As a patient you can ask for one at any time if you would feel more comfortable.

We recognise it is important to ensure a sense of trust, dignity and privacy though out all consultations. Consent is also required from a parent or legal guardian prior to the physical examination of any child or young person.

A relative or friend accompanying you may remain present during examinations at your own discretion, and with the agreement of your doctor, but the use of suitably trained personnel is more appropriate for the purposes of chaperoning. If such a member of staff is unavailable we will offer to re-schedule your appointment accordingly, as you prefer.

Our Promise to you

At Highcliffe Medical Centre we try to ensure that all patients are pleased with their experience of our service and we take complaints very seriously. If you need to complain, you will be dealt with courteously and promptly so that the matter is resolved as quickly as possible.

We learn from every mistake that we make, and we attempt to respond to patients’ concerns in a caring and sensitive way.

Talk to Us

Every patient has the right to make a complaint about the treatment or care they have received at Highcliffe Medical Centre. We understand that we may not always get everything right and, by telling us about the problem you have encountered, we will be able to improve our services and patient experience. We welcome your comments, both positive and negative, as these let us know when we are doing things right for you, our patients, and show us where there is room for improvement.

NHS complaints procedure

We hope that if you have a problem that you will use our in house complaints procedure and that the response you receive will be satisfactory. However if you do not wish to complain directly to the practice you can address your complaint to NHS Dorset at:
NHS Dorset ICB
NHS Dorset, County Hall,
Colliton Park,
Dorchester,
Dorset,
DT1 1XJ

Tel: 01305 368926
Email: customer.careteam@nhsdorset.nhs.uk

Further action

If you are dissatisfied with the outcome of your complaint from either Highcliffe Medical Centre or NHS Dorset, then you can escalate your complaint to Parliamentary Health Service Ombudsman (PHSO) at:

PHSO, Milbank Tower,
Milbank, London,
SW1P 4QP

Tel: 0345 015 4033
www.ombudsman.org.uk/making-complaint

Care Quality Commission 

The CQC doesn’t handle individual complaints about GPs, but you can still share your experience with them if you wish. 

You can contact the CQC in the following ways: 

• Telephone: 03000 616161
• Email: enquiries@cqc.org.uk
• Online form: Complain about a service or provider

Letters of appreciation

If you are happy with the care you have received, or a service by any of our staff, please let us know. Letters or emails can be sent to the Operations manager Sasha Venables or any of the Doctors and are always appreciated.

Suggestions

If you have any suggestions for making changes or improvements to the way we provide our services, please email Operations Manager Sasha Venables via sasha.venables@dorsetgp.nhs.uk.

How to make a complaint

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, ideally within a couple of days as this will enable us to establish what happened more easily.

A complaint can be made verbally or in writing. A complaints form is available from reception. Additionally, you can complain via email to our complaints manager via

highcliffe.datainput@nhs.net

Making a complaint on behalf of someone else

Please note that we adhere fully to the rules of medical confidentiality. Therefore if you are complaining on behalf of someone else you must have their written permission to do so. Our complaints form contains a section which provides consent where necessary.

Time frames for complaints

The time constraint on bringing a complaint is 12 months from the occurrence giving rise to the complaint, or 12 months from the time you become aware of the matter about which you wish to complain. The complaints manager will respond to you within three business days to acknowledge your complaint. We will aim to investigate and provide you with the findings as soon as we can and will provide regular updates regarding the investigation of your complaint.

Final Response

We will issue a final formal response to all complainants which will provide full details and the outcome of the complaint. We will liaise with you about the progress of any complaint.

A complaints form is available from reception. Additionally, you can complain via letter or email to our complaints manager:

Highcliffe Medical Centre,
248 Lymington Road,
Highcliffe,
Dorset,
BH23 5ET

Email: highcliffe.datainput@nhs.net

Patient Participation Group

The Practice also has an active Patient Participation Group (PPG) who are involved with assisting the practice with ideas for improving the service the Practice provides for its patients. If you are interested in joining this group please either visit our website for an application form or let one of our reception team know that you are interested in joining

Confidentiality

We will ensure that all complaints are investigated with the utmost confidentiality and that any documents are held separately from the patient’s healthcare record.

Not sure what to do…?

If you have a query or concern but are not sure if you want to make a complaint, or how to go about the process, you can speak to:

• PALS
• Dorset Healthwatch
• Independent health complaints advocacy

The practice complies with the Data Protection Act. All information about patients is confidential: from the most sensitive diagnosis, to the fact of having visited the surgery or being registered at the Practice. All patients can expect that their personal information will not be disclosed without their permission except in the most exceptional of circumstances, when somebody is at grave risk of serious harm.

All members of our surgery team (from reception to doctors) in the course of their duties will have access to your medical records. They all adhere to the highest standards of maintaining confidentiality. As our reception area is a little public, if you wish to discuss something of a confidential nature please mention it to one of the receptionists who will make arrangements for you to have the necessary privacy.

Under 16s

The duty of confidentiality owed to a person under 16 is as great as the duty owed to any other person. Young people aged under 16 years can choose to see health professionals, without informing their parents or carers. If a GP considers that the young person is competent to make decisions about their health, then the GP can give advice, prescribe and treat the young person without seeking further consent.

However, in terms of good practice, health professionals will encourage young people to discuss issues with a parent or carer. As with older people, sometimes the law requires us to report information to appropriate authorities in order to protect young people or members of the public.

Useful Websites

• Confidentiality NHS Code of Practice
• Confidentiality and Mental Health
• Confidentiality Guidance

More Information on Dorset Care Record (DCR)

The Freedom of Information Act creates a right of access to recorded information and obliges a public authority to:

• Have a publication scheme in place
• Allow public access to information held by public authorities.

The Act covers any recorded organisational information such as reports, policies or strategies, that is held by a public authority in England, Wales and Northern Ireland, and by UK-wide public authorities based in Scotland, however it does not cover personal information such as patient records which are covered by the Data Protection Act.

