Practice Policies

1. Purpose

This policy outlines the practice’s approach to requests for ADHD and autism assessments, referrals, diagnosis and prescribing responsibilities for registered patients.

The practice is committed to providing inclusive, respectful and appropriate healthcare for patients with suspected or diagnosed Attention Deficit Hyperactivity Disorder (ADHD) and Autism Spectrum Disorder (ASD).

The practice recognises the importance of timely assessment, appropriate specialist involvement and ongoing support for patients with neurodevelopmental conditions.

This policy sets out the practice’s position on NHS referrals, NHS Right to Choose referrals, privately obtained assessments and requests for shared care prescribing.

2. Scope

This policy applies to adult and paediatric patients registered with the practice who:

1. Are requesting assessment for suspected ADHD or autism.
2. Are seeking referral to an NHS specialist assessment service.
3. Wish to access an alternative provider through NHS Right to Choose.
4. Have obtained an ADHD or autism assessment privately.
5. Are requesting ongoing ADHD medication or shared care prescribing following specialist assessment and treatment.

3. Practice position

The practice does not undertake formal diagnostic assessments for ADHD or autism. Assessment and diagnosis must be undertaken by an appropriately qualified healthcare professional or specialist service with the relevant expertise.

The practice is happy to support patients seeking assessment through appropriate NHS pathways, including NHS Right to Choose where eligibility criteria are met.

The practice will also consider information and recommendations from private assessment providers. However, a private diagnosis does not automatically mean that the practice will accept prescribing or monitoring responsibilities.

All requests for shared care prescribing will be considered individually, taking account of the provider, the assessment undertaken, the proposed treatment, the relevant NHS-approved shared care protocol and the GP’s ability to prescribe safely.

The practice reserves the right to decline shared care arrangements where the required clinical or governance standards are not met or where the GP does not feel competent to undertake the prescribing responsibilities.

A decision not to accept shared care prescribing will not affect a patient’s entitlement to other appropriate primary care services.

4. ADHD assessments and referrals

Patients who believe they may have ADHD can discuss their symptoms and concerns with the practice.

The GP may undertake an initial clinical discussion to understand the patient’s difficulties, the impact on their daily functioning and whether referral for specialist assessment is appropriate.

The GP does not provide a formal ADHD diagnosis or initiate ADHD medication as part of the initial assessment.

Where appropriate, patients may be referred through:

1. The local NHS ADHD assessment pathway.
2. NHS Right to Choose, where the patient meets the relevant eligibility criteria and the chosen provider offers an appropriate NHS-commissioned service.
3. Other appropriate specialist pathways where clinically indicated.

The practice will follow current NHS Greater Manchester referral arrangements and relevant local guidance.

Referral does not guarantee a diagnosis or subsequent medication treatment. These decisions remain the responsibility of the assessing specialist.

5. Autism assessments and referrals

Patients who believe they may be autistic can discuss their concerns with the practice.

The GP may undertake an initial clinical discussion and consider referral to an appropriate specialist autism assessment service.

Autism assessments and diagnoses must be undertaken by an appropriately qualified specialist or multidisciplinary team in accordance with relevant NICE guidance.

Patients may be referred through:

1. The local NHS autism assessment pathway.
2. NHS Right to Choose, where the patient meets the relevant eligibility criteria.
3. Other appropriate specialist pathways where clinically indicated.

The practice does not undertake formal autism diagnostic assessments.

An autism diagnosis does not routinely require medication or shared care prescribing. Where medication is required for associated conditions, this will be considered separately according to the relevant clinical circumstances and prescribing arrangements.

6. NHS Right to Choose

The practice recognises patients’ legal rights to choose an eligible provider for NHS-funded ADHD and autism assessments under the NHS Right to Choose arrangements.

Patients wishing to exercise this right should discuss their preferred provider with the practice.

The practice will consider requests in accordance with current NHS Greater Manchester guidance, relevant eligibility criteria and the commissioned services available from the chosen provider.

