of administration or proof that you are the executor of the will.

It is important to make your complaint as soon as possible after the problem arises.

1. Complaints may be made verbally or in writing to the Practice Manager.

1. Your complaint will be recorded and acknowledged within 3 working days.

1. Your complaint will be investigated thoroughly and fairly.

1. As per the NHS England Complaints Resolution guidelines;

1. Inline with the NHS England’s complaints policy, we aim to respond within 40 working days. If no response is 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 of their right to approach the PHSO without waiting for local resolution to be completed

If we are unable to satisfy the complainant through local resolution, or the complainant is unhappy with our response, they have the right to take their complaint to the Health Service Ombudsman. The Ombudsman is independent of the government and the NHS. You can contact their helpline on 03450154033, email [email protected], fax 03000614000 or via post Millbank Tower, Millbank, London, SW1P 4QP. Further information about the Ombudsman is available at www.ombudsman.org.uk 

 Changes to making complaints from 1^st July 2023

from 1 July 2023, the way members of the public make a complaint about primary care services to the commissioner is changing.

There are two ways members of the public can make a complaint:

• You can complain to the healthcare provider: for example, a GP surgery
• You can complain to the commissioner of the service

West London instead of NHS England.

They will need to do this by:

• Telephone: 020 3350 4567 (This is an automated service. Please leave a

message requesting a call back)

• E-mail: [email protected]
• Writing to us at: Complaints Manager, NHS North West London, 15 Marylebone

Road, London NW1 5JD

The practice complies with data protection and access to medical records legislation. Identifiable information about you will be shared with others in the following circumstances:

• To provide further medical treatment for you e.g. from district nurses and hospital services.
• To help you get other services e.g. from the social services department. This requires your consent.
• When we have a duty to others e.g. in child protection cases. Anonymised patient information will also be used at local and national level to help the Health Policy makers and Government plan services e.g. for diabetic care.

If you do not wish that anonymous information about you be used in such a way, please let us know.

Reception and administration staff require access to your medical records in order to do their jobs. These members of staff are bound by the same rules of confidentiality as the medical staff.

Information about the General Practioners and the practice, required for disclosure under this act, can be made available to the public. All requests for such information should be made to the site manager.

This practice is supporting vital coronavirus (COVID-19) planning and research by sharing your data with NHS Digital.

The health and social care system is facing significant pressures due to the coronavirus (COVID-19) outbreak.

Health and care information is essential to deliver care to individuals, to support health, social care and other public services and to protect public health.

Information will also be vital in researching, monitoring, tracking and managing the coronavirus outbreak.

In the current emergency it has become even more important to share health and care information across relevant organisations.

This practice is supporting vital coronavirus planning and research by sharing your data with NHS Digital, the national safe haven for health and social care data in England.

NHS Digital will analyse the data they collect and securely and lawfully share data with other appropriate organisations, including health and care organisations, bodies engaged in disease surveillance and research organisations for coronavirus response purposes only.

These purposes include protecting public health, planning and providing health, social care and public services, identifying coronavirus trends and risks to public health, monitoring and managing the outbreak and carrying out of vital coronavirus research and clinical trials.

The British Medical Association, the Royal College of General Practitioners and the National Data Guardian are all supportive of this initiative.

NHS Digital has various legal powers to share data for purposes relating to the coronavirus response.

It is also required to share data in certain circumstances set out in the COVID-19 Direction and to share confidential patient information to support the response under a legal notice issued to it by the Secretary of State under the Health Service (Control of Patient Information) Regulations 2002 (COPI Regulations).

Legal notices under the COPI Regulations have also been issued to other health and social care organisations requiring those organisations to process and share confidential patient information to respond to the coronavirus outbreak.

Any information used or shared during the outbreak under these legal notices or the COPI Regulations will be limited to the period of the outbreak unless there is another legal basis for organisations to continue to use the information.

Data which is shared by NHS Digital will be subject to robust rules relating to privacy, security and confidentiality and only the minimum amount of data necessary to achieve the coronavirus purpose will be shared.

Organisations using your data will also need to have a clear legal basis to do so and will enter into a data sharing agreement with NHS Digital. Information about the data that NHS Digital shares, including who with and for what purpose will be published in the NHS Digital data release register.

For more information about how NHS Digital will use your data please see the NHS Digital Transparency Notice for GP Data for Pandemic Planning and Research (COVID-19).

The application of the National Data Opt-Out to information shared by NHS Digital will be considered on a case by case basis and may or may not apply depending on the specific purposes for which the data is to be used.

This is because during this period of emergency, the National Data Opt-Out will not generally apply where data is used to support the coronavirus outbreak, due to the public interest and legal requirements to share information.

NHS Digital has been legally directed to collect and analyse patient data from all GP practices in England to support the coronavirus response for the duration of the outbreak.