Public authorities include government departments, local authorities, the NHS, state schools and police forces.

The Act is enforced by the Information Commissioner who regulates both the Freedom of Information Act and the Data Protection Act.

The Surgery publication scheme

A publication scheme requires an authority to make information available to the public as part of its normal business activities. The scheme lists information under seven broad classes, which are:

• who we are and what we do
• what we spend and how we spend it
• what our priorities are and how we are doing it
• how we make decisions
• our policies and procedures
• lists and registers
• the services we offer

You can request our publication scheme leaflet at the surgery.

Who can request information?

Under the Act, any individual, anywhere in the world, is able to make a request to a practice for information. An applicant is entitled to be informed in writing, by the practice, whether the practice holds information of the description specified in the request and if that is the case, have the information communicated to him. An individual can request information, regardless of whether he/she is the subject of the information or affected by its use.

How should requests be made?

Requests must:

• be made in writing (this can be electronically e.g. email)
• state the name of the applicant and an address for correspondence
• describe the information requested.

What cannot be requested?

Personal data about staff and patients covered under Data Protection Act.

For more information see these websites:

• Legislation GOV.UK
• Information Commissioners Office

As of 1st September 2021 your data will be shared with NHS Digital to help improve health, care and services Patient data from GP medical records kept by GP practices in England is used every day to improve health, care and services through planning and research, helping to find better treatments and improve patient care. The NHS is introducing an improved way to share this information – called the General Practice Data for Planning and Research data collection.

NHS Digital will collect, analyse, publish and share this patient data to improve health and care services for everyone. This includes:

• Informing and developing health and social care policy
• Planning and commissioning health and care services
• Taking steps to protect public health (including managing and monitoring the coronavirus pandemic)
• In exceptional circumstances, providing you with individual care
• Enabling healthcare and scientific research

Any data that NHS Digital collects will only be used for health and care purposes. It is never shared with marketing or insurance companies

Find out more about General Practice Data for Planning and Research (GPDPR) on the NHS Digital website

NHS Digital will not collect any patient data for patients who have already registered a Type 1 Opt-out in line with current policy. If this changes patients who have registered a Type 1 Opt-out will be informed.

If you do not want your patient data shared with NHS Digital, you can register a Type 1 Opt-out with us. You can register a Type 1 Opt-out at any time. You can also change your mind at any time and withdraw a Type 1 Opt-out.

Data sharing with NHS Digital will start on 1st September 2021. If you have already registered a Type 1 Opt-out with your GP practice your data will not be shared with NHS Digital.

If you wish to register a Type 1 Opt-out with your GP practice before data sharing starts with NHS Digital, this should be done by returning this form to us by 23 August 2021 to allow time for processing it. If you have previously registered a Type 1 Opt-out and you would like to withdraw this, you can also use the form to do this. If you register a Type 1 Opt-out after your patient data has already been shared with NHS Digital, no more of your data will be shared with NHS Digital. NHS Digital will however still hold the patient data which was shared with us before you registered the Type 1 Opt-out.

If you do not want NHS Digital to share your identifiable patient data with anyone else for purposes beyond your own care, then you can also register a National Data Opt-out (also known as Type 2 Opt out).

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.

The average pay for GPs working in Highcliffe Medical Centre during financial year 2020-21 was £74,087 before tax and national insurance. This is for 1 full time GP, 10 part time GPs and 3 locum GPs who worked in the practice for more than 6 months.

NHS England require that net earnings of doctors engaged in the practice are publicised and the required disclosure is shown above. 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.

Highcliffe Medical Centre is committed to the control of infection within the building and in relation to any clinical procedures carried out with in it. This annual statement will be generated each year in October, in accordance with the requirements of the Health and Social Care Act 2008 Code of Practice on the prevention and control of infections and related guidance. The report will be published on the practice website and will include the following summary:

• Any infection transmission incidents and any action taken (these will have been reported in accordance with our significant event procedure)
• Details of any infection control audits carried out, and actions undertaken
• Details of any risk assessments undertaken for the prevention and control of infection
• Details of staff training
• Any review and update of policies, procedures, and guidelines

Infection Prevention and Control (IPC) lead

The lead for infection prevention and control at Highcliffe Medical Centre is Alexandra Harrison.

The IPC lead is supported by Operations Manager Sasha Venables.

Infection transmission incidents (significant events)

Significant events involve examples of good practice as well as challenging events.

Positive events are discussed at meetings to allow all staff to be appraised in areas of best practice.

Negative events are managed by the staff member who either identified or was advised of any potential shortcoming. This person will complete a Significant Event Analysis (SEA) form which commences an investigation process to establish what can be learnt and to indicate changes that might lead to future improvements.

All significant events are reviewed and discussed at several meetings each month. Any learning points are cascaded to all relevant staff where an action plan, including audits or policy review, may follow.

In the past year, there have been no significant events raised which related to infection control. There have also been no complaints made regarding cleanliness or infection control.

Infection prevention audit and actions

At Highcliffe medical centre we ensure to complete a range of audits to ensure we are constantly upholding the highest quality of cleanliness and infection control measures are being met. In the last 12 months the following audits that have been completed.
The annual Infection Prevention and Control audit was completed by Alexandra Harrison in June 2023 and resulted in the following actions:
• Investigation into the clinical flooring in rooms 2 and 13
• Ordered new clinical waste bin and domestic bins
• Reviewed cleaning schedule with Two Counties Cleaning contractors

An audit on hand hygiene was undertaken by Alexandra Harrison in March 2023 where all available practice staff where audited, this included 100% of the clinical team.
Privacy curtains were audited in Jan 2023 and April 2023 and will continue to be audited every 3 months.
An Aseptic Technique Audit was completed in April 2023 and was discussed during a nursing meeting.
Cleaning Standard Audits have been completed every 2 months by our cleaning contractors and the operations manager Sasha Venables- These are completed to ensure the standard of cleaning our contractors are providing meet the standards set out in the new NHS cleaning standards.
Our latest CQC inspection was in August 2016 where the only area for improvement in regard to infection control was the use of shower trays in the nursing rooms for the cleaning of ulcers and wounds before applying dressings. We no longer use the shower facilities.