The chosen provider must be eligible to receive the relevant NHS referral and provide the service requested.

Patients should be aware that:

1. Not all providers offer both ADHD and autism assessments.
2. Not all providers offer medication initiation or ongoing treatment.
3. Some providers offer assessment only.
4. The availability of post-diagnostic support and ongoing specialist care varies between providers.
5. A referral for assessment does not guarantee that the practice will subsequently accept shared care prescribing.

The practice will consider shared care requests from eligible Right to Choose providers in accordance with Section 9 of this policy.

7. Privately obtained ADHD and autism assessments

The practice recognises that some patients may choose to access private ADHD or autism assessments.

Patients who have obtained a private diagnosis may provide their assessment report to the practice for their clinical records.

The practice may review the information provided and consider whether any further primary care support, investigations or referrals are appropriate.

A private diagnosis does not automatically transfer clinical responsibility to the GP practice.

The practice will not routinely repeat specialist assessments or independently validate a diagnosis made by another provider. Where there are concerns about the adequacy of the assessment, the GP may recommend further specialist review.

Requests for ADHD medication prescribing following a private assessment will be considered in accordance with the shared care arrangements outlined in this policy.

8. ADHD medication initiation and titration

ADHD medication requires specialist knowledge, appropriate baseline assessment, dose titration and ongoing monitoring.

In accordance with NICE guidance, ADHD medication should only be initiated by a healthcare professional with appropriate training and expertise in diagnosing and managing ADHD.

The practice does not routinely initiate ADHD medication or undertake dose titration.

Medication initiation and titration should remain the responsibility of the specialist ADHD service until:

1. The diagnosis has been confirmed.
2. Appropriate baseline assessments and investigations have been completed.
3. Medication has been initiated and titrated.
4. The patient has reached a clinically stable dose.
5. An appropriate shared care protocol is in place.
6. The GP has reviewed and formally accepted the shared care arrangement.

The specialist service must provide sufficient clinical information and remain available to provide advice regarding treatment and any concerns arising during ongoing care.

9. ADHD shared care prescribing

The practice is willing to consider shared care prescribing requests from:

1. NHS ADHD specialist services.
2. NHS Right to Choose providers.
3. Private ADHD specialist providers.

All requests will be considered individually and must meet the relevant NHS-approved shared care protocol and clinical governance requirements.

The practice will only accept prescribing responsibility where:

1. The patient has received an appropriate specialist ADHD assessment.
2. The diagnosis and treatment recommendation are clearly documented.
3. The specialist has appropriate qualifications, registration and experience.
4. Medication has been initiated and titrated by the specialist.
5. The patient’s medication and dosage have been stabilised.
6. An appropriate written shared care protocol has been provided and has the required NHS approval or formal adoption by the relevant medicines management or commissioning body.
7. Baseline investigations and ongoing monitoring requirements have been completed or clearly arranged.
8. The responsibilities of the specialist provider and GP practice are clearly defined.
9. The specialist provider remains available to offer advice and undertake further specialist review where required.
10. The GP is satisfied that they have the necessary knowledge, experience and competence to prescribe safely.

The practice will consider private-provider requests where the proposed protocol and arrangements meet these requirements. The fact that a provider is private or registered with the CQC does not, by itself, establish that a shared care arrangement is appropriate or NHS-approved.

Acceptance of shared care is not automatic, even where the patient has received a diagnosis and medication recommendation from a specialist.

The practice reserves the right to decline any request where the clinical information, protocol, monitoring arrangements or specialist support are considered inadequate.

Prescribing responsibility will only transfer once the practice has reviewed the documentation and confirmed acceptance in writing.

Until shared care has been formally accepted, prescribing and monitoring responsibility remains with the initiating specialist provider.

10. Monitoring and ongoing prescribing

Where shared care is accepted, prescribing and monitoring must follow the relevant NHS-approved shared care protocol.

Patients receiving ADHD medication must have a formal review at least annually by their ADHD specialist service or an appropriately qualified healthcare professional with expertise in ADHD management, in accordance with NICE guidance and the relevant shared care protocol.