NHS Digital will become the controller under the General Data Protection Regulation 2016 (GDPR) of the personal data collected and analysed jointly with the Secretary of State for Health and Social Care, who has directed NHS Digital to collect and analyse this data under the COVID-19 Public Health Directions 2020 (COVID-19 Direction).

All GP practices in England are legally required to share data with NHS Digital for this purpose under the Health and Social Care Act 2012 (2012 Act). More information about this requirement is contained in the data provision notice issued by NHS Digital to GP practices.

Under GDPR our legal basis for sharing this personal data with NHS Digital is Article 6(1)(c) – legal obligation. Our legal basis for sharing personal data relating to health, is Article 9(2)(g) – substantial public interest, for the purposes of NHS Digital exercising its statutory functions under the COVID-19 Direction.

The NHS prescription charge is a flat-rate amount which successive Governments have thought it reasonable to charge for those who can afford to pay for their medicines.

Extensive exemption and remission arrangements protect those likely to have difficulty in paying charges (NHS prescription and dental charges, optical and hospital travel costs).

If you think you may be exempt please ask for a medical exemption form from your pharmacist or doctor.

Prescription prepayment certificates (PPCs) offer real savings for people who need several items of  medication on a regular basis.

You can also speak to your pharmacist for further information.

Charges

• Prescription (per item): £9.15
• 12-month prepayment certificate (PPC): £105.90
• 3-month PPC: £29.65

If you will have to pay for four or more prescription items in three months, or more than 15 items in 12 months, you may find it cheaper to buy a PPC .

To order a pre-payment certificate:

Telephone advice and order line 0845 850 0030

General Public – Buy or Renew a PPC On-line

There is further information about prescription exemptions and fees on the NHS website

Useful leaflets and posters

Conditions that could be self-managed and items that should not be routinely prescribed in Primary Care

Medicines that can be purchased without a prescription

Ordering repeat prescriptions online

Be in the know about repeat prescription requests

Repeat prescriptions; requesting your repeat prescriptions

The data being shared with NHS Digital will include information about patients who are currently registered with a GP practice or who have a date of death on or after 1 November 2019 whose record contains coded information relevant to coronavirus planning and research.

The data contains NHS Number, postcode, address, surname, forename, sex, ethnicity, date of birth and date of death for those patients.

It will also include coded health data which is held in your GP record such as details of:

• diagnoses and findings
• medications and other prescribed items
• investigations, tests and results
• treatments and outcomes
• vaccinations and immunisations

To read more about the health and care information NHS Digital collects, its legal basis for collecting this information and what choices and rights you have in relation to the processing by NHS Digital of your personal data, see:

• the NHS Digital GPES Data for Pandemic Planning and Research (COVID-19) Transparency Notice
• the NHS Digital Coronavirus (COVID-19) Response Transparency Notice
• the NHS Digital General Transparency Notice
• how NHS Digital looks after your health and care information

Introduction

The NHS Zero Tolerance Zone is a nation-wide campaign to tackle violence and abuse, both physical and verbal, against all members of staff working in the NHS. Its two principal aims are: · To inform the public that violence against staff working in the NHS is unacceptable and the Government is determined to stamp it out · To inform all staff that violence and intimidation is unacceptable and is being tackled. The practice fully supports this campaign and its legal requirements to provide, as far as is reasonably practicable, conditions of working that are conducive to the prevention of and safe management of violence.

Background

In January 2000 the Department of Health (DOH) issued guidelines to Health Authorities to introduce local initiatives as part of a Zero Tolerance Campaign which addresses any incident where a General Practitioner (GP), or his/her staff are exposed to violent or abusive behaviour. As well as having a right to protect themselves, GPs have a duty, as employers, to protect their staff and as providers of a public service, those with reason to be on their premises. The DOH established the following definition for violence/abuse – “Any incident where a GP, or his or her staff, are abused, threatened or assaulted in circumstances related to their work, involving an explicit or implicit challenge to their safety, wellbeing or health”. The definition does not define violence just as physical assault but also includes threats that challenge the “Safety, wellbeing or health of staff”.

Here are some examples of the breaches of the Zero Tolerance Policy;

• Behaviours that target a person based on their protected characteristic or belonging to a marginalised group. These can be intentional and unintentional and are based on biases either conscious and unconscious
• Any physical violence towards any member of the Primary Health Care Team or other patients, such as pushing or shoving
• Racial abuse and sexual harassment
• Causing damage/stealing from the Practice’s premises, staff or patients
• Obtaining drugs and/or medical services fraudulently
• Refusing appointments with an appropriate clinician for the presenting care need i.e. insisting on a GP appointment when seeing a pharmacist or nurse prescriber is most appropriate or refusing to see an available GP for your presenting care need when your preferred GP is unavailable
• Refusing to access the service in the appropriate manner i.e. sending emails/texts instead of using the NHS Digital approved digital consultation service
• Demanding a same day appointment for a routine clinical need – this deprives access to urgent care services for those who genuinely need it
• Contacting individuals directly via social media or personal email instead of through the practice contact channels
• Using bad language threatening or swearing at practice staff or other service users;
• Unnecessarily persistent or unrealistic service demands that cause disruption;
• Verbal, non-verbal and environmental slights, snubs and insults which communicate hostile, derogatory or negative messages;