Highcliffe Medical Centre plan to undertake the following audits in the next 12 months

• Annual infection control Audit
• Hand Hygiene Audit
• Privacy Curtain Audit
• 3 monthly Cleaning Audit
• Aseptic Technique Audit
• Clinical Waste Audit

Risk assessments

Risk assessments are carried out so that any risk is minimised and made to be as low as is reasonably practicable. Additionally, a risk assessment that can identify best practice can be established and then followed.

In the last year, the following risk assessments relating to infection control were carried out/reviewed:

• General IPC risks
• COSHH
• Privacy curtain cleaning or changes
• Sharps
• Water safety (legionella)

Training

In addition to staff being involved in risk assessments and significant events, at Highcliffe Medical Centre all staff receive IPC induction training on commencing their post. Thereafter, all staff receive refresher training annually. Staff are encouraged to raise any IPC concerns with the managers or the IPC lead

Policies and procedures

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 staff members at Highcliffe Medical Centre to be familiar with this statement, and their roles and responsibilities under it.

Review

The IPC lead and the Operations Manager are responsible for reviewing and producing the annual statement.

This annual statement will be updated on or before 31st October every year.

In Dorset, general practices adhere to strict IT and data protection policies to ensure patient information is kept secure and confidential. These policies cover data storage, access, and sharing, with a focus on complying with legal requirements like GDPR and the UK GDPR. Practices utilize encryption, administrative, and technical controls to protect personal and confidential information.

Key aspects of IT and data protection policies in Dorset GP practices include:

Data Security:

Practices employ various methods to safeguard patient data, including encryption for laptops and restricting access to authorized personnel only.

Data Sharing:

Sharing of patient information is governed by strict protocols, with a focus on obtaining consent and adhering to legal requirements. Patients can opt-out of data sharing for certain purposes like service planning or research.

Data Processors:

When engaging with third-party data processors, such as software providers, practices ensure they are legally and contractually bound to maintain high security standards and comply with data protection laws.

Transparency and Accountability:

Practices are committed to transparency regarding how they handle patient information. This includes providing clear privacy notices and making information about data processing available to patients.

Patient Rights:

Patients have various rights under data protection law, including the right to access, rectify, erase, restrict, object to processing, and request data portability.

Overview of information held and shared

This Privacy Notice explains and describes how this GP Practice uses and manages the information it holds about its patients, service users and staff. This includes how the information may be shared with other NHS organisations and with non-NHS organisations, and how the confidentiality of information is maintained.

Our contact details

Highcliffe Medical Centre
248 Lymington Road, Christchurch Dorset
Tel: 01425 272 203

Data Protection Officers: Dawn Maile, Helen Williams (NHS Dorset) & Emily Hutchings (NHS Dorset)

Data Protection Registration Number: Z5656411

How we contact you

SMS communications: if you have provided us with your mobile telephone number, we may use this to send you SMS messages relating to your healthcare. These may include automatic appointment reminders or cancellations, reminders of clinics, invitations to screening, medication reviews, vaccination appointments, requests to complete surveys or to make you aware of services provided by the surgery that we feel will be to your benefit, or to update you about local and national health promotions. If you do not wish to receive these messages, please let the reception team know.

Email communications: where you have provided your email addresses for communication purposes, we may contact you when necessary to do so for direct health care purposes or to provide you with service updates that relate to the essential task and function of the Practice. Electronic communication is a more efficient and cost-effective method of communicating with you. The Practice aims to keep communication to a minimum, but if you do not wish to receive these messages, please let the reception team know.

Recorded telephone calls: where we contact you or you contact us by telephone, we record all incoming and outgoing telephone calls to and from the Practice for the following purposes:

• to help with staff training (in this instance a transcript of the call is created which contains no patient identifiable or sensitive information).
• to enable us to obtain the necessary facts in the event of a complaint.
• for patient telephone consultations (in this instance a transcript of the call is created and entered into the individual patient health record).
• for medico-legal purposes; and
• for quality assurance to allow us to audit and improve our service to you.

Recordings of telephone calls will only be accessed where necessary by the Practice management team. Recordings are stored in accordance with the NHS Records Management Code of Practice Retention Schedule, after which they are deleted.

Overview of information held and shared:

What type of personal information do we hold about our patients?

We currently collect and process the following information about our patients:

• identity details – name, gender, sexual orientation, date of birth, NHS number.
• contact details – address, telephone, email address.
• next of kin’ details – the contact details of a close relative or friend.
• details of any carer you may have, or anyone you care for.
• details of any appointments with the GPs and nursing staff.
• reports from secondary care of any A&E visits, inpatient stays, or clinic appointments.
• results of any scans, X-rays and pathology tests requested.
• details of any diagnosis and treatments given.
• details of any longstanding health concerns and conditions.
• details about your health, treatment and care and other relevant information from health professionals, care providers or relatives who care for you.
• details about any funding for continuing health care or personal health budget support you have sought.
• information about any allergies.
• information about any DNAR decisions and any living wills that we know of.
• details from where you have signed up to our newsletter/patient participation group.
• correspondence from other Health and Social Care providers that provide you with services.

We work with a number of Health and Social care organisations and independent treatment centres in order to provide you with the best possible care and options for treatment. Your information may therefore be shared securely to provide continuity of care.

Sharing patient information

We know that good communication with other healthcare professionals involved in your care is beneficial to you, and so we work closely with many organisations in order to provide you with the best possible care. This means that if another healthcare professional or service is involved in your care, it might be appropriate to share information with them in order for you to receive the required care.

Your information will be shared between those involved in providing health care services and treatments to you. This includes doctors, nurses and allied health professionals, but may also include administrative staff who deal with booking appointments or typing clinic letters.

Access to information is strictly controlled and restricted to those who need it in order to do their jobs. All of our staff receive annual mandatory training on confidentiality and data security and also have strict contractual clauses within their employment contracts which oblige them to respect data protection and confidentiality.