The annual review is the responsibility of the patient to arrange directly with their specialist provider. Patients must contact their ADHD clinic or specialist service in advance of their annual review date to ensure that an appointment is arranged and completed.

The practice will not routinely arrange or chase annual specialist reviews on behalf of patients.

The annual review should consider:

1. Whether the ADHD diagnosis and ongoing need for medication remain appropriate.
2. The effectiveness of the current medication and dosage.
3. Any side effects or adverse reactions.
4. Blood pressure and pulse.
5. Weight and, for children and young people, height and growth.
6. Any changes in physical or mental health.
7. Whether treatment should continue, be adjusted or discontinued.
8. Any further specialist investigations or interventions required.

Following the annual review, the specialist provider must supply the practice with an updated clinical report confirming the outcome of the review, the ongoing treatment recommendation and any changes to the management plan.

Failure to attend or arrange the required annual specialist review

Patients are responsible for ensuring that they attend their annual specialist review and that the practice receives the necessary confirmation from their specialist provider.

Where an annual review has not taken place, or the practice has not received appropriate confirmation and recommendations from the specialist service, the practice may be unable to continue issuing repeat ADHD medication prescriptions.

The practice will contact the patient to explain that an updated specialist review is required and that prescribing may be suspended if the necessary review and documentation are not provided.

Where the required review remains outstanding, the practice reserves the right to withhold further repeat prescriptions until appropriate specialist review and confirmation have been received.

Any decision to withhold or discontinue medication will take account of the individual patient’s clinical circumstances, the medication prescribed and the need to avoid an unsafe interruption to treatment. Where necessary, the practice will liaise with the specialist provider to agree appropriate arrangements.

The practice cannot accept ongoing prescribing responsibility indefinitely without the required specialist oversight and confirmation that treatment remains appropriate.

The specialist service must remain available to provide advice, review the patient where necessary and support any changes to treatment.

11. Declining or withdrawing shared care

The practice may decline a shared care request or withdraw from an existing arrangement where:

1. The provider or protocol does not meet the required NHS approval or governance standards.
2. The specialist assessment or supporting documentation is inadequate.
3. Medication has not been appropriately stabilised.
4. The monitoring arrangements are insufficient.
5. The specialist provider is unable to offer appropriate ongoing support.
6. The patient requires treatment or monitoring outside the agreed protocol.
7. The GP has concerns about the safety or appropriateness of prescribing.
8. The GP does not feel competent to undertake the prescribing responsibilities.
9. The agreed responsibilities are not being fulfilled by the specialist provider.

Where shared care is declined or withdrawn, the practice will communicate its decision and reasons to the patient and specialist provider.

The initiating specialist provider remains responsible for prescribing and monitoring where shared care has not been accepted or has been withdrawn.

Appropriate arrangements should be discussed with the specialist provider to support continuity of treatment and avoid an unsafe interruption to medication.

12. Existing diagnoses and patients transferring from other practices

Patients transferring to the practice who already have an ADHD or autism diagnosis will be considered individually.

A previous diagnosis or prescribing arrangement does not automatically mean that the practice will accept prescribing responsibility.

Where a patient is already receiving ADHD medication under a shared care arrangement, the practice will request relevant specialist correspondence, diagnostic reports, medication history, monitoring information and the existing shared care protocol.

The GP will review the documentation before deciding whether to accept ongoing prescribing responsibility.

Where adequate information or an appropriate shared care arrangement is not available, the patient may need to be referred back to their specialist provider for further assessment or clarification.

13. Supporting patients with ADHD and autism

Regardless of whether the practice accepts shared care prescribing or whether a formal diagnosis has been made, patients will continue to receive appropriate and respectful primary care.

This includes:

1. General medical care and management of long-term conditions.
2. Mental health and wellbeing support.
3. Assessment and management of anxiety, depression and other associated conditions.
4. Support with sleep difficulties where appropriate.
5. Signposting to relevant NHS and community services.
6. Advice regarding reasonable adjustments and available support.
7. Appropriate referral to other services where clinically indicated.