Process

The practice operates a Zero Tolerance Policy towards any member of our staff or patients. Patients are expected to be considerate and act reasonably. Management cites but does not restrict, the following unacceptable behaviour within its Zero Tolerance Policy: · any display of a violent temper · shouting, raised voices, sarcasm, pointing fingers. · repeated or insistent points being made; not engaging with staff in a positive way; being pushy or trying to intimidate staff · hostile or aggressive behaviour · threats, swearing, spitting · any mention or display of any object that could be used as a weapon. Should a member of staff (or patient) feel that they have encountered behaviour that could be classed as unacceptable within the Practice Zero Tolerance Policy, a complaint should be made to the Practice Manager. Once the matter has been reviewed by the Practice Manager the person in question will be sent a formal warning letter, depending on the severity of the incident they may then be either sent a warning letter with behavioural agreement to be signed within 30 days of the warning letter been issued or be removed from the practice list. We will have no hesitation in having the patient removed from the building by the Police should his/her behaviour warrant it.

Police involvement

If an incident is taking place and staff feel that a Police presence is required, regardless of the circumstances, the Police will be called to deal with the incident. It is our responsibility to protect our staff and patients and therefore no hesitation will be made if a Police presence is required. If the patient has left the premises and there is no immediate danger, the Police will still be notified of the incident so it can be recorded for future reference. The GP will also keep a record of the incident.

Warning system

Following an incident where a complaint has been made about a patient’s behaviour a formal warning letter will be sent with a behavioural agreement to be signed within 30 days of the date of the warning letter. The letter will notify the person that their behaviour was unacceptable and will not be tolerated, if the person is a patient at the surgery they will be warned that they run the risk of being removed from our practice list if they do not sign the behavioural agreement within the specified time period. The letter will clearly state that if there is any reoccurrence of their behaviour in any way that they will be removed from the Practice list. A permanent record of the warning, including the date and reason for the warning, will be made and retained. Although this procedure will be generally applied, there may be occasions where the Management Team feel that an episode of behaviour is so serious that a patient will removed from the Practice list with immediate effect. Where this is the case, the police will usually have been called to attend the Practice and one or more members of staff or patients will have been threatened or attacked or narrowly avoided being attacked. It is important to remember that it is not the intention of the perpetrator that is relevant, rather than the perception that is generated by the actions and behaviour of the perpetrator that will generate the Practice response.

Removal from the Practice List

Removal of patients from this Practice list is an exceptional and rare event and is a last resort. The practice must respect the safety and wellbeing of their staff and patients, and if a patient at the surgery is unable to respect the staff and treat them with courtesy then it is in the best interest of the patient in question and, more importantly, our staff that they register elsewhere. If the decision to remove a patient from the practice list is made, NHS England will be notified either immediately (in case of serious breaches where a deregistration is to be processed within 24hours with or without a police reference as necessary) or on 8 days’ notice for the protection of other NHS staff members. If a patient is removed from the Practice list, they will also be banned from entering the Practice premises or contacting Practice staff in any way.

Notifying the Patient

The Practice will take steps to contact the patient to inform them of the action being taken. After having a formal consultation with our integrated care board, we advise patients that following a breach of zero tolerance threshold, where the breach is not warranting a removal, practice is more than happy to carry on providing the service as normal provided a behavioural agreement is signed. This means that the practice will be monitoring patients behavioural after they have signed the agreement for a period of 12 months and should there be a reoccurrence of the same, a deduction will be processed as appropriate. Practice warning letter clearly specifies about the 30 days’ time period for signing the behavioural agreement and the patient will be informed in writing to their home address or through a verified email. Failing to sign the behavioural agreement within the given time period will result in the de-registration of the patient and no further notifications will be sent. Once this decision has been made the deduction will not be revoked under any circumstances, and the subject will not be entertained by any staff member and will be only considered as harassment. Practice is not obliged to send removal notifications in cases of serious breaches where it is necessary to remove patients within 24 hours’ time period, however all necessary measures will be taken by the practice to inform the NHS health authority of the event so that they can contact the patient directly to

Removing other members of the household

Because of the possible need to visit patients at home it may be necessary to terminate responsibility for other members of the family or the entire household. The prospect of visiting patients where a relative, who is no longer a patient of the practice by virtue of their unacceptable behaviour resides, or being regularly confronted by the removed patient, may make it too difficult for the practice to continue to look after the whole family. This is particularly likely where the patient has been removed because of violence or threatening behaviour and keeping the other family members could put Doctors or their staff at risk.