Who we share with

The Practice shares and receives patient information from a range of organisations or individuals for a variety of lawful purposes, including:

• hospitals and other NHS organisations for the purposes of providing direct care and treatment to the patient, including assessment and clinical decision making in nursing and residential care homes, screening programmes, and administration.
• social workers or to other non-NHS staff involved in providing health and social care.
• specialist employees or organisations for the purposes of clinical auditing.
• those with parental responsibility for patients, including guardians, to support your care.
• family members and carers without parental responsibility, to support your care.
• medical researchers for research purposes (subject to explicit consent, unless the data is anonymous).
• NHS managers, Commissioning Support Units, Integrated Care Boards, NHS England and the Department of Health for the purpose of planning, commissioning, managing and auditing healthcare services.
• bodies with statutory investigative powers e.g. the Care Quality Commission, the GMC, the Audit Commission and Health Services Ombudsman.
• national registries e.g. the UK Association of Cancer Registries.
• NHS 111 to support the provision of medical help and advice.
• Department for Work and Pensions to improve the monitoring of public health and commissioning and quality of health services through the provision of anonymised data on patients who have been issued with a fit note under the Fit for Work scheme.
• contracted third party processors for the purposes of responding to requests for medical reports and subject access requests.
• approved health app providers to allow you to enter your own health data into the apps for clinical observation and monitoring.
• ambulance trusts for the provision of direct care and emergency treatment to the patient.
• independent contractors such as dentists, opticians, pharmacists.
• solicitors, insurance companies, the Courts (including a Coroners Court), tribunals and inquiries where required by law or with your consent.
• non-NHS organisations which are also providing health, care and emergency/front line services. These organisations may include, but are not restricted to, social services, education services, local authorities, the police, fire and rescue services, voluntary sector providers, and private sector providers.
• authorised sub-contractors, including those supporting the collection of QOF data.
• third party processors such as IT software and systems suppliers or internet and telephony suppliers for the provision of systems and technical support services. This includes systems, for example, the electronic patient record and practice telephony systems, and software such as that used for e-consultations, video communications, redaction, text and SMS messaging.

Confidential patient identifiable information is only shared with other organisations where there is a legal basis to do so, such as:

• when there is a Court Order or a statutory duty to share patient data.
• where there is a statutory power to share patient data.
• when the patient has given his/her explicit consent to the sharing.
• when the patient has implicitly consented for the purpose of direct care.
• when the sharing of patient data without consent has been authorised by the Health Research Authority’s Confidentiality Advisory Group (HRA CAG) under s.251 of the NHS Act 2006.

Patient identifiable information is only shared on a need- to- know basis, where there is a direct purpose to do so, limited to what is necessary for that purpose. Patient information may be shared, for the purposes of providing direct patient care, with other NHS provider organisations such as NHS Acute Trusts (hospitals), NHS Community Health, other NHS General Practitioners (GPs), NHS Ambulance services in order to maintain patient safety; this data will always be identifiable. For the purposes of commissioning and managing healthcare, patient information may also be shared with other types of NHS organisations such as NHS Dorset, and NHS England. In such cases, the shared data is made anonymous or pseudonymised, wherever possible, by removing all patient identifiable details, unless the law requires the patient’s identity to be included.

Patients are not legally or contractually obliged to share information with their healthcare provider however, your care will be affected if your clinicians do not have the relevant information necessary in order to diagnose and treat you. If you have set sharing and opt-out preferences these will be respected where there is no lawful obligation to share the information.

Tier Two – Purposes of processing, opting out of processing, retention and your rights

Purposes of processing

Our Practice processes patient data for the following primary purposes:

• providing direct healthcare.
• providing other healthcare providers with information regarding your healthcare.
• supporting social care with safeguarding vulnerable patients.

We keep records in order to:

• have accurate and up to date information available to the right care and treatment options.
• have information available to clinicians that you may see or be referred to at another NHS organisation or organisation providing NHS services.

Summary Care Record (SCR)

There is a national NHS healthcare records database provided and facilitated by NHS England, which holds your Summary Care Record (SCR). Your SCR is an electronic record which contains information about the medicines you take, allergies you suffer from and any bad reactions to medicines you have had. Storing information in one place makes it easier for healthcare staff to treat you in an emergency, or when your GP Practice is closed. This information could make a difference to how a doctor decides to care for you, for example which medicines they choose to prescribe for you.

Only healthcare staff involved in your care will access your Summary Care Record. When you are registered with a GP Practice in England your Summary Care Record is created automatically. It is not compulsory to have a Summary Care Record. If you choose to opt-out, you need to inform the Practice.

For further information about SCR, visit the NHS England website

Following the Covid pandemic, a change has been made to the way Summary Care Records are made available, to enable health and care professionals to have better medical information about the patient they are treating at the point of care. If you have not previously expressed a preference with regard to your SCR, both the core information set out above, and additional information below will be included in your SCR by default. The additional information includes:

• significant medical history (past and present).
• reason for medication.
• anticipatory care information (such as information about the management of long-term conditions).
• end of life care information.
• information about your immunisations.

Specific sensitive information such as any fertility treatments, sexually transmitted infections, pregnancy terminations or gender reassignment will not be included, unless you specifically ask for any of these items to be included.

GP Connect

We use a facility called GP Connect to support your direct care. GP Connect makes patient information available to all appropriate clinicians when and where they need it, to support direct patient care, leading to improvements in both care and outcomes. GP Connect is not used for any purpose other than direct care.

Authorised Clinicians such as GPs, NHS111 Clinicians, Care Home Nurses (if you are in a Care Home), Secondary Care Trusts, Social Care Clinicians are able to access the GP records of the patients they are treating via a secure NHS England service called GP connect.

The NHS 111 service (and other services determined locally e.g. other GP Practices in a Primary Care Network) will be able to book appointments for patients at GP Practices and other local services. For additional information about the GP Connect facility, visit the NHS England website.