The practice will ensure that patients are treated with dignity, respect and understanding.

A decision not to accept shared care prescribing will not affect a patient’s entitlement to other appropriate primary care services.

14. Children and young people

Requests involving children and young people must be considered in accordance with current NICE guidance, NHS England requirements and local NHS Greater Manchester pathways.

ADHD and autism assessments in children and young people should be undertaken by appropriately qualified specialist services.

ADHD medication should only be initiated and titrated by an appropriately trained specialist.

Requests for shared care prescribing in children and young people will be considered in accordance with the relevant age-specific NHS-approved shared care protocol.

The practice will not independently initiate ADHD medication or assume prescribing responsibility without an appropriate specialist recommendation and formally accepted shared care arrangement.

15. Review of policy

This policy will be reviewed periodically and updated in line with changes to NICE guidance, NHS England policy, NHS Greater Manchester referral pathways, Greater Manchester Medicines Management Group guidance and relevant legislation.

GDPR Privacy Notice

The Information Commissioner recognises the unprecedented challenges the NHS and other health professionals are facing during COVID-19.

The ICO (Information Commissioners Office) also recognise that ‘Public bodies may require additional collection and sharing of personal data to protect against serious threats to public health.’

On 20th March 2020 the Secretary of State for Health and Social Care issued a Notice under Regulation 3(4) of The Health Service (Control of Patient Information) Regulations 2002 requiring organisations such as GP Practices to use your information to help GP Practices and other healthcare organisations to respond to and deal with the COVID-19 pandemic.

In order to look after your healthcare needs during this difficult time, we may urgently need to share your personal information, including medical records, with clinical and non-clinical staff who belong to organisations that are permitted to use your information and need to use it to help deal with the COVID-19 pandemic.  This could (amongst other measures) consist of treating you; and enable us and other healthcare organisations to monitor the disease, assess risk and manage the spread of the disease.

Please be assured that we will only share information and health data that is necessary to meet yours and public healthcare needs.

The Secretary of State for Health and Social Care has also stated that these measures are temporary and will expire on 30th September 2020 unless a further extension is required.

Please also note that the data protection and electronic communication laws do not stop us from sending public health messages to you, either by phone, text or email as these messages are not direct marketing.

It may also be necessary to use your information and health data to facilitate digital consultations and diagnoses and we will always do this with your security in mind.

If you are concerned about how your information is being used, please contact our DPO using mhcc.ig@nhs.net.

Staff and patients

The practice is committed to ensuring that, as far as is reasonably practicable, the way in which we provide services to the public and the way in which we treat our staff reflects their individual needs and does not discriminate against individuals or groups on any grounds.

Equality and Diversity

The practice aims to promote equality and diversity and value the benefits this brings. It is our aim to ensure that all staff feel valued and have a fair and equitable quality of working life.

Human rights

The Practice is committed to the principles contained in the Human Rights Act. We aim to ensure that our employment policies protect the rights and interests of our staff and ensure that they are treated in a fair, dignified and equitable way when employed at the Practice.

Information governance

Any practice policy which impacts on or involves the use and disclosure of personal information (patient or employee) must make reference to and ensure that the content of the policy is comparable with the relevant statutory or legal requirement and ethical standards.

Data Protection Act 1998 and the NHS Confidentiality Code of Practice

The Data Protection Act (DPA) provides a framework which governs the processing of information that identifies living individuals. Processing includes holding, obtaining, recording, using and disclosing of information and the Act applies to all forms of media, including paper and images. It applies to confidential patient information but is far wider in its scope, e.g. it also covers personnel records.