OpenSAFELY

NHS England has been directed by the Government to establish and operate the OpenSAFELY service. This service provides a Trusted Research Environment that supports COVID-19 research and analysis. Each GP practice remains the controller of its own patient data but is required to let researchers run queries on pseudonymised patient data. This means identifiers are removed and replaced with a pseudonym, through OpenSAFELY. Only researchers approved by NHS England are allowed to run these queries and they will not be able to access information that directly or indirectly identifies individuals.

Read more about OpenSAFELY here

GP clinical system – electronic patient records

Our Practice uses an electronic patient record to securely process and share information between NHS staff. This means that the healthcare professional who is caring for you can see your medical history, including any allergies and current medications, to provide you with safe care.

Our Practice uses SystmOne as our Electronic Patient Record.

Find out more about SystmOne on the TPP Website here

Enhanced data sharing model (EDSM) in SystmOne

We are able to share clinical information about your health and care requirements held on your SystmOne electronic patient record with other health organisations including other GP practices, child health services, community health services, hospitals, out of hours, continuing healthcare team at NHS Dorset and other similar organisations. This means that the healthcare professional looking after you has the most relevant information to enable them to provide you with the most appropriate care. We automatically set up the sharing facility in our electronic patient record system to allow your information to be shared out to other health organisations for the purpose of direct patient care.

Local trusted organisations that we work with on a regular basis are able to access your record immediately once they have asked your permission. If you say “no” they will not be able to see any information. An audit log is maintained, showing who accessed your record and when it was accessed. You are entitled to request a copy of this log.

If you see a healthcare professional outside your local geographic area (who also uses SystmOne), and you agree that they can have access to your medical records, you will be asked to provide additional security details in the form of a verification code which is sent to you either as a text, email or via your SystmOnline account. It is therefore important that we always have your up-to-date contact details.

If you do not wish us to share your information in this way, please let us know at Reception and we will ensure that your information is not shared.

Primary Care Networks

Primary Care Networks (PCNs) are groups of GP Practices working closely together with their local partners (e.g. other primary and community care staff, mental health, social care, pharmacy, hospital and voluntary services) for the benefit of patients and the local community. Our Practice is part of Christchurch PCN, alongside Stour, Christchurch Medical and Farmhouse Practices.

Working as part of a network rather than a stand-alone business means that the GP Practices in our PCN can share expertise and resources which means that we can offer a wide range of services to suit the needs of our local community to give you the best possible care. You may be seen by clinicians from anywhere in our PCN, at any of our Practices. In order that they can give you the best possible care, they will have access to your health data. Only healthcare staff involved in your care will have access to your record.

Social Prescribing

Social prescribing enables GPs, nurses and other primary care professionals to refer patients to a range of local, non-clinical community services to help patients to improve their health, wellbeing and social welfare. This can include advice and information on local services and connecting individuals to social activities, clubs, groups, and like-minded individuals in the community. For example, signposting people who have been diagnosed with dementia to local dementia support groups. The Practice will do this by employing someone to act as a ‘link’ between the Practice, the patient and the non-clinical services within the community. Current providers in our area include:

• Livewell Dorset
• Home Start West Dorset
• Help and Care

We will refer you to one of these providers and will send basic information such as name, NHS number, address, date of birth and background to your health and wellbeing needs. The providers are bound by confidentiality in the same way that Practice staff are, and there is a Data Sharing Agreement in place to ensure that personal data is used in a lawful and appropriate way. More information about social prescribing can be found on the NHS England website.

Dorset Care Record (DCR)

Health and social care organisations in Dorset may hold different sets of records about you, and not every organisation uses SystmOne. The Dorset Care Record is a confidential computer record that joins up all these different records to create one complete and up to-date record. This provides direct access for authorised health and social care professionals to obtain as full a picture as possible of your history, needs, support and service contacts.

If you do not wish your information to be shared in this way, you will need to opt-out of the Dorset Care Record. You can do this by contacting the Data Protection Officer (details provided on the DCR website). There is a Privacy Notice for the Dorset Care Record which sets out how they use your information.

Dorset Integrated Care Board (ICB)

Dorset’s integrated care board, named ‘NHS Dorset’, undertakes the statutory responsibilities of the previous Clinical Commissioning Group (CCG) and is responsible for healthcare planning to meet the needs of people and communities in Dorset. NHS Dorset will work more closely with other NHS organisations and local authorities in Dorset’s integrated care system, known locally as ‘Our Dorset’ to improve services to meet the needs of local people and deliver better outcomes. The partnership includes:

• Foundation Trusts: Dorset County Hospital NHS Foundation Trust, University Hospitals Dorset NHS Foundation Trust, Dorset Healthcare University NHS Foundation Trust and South Western Ambulance Service NHS Foundation Trust.
• Bournemouth, Christchurch and Poole Council, and Dorset Council.
• Public Health Dorset.
• People and communities within Dorset.

NHS Dorset have a ‘Dorset Intelligence and Insight’ (DiiS) Business Intelligence platform which uses pseudonymised data to reveal important insights into local and community health care, in order to inform the future of health care for communities. Information is pseudonymised so that when a new service is introduced to help with a particular long- term condition in a particular community, the Practice can ask for any of their own patients to be re-identified from the data in order to invite you to use the new service.

Diabetic eye screening

The Dorset Diabetic Eye Screening Programme is provided by NEC Care, commissioned by NHS England South (Wessex) as part of the National Diabetic Eye Screening Programme. The programme supports your invitation for eye screening and ongoing care by the screening programme. Your information may be shared with any Hospital Eye Services you are under the care of to support further treatment, and with other healthcare professionals involved in your care. We also share information with Health Intelligence in order to provide diabetic retinopathy screening for our diabetic patients.

Find out more about the Diabetic Eye Screening Programme on their website

Diabetes prevention programme

The Healthier You: NHS Diabetes Prevention Programme is provided in Dorset by ‘Live Well Taking Control (LWTC)’, commissioned by NHS England, as part of the National Diabetes Prevention Programme. This programme identifies those at high risk of Type 2 diabetes and refers them onto a behaviour change programme run by ‘Live Well Taking Control’.