The DPA provides a legal gateway and timetable for the disclosure of personal information to the data subject (e.g. Health Record to a patient, personal file to an employee). Whilst the DPA applies to both patient and employee information, the Confidentiality Code of Practice (COP) applies only to patient information. The COP incorporates the requirements of the DPA and other relevant legislation together with the recommendations of the Caldicott report and medical ethical considerations, in some cases extending statutory requirements and provides detailed specific guidance. This Equal Opportunities and Diversity Policy contains the following sections:

1. Introduction
2. Practice Statement
3. Recruitment and Selection
4. Employee relations
5. Zero Tolerance

Introduction

The practice is committed to equal opportunities and to building a valued workforce whose diversity reflects our community. Our Equality and Diversity Policy takes into account all current UK and EU legislation and guidelines, including codes of practice from the Equality and Human Rights Commission.

This Equality and Diversity Policy has been written in accordance with current best practice and has been updated in line with the Equality Act 2010.

Practice statement

Under the Equality Act 2010, it is against the law for a company to discriminate against anyone on the grounds of colour, age, sex, race/nationality – including citizenship – ethnic or national origins, marital status, civil partnership, disability, sexual orientation, gender reassignment, any religion, or religious or philosophical belief.

It is also possible for employees to claim discrimination on a combination of two of these grounds. Similarly, if employees discriminate against a colleague or patient, the Practice could be held vicariously liable for their acts and be responsible for paying the compensation or damages to the victim of the discrimination.

If the Practice can prove that it has done all that was reasonable to prevent the discriminatory acts from occurring, then its liability can be reduced or eliminated. Having an equal opportunity policy and apprising all staff of its existence is one of the things that a reasonable employer should do. The Practice has the following policies in place which need to be read along with this Equality and Diversity policy:

• Equality Act: Operational Procedures & Policy
• Culture & Religious policy
• Grievance Procedures
• Bullying and Harassment
• Age Discrimination
• Equal Opportunities policy
• Recruitment and Selection Policy
• Training and Development Policy
• Dignity at work
• Being Open Policy
• Information Governance Policy i.e. confidentiality/consent

Recruitment and selection

The practice has implemented a recruitment & selection policy. The objective of this policy is to recruit the best person for a role and outlines the responsibilities of the recruiting managers in complying with legal and locally agreed requirements.

At every stage of the recruitment process, Managers will treat all applicants equally, showing no discrimination on the grounds of their ethnic origin or nationality, disability, gender, gender reassignment, marital status, age, sexual orientation, race, trade union activity or political or religious beliefs. Applicants will be selected against criteria based solely on objective, job-related criteria and their ability to do the job applied for. The Practice will consider providing appropriate assistance to ensure equality for all.

Relevant educational, training and development opportunities are open to all staff and all staff have a personal development plan in place, which must be reviewed annually. Information on education, training and development opportunities is widely publicised, and attendance is monitored for.

Monitoring information is gathered periodically to ensure there are no inequalities in opportunities for promotion.

Employee relations

The Practice has developed several ‘Employee Friendly’ Policies and also has in place Disciplinary, Dignity at Work and Grievance Policies to process employee relations issues. As with any Practice Policy, these are fair and consistent in their manner. Practice policies do not discriminate against anyone on the grounds of colour, age, sex, race/nationality – including citizenship – ethnic or national origins, marital status, civil partnership, disability, sexual orientation, gender reassignment, any religion, or religious or philosophical belief. Instances of harassment under any of the above are treated very seriously and are addressed under the Dignity at Work and Disciplinary Policies.

The ICO has published a new Model Publication Scheme that all public authorities are required to adopt. For more information please visit the ICO website.

1. Purpose

This policy outlines the practice’s approach to requests for prescribing and monitoring gender-affirming hormone treatment for transgender and gender-diverse patients.

The practice is committed to providing inclusive, respectful and appropriate healthcare for all patients, including those who are transgender or experiencing gender incongruence.

Hormone treatments for gender incongruence require specialist assessment, prescribing expertise and ongoing monitoring. This policy sets out the circumstances in which the practice may consider accepting prescribing responsibility under an appropriate NHS-approved shared care arrangement.

2. Scope

This policy applies to patients registered with the practice who:

1. Are seeking or receiving gender-affirming hormone treatment.
2. Have been assessed by an NHS gender identity service or a private gender specialist provider.
3. Are requesting that the practice accepts prescribing and monitoring responsibilities under a shared care arrangement.