Find out more about the Diabetes Prevention Programme on their website

Our practice website

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Individual funding request

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

Invoice validation

Invoice validation is an important process. It involves using your NHS number to check which ICB is responsible for paying for your treatment. We can also use your NHS number to check whether your care has been funded through specialist commissioning, which NHS England will pay for. The process makes sure that the organisations providing your care are paid correctly.

Incident management

If you are involved in an incident, for example you slip and fall whilst in the Practice, your information may be included in the incident report and used as part of the investigation process.

Complaints and queries

If you raise a complaint or query with the Practice, the team will hold information about you within their secure database in order to ensure that your complaint or query is answered appropriately by the relevant person or department. Details of complaints or queries will not be stored within your medical records.

Secondary Uses

We may also process data for the following secondary uses:

• Clinical Research: sometimes your information may be requested to be used for research purposes – the practice will always gain your consent before using information for this purpose. All NHS organisations are expected to participate and support health and care research, and further information about this can be found here.
• Clinical Audit: information may be used for audit to monitor the quality of the service provided. Some of this information may be held centrally and used for statistical purposes. Where this is done we make sure that individual patient records cannot be identified, e.g. the National Diabetes Audit. Audits will have approval from the Clinical Advisory Group, under s.251 of the NHS Act 2006 and data submissions will be signed off by our Caldicott Guardian.
• Improving Services: NHS Dorset will sometimes extract pseudonymised medical information about you to help identify areas for improvement in the services provided to you.
• Risk Stratification: data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or (re)admission and identifying a need for preventive intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP Practice. A risk score is then arrived at through an analysis of your de-identified information using software managed by NHS approved third parties and is only provided back to your GP as data controller in an identifiable form. Through the Dorset Intelligence & Insight Service (DiiS) we are working to improve short term and medium-term health outcomes for local populations through the application of Population Health Management and Analysis. The DiiS, set up and run by NHS staff across Dorset and hosted within Dorset HealthCare, pseudonymise at source and extract the data to analyse the use of services and identify areas for prevention and improvement in overall patient health and well-being outcomes. A small number of specialist analytics staff from NHS Trusts manage this data within the DiiS platform. In addition, the DiiS work with Sollis to provide risk stratification of this data which enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary, your GP may be able to offer you additional services including social prescribing.
• National Archiving: records made by an NHS organisation are Public Records in accordance with Schedule 1 of the Public Records Act 1958. The Public Records Act 1958 requires organisations to select core records for permanent preservation at the relevant Place of Deposit (PoD) appointed by the Secretary of State for Culture, Media and Sport. PoDs are usually public archive services provided by the relevant local authority. The selection and transfer must take place at or before records are 20 years old and is a separate process from appraisal for retention to support current service provision. Potential transfers of digital records should be discussed with the PoD in advance to ensure that technical issues can be resolved. Records no longer required for current service provision may be temporarily retained pending transfer to a PoD and records containing sensitive personal data should not normally be transferred early.

These secondary uses help the NHS to:

• prepare and analyse statistics on NHS performance.
• audit NHS services, locally and nationally.
• monitor how we spend public money.
• plan and manage health services for the population of Dorset.
• conduct health research and development of treatments.

Our Practice values the concept of data minimisation and will use anonymised or pseudonymised information as much as possible. We rely on UK GDPR Articles 6(1)(e) and Articles 9(2)(h) for lawfully processing identifiable data. Where you have opted-out of the use of identifiable data for secondary purposes, your data will not be used unless it is anonymised or unless there is a legal obligation for us to process it.

Cross Border Transfers between the UK, the EU, other third countries or international organisations

Following the UK’s exit from the European Union the UK has now become a third country under the EU GDPR. An adequacy decision for the UK has been approved by the EU Commission under Article 45(3) of the EU GDPR, allowing the free flow of personal data between the EU and the UK to continue. The Practice does not routinely transfer data outside of the European Economic Area and will assess any ad-hoc transfers against adequacy (UK GDPR Article 45) and appropriateness of safeguards and data protection (UK GDPR Article 46) of the country of transfer.

Opting out of processing

National data opt-out

Whenever you use a health or care service, important information about you is collected in your patient record for that service to ensure you get the best possible care and treatment. The information collected about you when you use these services can also be used and provided to other organisations for purposes beyond your individual care, for instance to help with:

• improving the quality and standards of care provided
• research into the development of new treatments
• preventing illness and diseases
• monitoring safety
• planning services

This may only take place when there is a clear legal basis to use this information. Confidential patient information about your health and care is only used like this where allowed by law. Most of the time, anonymised data is used for research and planning so that you cannot be identified in which case your confidential patient information isn’t needed. You have a choice about whether you want your confidential patient information to be used in this way. If you are happy with this use of information you do not need to do anything. If you do choose to opt out your confidential patient information will still be used to support your individual care.

Patients can view or change their national data opt-out choice at any time by using the online service at www.nhs.uk/your-nhs-data-matters, or by calling 0300 3035678.

For further information:

Which covers health and care research:

Visit the HRA website

Which covers how and why patient information is used, the safeguards and how decisions are made: understanding patient data

Data being used or shared for purposes beyond individual care does not include your data being shared with insurance companies or used for marketing purposes and data would only be used in this way with your specific agreement.

Our Practice is compliant with the national data opt-out policy which means that we have systems and processes in place to comply with the national data opt-out so that your choice can be applied to any confidential patient information we use or share for purposes beyond your individual care.

Type 1 opt-out

Patients can opt out of their confidential patient information being used for purposes beyond their individual care without their explicit consent. This opt-out applies to flows of data under the Health and Social Care Act 2012, section 259. If you do not want your personally identifiable patient data to be shared outside of the Practice for purposes other than your own care, you can register a Type 1 opt-out by completing a Type 1 opt-out form available at reception.