This policy covers requests relating to feminising and masculinising hormone treatments.

3. Practice position

The practice does not routinely initiate or prescribe hormone treatments for gender incongruence outside an appropriate formal NHS-approved shared care protocol.

The practice is happy to work with NHS gender identity services, including Indigo Gender Service, where an appropriate shared care arrangement is in place.

The practice is also willing to consider shared care requests from private gender specialist providers, provided that the proposed shared care protocol and arrangements have appropriate NHS approval and meet the required clinical and governance standards.

All requests will be reviewed individually. Acceptance of a shared care arrangement is not automatic and remains at the discretion of the prescribing GP.

The practice will only accept prescribing responsibility where:

1. The patient has undergone an appropriate specialist assessment.
2. Treatment has been recommended by an appropriately qualified and experienced specialist.
3. A formal written shared care protocol is in place and has the appropriate NHS approval.
4. The responsibilities of the specialist provider and GP practice are clearly defined.
5. Appropriate arrangements are in place for prescribing, monitoring, reviewing treatment and managing complications.
6. The GP is satisfied that they have the necessary knowledge, experience and competence to undertake the proposed prescribing responsibilities safely.

The practice reserves the right to decline any shared care request where these requirements are not met or where the GP does not feel able to prescribe safely.

4. Shared care requests from NHS gender identity services

The practice is happy to consider shared care requests from NHS gender identity services, including Indigo Gender Service.

Prescribing may be undertaken where an appropriate NHS-approved shared care protocol is in place and the GP is satisfied that the proposed arrangements are clinically appropriate and safe.

Prescribing and monitoring should follow the relevant NHS specialist service protocol and local medicines management guidance.

5. Shared care requests from private providers

The practice recognises that some patients may choose to access gender specialist services privately.

The practice is willing to consider shared care requests from private gender specialist providers where the proposed shared care protocol has been formally approved or adopted by the relevant NHS medicines management or commissioning body.

Each request will be considered individually. The practice will assess:

1. The provider’s professional registration, qualifications and experience.
2. Whether the provider and proposed shared care arrangements meet the relevant NHS approval and governance requirements.
3. Whether an appropriate specialist assessment has been undertaken.
4. The clinical rationale for the recommended treatment.
5. Whether the proposed medication and dosage are consistent with the approved protocol.
6. Whether baseline investigations and ongoing monitoring requirements are clearly specified.
7. Whether the specialist provider will remain available to offer advice and manage complications or treatment-related concerns.
8. Whether responsibilities for prescribing, monitoring, reviewing and responding to abnormal results are clearly allocated.

The practice may request further information or clarification from the provider before making a decision.

The practice is under no obligation to accept a shared care request, even where a patient has been assessed and treatment recommended by a private provider.

Prescribing responsibility will only be accepted once the practice has reviewed the documentation and confirmed its agreement in writing. Until that point, prescribing and monitoring responsibility remains with the initiating specialist provider.

6. Bridging prescriptions and self-sourced hormones

The practice does not initiate or provide bridging prescriptions for gender-affirming hormone treatment outside an appropriate NHS-approved shared care protocol.

This includes requests from patients who:

1. Are awaiting their first assessment at an NHS Gender Identity Clinic.
2. Are self-prescribing hormones obtained online or from other unregulated sources.
3. Are requesting hormone treatment before completing an appropriate specialist assessment.
4. Have received recommendations from a private provider where an appropriate NHS-approved shared care arrangement is not in place.

The practice recognises that patients may experience significant distress while waiting for specialist assessment and treatment. However, the practice is unable to initiate or assume prescribing responsibility outside the arrangements described in this policy.

Where a patient is self-prescribing or obtaining medication from an unregulated source, the GP will offer an appropriate clinical discussion about potential risks and available support.

Any immediate concerns regarding physical health, mental health or risk of self-harm or suicide will be assessed and managed appropriately.

7. Prescribing responsibilities and monitoring

Where shared care is accepted, prescribing and monitoring must follow the agreed NHS-approved protocol.

The protocol must clearly identify the responsibilities of the specialist service and GP practice, including:

1. Issuing prescriptions and arranging repeat medication.
2. Baseline and ongoing blood investigations.
3. Clinical reviews and treatment monitoring.
4. Monitoring for adverse effects and complications.
5. Responding to abnormal investigation results.
6. Dose adjustments and treatment changes.
7. Arrangements for specialist advice and escalation.

The GP will not independently initiate treatment or make dose changes outside the agreed protocol without appropriate specialist advice.

The specialist provider must remain available for advice and review where clinically necessary.

The GP retains responsibility for any prescription they issue and must be satisfied that it is clinically appropriate and safe.

8. Declining or withdrawing shared care

The practice may decline a shared care request or withdraw from an existing arrangement where:

1. The provider or protocol no longer meets the required standards.
2. Specialist support or monitoring arrangements are inadequate.
3. The patient requires treatment or monitoring outside the agreed protocol.
4. There are concerns about the safety or appropriateness of prescribing.
5. The GP does not feel competent to undertake the prescribing responsibilities.
6. The agreed responsibilities are not being fulfilled by the specialist provider.

Where shared care is declined or withdrawn, the practice will communicate its decision and reasons to the patient and specialist provider.

Appropriate arrangements should be discussed with the specialist provider to support continuity of care and avoid an unsafe interruption to treatment.

9. Supporting transgender and gender-diverse patients

Regardless of whether the practice accepts prescribing responsibility for hormone treatment, all transgender and gender-diverse patients will continue to receive appropriate and respectful primary care.

This includes:

1. General medical care and management of long-term conditions.
2. Mental health and wellbeing support.
3. Assessment and management of self-harm or suicidal risk.
4. Sexual health services and contraception where relevant.
5. Appropriate screening advice.
6. Referral to NHS gender identity services where requested or appropriate.
7. Support with accessing relevant NHS services and information.

The practice will ensure that patients are treated with dignity and respect, using their preferred name, title and pronouns.

A decision not to accept prescribing responsibility will not affect a patient’s entitlement to other appropriate primary care services.

10. Children and young people

Requests involving patients under 18 years of age must be managed in accordance with current NHS England guidance, relevant legislation and specialist NHS service pathways.

The practice will not independently initiate gender-affirming hormone treatment in children or young people.

Any requests involving puberty suppression or gender-affirming hormone treatment for under-18s must be considered in accordance with applicable national restrictions and specialist NHS guidance.

11. Review of policy

This policy will be reviewed periodically and updated in line with changes to GMC guidance, NHS England policy, local NHS medicines management guidance and relevant legislation.

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• How to complain

Contact details

Phone: 01614342753

What information we collect, use, and why

We collect or use the following personal information for recruitment purposes:

• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Copies of passports or other photo ID
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)
• Right to work information
• Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
• Security clearance details (eg basic checks and higher security clearance)

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information for recruitment purposes are:

• Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Where we get personal information from

• Directly from you
• Regulatory authorities
• Relevant regulatory authorities
• Previous employers

How long we keep information

We keep personal information in line with the NHS Records Management Code of Practice. Retention periods depend on the type of record and the purpose for which it is held.

Recruitment records for unsuccessful applicants are kept for up to 6 months after the recruitment process ends.

Recruitment records for successful applicants are transferred to the staff personnel file.

Staff personnel records are kept for 6 years after employment ends.

Right to work checks are kept for the duration of employment and for 2 years after employment ends.

Disclosure and Barring Service certificates are not retained for longer than 6 months. We keep a record of the check outcome and reference number for safeguarding and audit purposes.

Payroll and pension records are kept in accordance with HMRC and NHS pension requirements.