Retention The Practice works to the NHS Records Management Code of Practice Retention Schedule for the retention of our patient information.

Data subject rights

The law gives you certain rights to your personal healthcare information that we hold:

1. Right of access to your information

You have the right to request a copy of the personal information that we hold about you; this is known as a Subject Access Request. We have one month to reply to you and give you the information that you require. This can be extended by two further months if the request is complex or we have received a number of requests from you. Subject Access Requests can be made by you the patient, by a legal representative; a solicitor acting on your behalf, a carer, parent, guardian or appointment representative, with appropriate consent. A personal representative also has the right of access to deceased records.

If you would like a copy of the information we hold about you, please contact: Kelly Adams – kelly.adams@dorsetgp.nhs.uk

We will provide this information free of charge however, we may in some limited and exceptional circumstances have to make an administrative charge for any extra copies if the information requested is excessive, complex or repetitive.

We can restrict disclosure of your information if your doctor feels that granting access would disclose information likely to cause serious harm to your physical or mental health or that of another individual, and where you do not already know the information. Or where granting access would disclose information relating to or provided by a third party who could be identified from the information, and who has not provided consent for it to be released.

NB: Patient online access

All GP surgeries are required to give all patients in England online access to new information as it is added to their GP health record. Patients with online accounts, such as through the NHS App, should be able to read new entries, including free text, in their health record. This applies to future (prospective) record entries and not historic data. More information about accessing online patient GP health records can be found here.

2. Right to restrict or object to the use of your information

We cannot share your information with anyone else for a purpose that is not directly related to your health without your consent. Patients have the right to restrict the processing of your personal information for secondary purposes through NHS England’s National Data Opt-Out. More information is available here.

The right to restrict processing of healthcare data can only be exercised in the following circumstances:

• the accuracy of the data is contested.
• the processing is unlawful.

3. Right to have incorrect information corrected

If you feel that information held about you is incorrect, you have the right to ask for it to be corrected. This applies to matters of fact, not opinion. Incorrect contact information such as your address will be corrected immediately. If the information is of a clinical nature, this will need to be reviewed and investigated by the Practice, which will result in one of the following outcomes:

• the Practice considers the information to be correct at the time of recording and will not amend the data. A statement from you may be placed within the record to demonstrate that you disagree with the information held. You have the right to appeal to the Information Commissioner.
• the Practice agrees that the information is incorrect, however it is not legal to modify or remove information within the record as it represents ‘historical information’ which may have influenced subsequent events of decisions made.  In these circumstances, a note will be made in the record which advises the reader of the inaccuracy and of the correct facts.  The practice will agree the content of the note with you.

4. Right to data portability

This right only applies where the original processing is based on the data subject’s consent or fulfilment of a contract that they are party to, and if the processing is automated.  However, in the spirit of the Regulations, you have the right to request that your personal and/or healthcare information is transferred, in and electronic or other form, to another organisation.

5. Right to appropriate decision making

The right to appropriate decision making applies to automated processing, including profiling, which produces legal outcomes, or that significantly affects you.  The Practice has not identified any automated processing which is solely automated and without human involvement in the outcome of the processing.

6. Right to erasure

This is sometimes known at the right to be forgotten, but it is not an absolute right.  You cannot ask for this right of erasure in relation to records which the Practice is legally bound to retain.  The Practice has an obligation, not only to retain information for a specified time period, but also not to retain information for longer than is necessary and will dispose of information securely.  Please see above section on retention.

7. Right to lodge a complaint

If you are dissatisfied with the handling of your personal information, you have the right to make a complaint.  In the first instance, formal complaints should be addressed to: Janet Newman Business Manager – janet.newman@dorsetgp.nhs.uk.

You also have the right to make a complaint to the Information Commissioner’s Office – the independent regulator of data protection:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Or by using their online submission.

The law explained

Data Protection Principles

There are six core principles to data protection legislation:

1. Personal data must be processed lawfully, fairly and transparently (lawfulness, fairness and transparency).
2. Personal data must be collected for specific, explicit and legitimate purposes and not processed in a manner that is incompatible with those purposes (purpose limitation).
3. Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (data minimisation).
4. Personal data must be accurate and up to date (accuracy).
5. Personal data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation).
6. Personal data is processed in a manner that ensures appropriate Security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (integrity and confidentiality).

Data Controller and processors

The Practice is the Data Controller of the data which we gather, hold, and create about you.

The Practice engages with data processors who may process your data.  All Data Processors are held to strict contractual obligations, which specify the limitations, any access arrangements, storage and retention of the data on our behalf as well as strict confidentiality and information handling clauses.  All data processors are also held to high information security standards and are asked to provide evidence of how they meet Data Protection legislation.  These processors may be software suppliers or specialist and support services.

Lawful basis

The Practice processes personal data for primary purposes under the following legal bases:

General Data Protection Regulation 2016/679 Article 6(1)(e):
“Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”

For the processing of personal data for secondary purposes the Practice may rely on one of the following legal basis depending on the circumstances:

General Data Protection Regulation 2016/679 Article 6(1)(c):
“Processing is necessary for compliance with a legal obligation to which the controller is subject”

There are some National Audits and patient registers which require the Practice to process your information under Article 6(1)(c) in accordance with UK legislations such as the National Health Service Act 2006 and Health and Social Care (Safety and Quality) Act 2015.

There are also obligations within the Crime and Disorder Act 1998, Terrorism Act, Children’s Act(s) 1989 and 2004, Mental Health Act 1983 and 2007 to share information with the Police or Social Services.

The Practice processes special categories of data (health data) for primary purposes under the following legal basis:

General Data Protection Regulation 2016/679 Article 9(2)(h):
“Processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health and social care systems and services on the basis of Union or Member State law or pursuant to contact with a health professional and subject to the conditions and safeguards referred to in paragraph 3”

Paragraph 3:  “Personal data referred to in paragraph 1 [special categories of data] may be processed for the purposes referred to in point (h) of paragraph 2 when those data are processed by or under the responsibility of a professional subject to the obligation of a professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.”