Where records are no longer required, they are securely destroyed.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Others we share personal information with

• Organisations we’re legally obliged to share personal information with

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

• you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
• we have a legal requirement (including court orders) to collect, share or use the data;
• on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
• If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
• If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

National data opt-out

We comply with England’s national data opt-out because we’re using confidential patient information for purposes beyond individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

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

Helpline number: 0303 123 1113

Website: www.ico.org.uk/make-a-complaint

The practice fully supports the NHS Zero Tolerance Policy. The aim of this policy is to tackle the increasing problem of violence against staff working in the NHS and ensures that doctors and all other staff have a right to care for others without fear of being attacked or abused. We understand that ill patients do not always act in a reasonable manner and will take this into consideration when trying to deal with a misunderstanding or complaint.

We ask you to treat your doctors, other patients, and all other staff courteously and act reasonably. All incidents will be followed up and you will be sent a formal warning after a second incident or removed from the practice list after a third incident if your behaviour has been unreasonable.

However, aggressive behaviour, be it violent or verbally abusive, will not be tolerated and may result in you being removed from The practice list and, in extreme cases, the Police will be contacted if an incident is taking place and the patient is posing a threat to staff or other patients.

Withington Medical Practice has a strict Zero Tolerance Policy. Our policy extends to but is not limited to homophobia, racism, transphobia, biphobia, misogyny, harassment, classism and xenophobia.

In order for the practice to maintain good relations with its patients the practice would like to ask all its patients to read and take note of the occasional types of behaviour that would be found unacceptable:

• Using bad language or swearing at practice staff
• Any physical violence towards any member of the Primary Health Care Team or
  other patients, such as pushing or shoving
• Verbal abuse towards the staff in any form including verbally insulting the staff
• Racial abuse and sexual harassment will not be tolerated within this practice
• Persistent or unrealistic demands that cause stress to staff will not be accepted.
  Requests will be met wherever possible and explanations are given when they
  cannot
• Causing damage/stealing from the Practice’s premises, staff or patients
• Obtaining drugs and/or medical services fraudulently
• We ask you to treat your GPs and their staff courteously at all times.
• It also extends further to include but is not limited to:
• Ableism – Prejudice in favour of able-bodied people
• Transphobia – Hostility to, prejudice, or discrimination against transgender or gender nonconforming people.
• Queerphobia – Hostility to, prejudice, or discrimination against anyone identifying as queer and
  any and all coinciding discrimination.
• Biphobia – Hostility to, prejudice, or discrimination against bisexual people.
• Ace/Aro phobia – Hostility to, prejudice, or discrimination against asexual or aromantic people.
• Racism – Hostility to, prejudice, or discrimination against someone based on their race.
• Islamophobia – Hostility to, prejudice, or discrimination against Islam or Muslims, especially as a political force.
• Xenophobia – Dislike of or prejudice against people from other countries and/or of different nationalities
• Misogyny – Dislike of, contempt for, or ingrained prejudice against women
• Sexism – Hostility to, prejudice, or discrimination typically against women, on the basis of sex.
• Classism – Hostility to, prejudice, or discrimination against people belonging to a particular social class, typically of a low socioeconomic class.
• Transmisogyny – The intersection of transphobia and misogyny. Misogyny is specifically targeted toward trans women and trans feminine people on the basis of their gender identity.
• Misogynoir – This is defined as misogyny directed towards black women where race and
  gender both play roles in bias. It was coined by queer black feminist Moya Bailey,
  who created the term to address misogyny directed toward black women in
  American visual and popular culture.
• Anti-semitism – Hostility to, prejudice, or discrimination against Jewish people
• Homophobia – Hostility to, prejudice, or discrimination against homosexual people.

A good patient-doctor relationship, based on mutual respect and trust, is the cornerstone of good patient care. The removal of patients from our list is an exceptional and rare event and is a last resort in an impaired patient-practice relationship. When trust has irretrievably broken down, it is in the patient’s interest, just as much as that of The Practice, that they should find a new practice. An exception to this is on immediate removal on the grounds of violence e.g. when the Police are involved.

In rare cases, however, 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 doctorsor other staff at risk.