General Data Protection Regulation 2016/679 Article 9(2)(b):
“Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and interests of the data subject”

The Practice processes special categories of data for secondary purposes under the following legal basis:

General Data Protection Regulation 2016/679 Article 9(2)(j):
“Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subjects”

General Data Protection Regulation 2016/679 Article 9(2)(i):
“Processing is necessary for reasons of public interest in the areas of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy.”

Where data has been anonymised it is not considered to be personal data and the General Data Protection Regulations 2016/679 and Data Protection Act 1998 will not apply. The Practice will use anonymous data for audit and population health management.

Occasionally, the Practice may rely on consent as a legal basis:

General Data Protection Regulation 2016/679 Article 6(1)(a):
“The data subject has given consent to the processing of his or her personal data for one or more specific circumstances”

Where you are asked for your consent to take part in Research, Clinical Trials or Audits, your care will not be affected if your decline to take part.  Research and Audit are vital for the NHS to evaluate and improve Healthcare for everyone.

General Data Protection Regulation 2016/679 Article 9(2)(a):
“The data subject has given explicit consent to the processing of those personal data for one of more specified purposes”

However, these circumstances will be few and the Practice will not rely on consent where there is another lawful basis that we should use.

General Data Protection Regulation 2016/679 Recital 43 specifies that for consent to be freely given it
“Should not provide a valid legal ground for the processing of personal data in a specific case where there is a clear imbalance between the data subject and the controller, in particular where the controller is a public authority and it is therefore unlikely that consent was freely given in all the circumstances of that specific situation.”

Our Practice upholds transparency and fairness through the use of this privacy notice. We uphold data minimisation techniques like pseudonymisation and anonymisation where possible to protect data and ensure that the purpose of processing is relevant and adequate.

The Practice holds data security in the highest importance; our systems have role based access and clinical systems are auditable to ensure transparency in the use of systems by staff.  Devices are encrypted and all our staff undertake annual mandatory data security training.

Where else to find our privacy notice

A copy of this notice is behind the main reception desk and you can request a copy from the reception team.

Social media is a type of interactive online media that allows parties to communicate instantly with each other and allows the sharing of data in a public forum. Examples of social media include but are not limited to X, Facebook, LinkedIn, You Tube, Flickr, WhatsApp, Instagram and Snapchat.

Patient Use of Social Media

Highcliffe Medical Centre have a duty to protect our staff from online abuse which can be very upsetting. We encourage patients to feedback to the surgery through appropriate channels and we can then act on it as necessary. Legal advice will be sought and the appropriate action taken against any patient who posts defamatory comments. Feedback is a useful part of the interaction between Highcliffe Medical Centre and its patients and other service users. However, derogatory or hurtful comments about Highcliffe Medical Centre or staff on social media are not an acceptable part of the relationship between both parties. Defamatory comments about our team are not to be shared on any social media platform.

Notice of Practice Action towards patient abuse on Social Media

“Non-physical assault, physical, verbal or racial abusive behaviour is NOT acceptable and will NOT be tolerated at Highcliffe Medical Centre. Everyone has a duty to behave in an acceptable and appropriate manner. Staff have a right to work, as patients have a right to be treated, free from fear of assault and abuse, in an environment that is properly safe and secure.  The NHS defines non-physical assault as: “the use of inappropriate words or behaviour causing distress and/or constituting harassment”. Patients who are abusive to, or physically/ non-physically assault any Highcliffe Medical Centre Staff or other patients whilst in our Practices will be removed from the practice list, along with those registered at the same household. Mutual respect is expected at all times.”

More Information on Subject Access Request Procedure

Your Summary Care Record is a short summary of your GP medical records. It tells other health and care staff who care for you about the medicines you take and your allergies.

What is an SCR?

If you are registered with a GP Practice in England, you will already have an SCR unless you have previously chosen not to have one.

It includes the following basic information:

• Medicines you are taking
• Allergies you suffer from
• Any bad reactions to medicines

It also includes your name, address, date of birth and unique NHS Number which helps to identify you correctly.

What choices do you have?

You can now choose to include more information in your SCR, such as significant medical history (past and present), information about management of long term conditions, immunisations and patient preferences such as end of life care information, particular care needs and communication preferences.

Your SCR is available to authorised healthcare staff providing your care anywhere in England, but they will ask your permission before they look at it. This means that if you have an accident or become ill, healthcare staff treating you will have immediate access to important information about your health.

This Practice supports SCR however, as a patient you have a choice:

• If you would like an SCR you do not need to do anything and an SCR will be created for you

• If you do NOT want an SCR please contact us online, or alternatively please get in touch with the practice to complete a paper form.

Remember, you can change your mind about your SCR at any time. Talk to our Practice if you want to discuss your option to add more information or decide you no longer want an SCR. If you do nothing we will assume you are happy for us to create a SCR for you.

Vulnerable patients and carers

Having an SCR that includes extra information can be of particular benefit to patients with detailed and complex health problems. If you are a carer for someone and believe that this may benefit them, you could discuss it with them and their GP Practice.

Who can see my SCR?

Only authorised, professional healthcare staff in England who are involved in your direct care can have access to your SCR. Your SCR will not be used for any other purposes.

These staff:

• Need to have a Smartcard with a chip and passcode
• Will only see the information they need to do their job
• Will have their details recorded every time they look at your record

Healthcare professionals will ask for your permission if they need to look at your SCR. If they cannot ask you because you are unconscious or otherwise unable to communicate, they may decide to look at your record because doing so is in your best interest. This access is recorded and checked to ensure that it is appropriate.

SCRs for children

If you are the parent or guardian of a child under 16, and feel they are able to understand this information you should show it to them. You can then support them to come to a decision about having an SCR and whether to include additional information. You may request to opt them out of SAR; any opt-out requests on behalf of children will be carefully considered.

Confidentiality

For information on how the NHS will collect, store and allow access to your electronic records visit the NHS website.

More Information on the NHS Constitution for England

More Information on Your NHS Data

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.