Introduction 

This policy outlines the practice’s call recording process.

The purpose of call recording is to provide a record of incoming and outgoing calls which can:

• Identify practice staff training needs
• Protect practice staff from nuisance or abusive calls
• Establish facts relating to incoming/outgoing calls made (e.g. complaints)
• Identify any issues in practice processes with a view to improving them (e.g. to aid workforce planning)
• Only calls to and from reception are recorded.

Purpose

The purpose of this policy is to ensure that call recording is managed in line with Data Protection Act 2018 requirements.

The practice will make every reasonable effort to advise callers that their call may be recorded and for what purpose the recording may be used. This will normally be via a pre-recorded message within the telephone system and via signage at the practice. The voice file will be stored within the telephone recording system software to which the same rules of confidentiality will apply. The practice’s data protection registration covers voice files similarly to other data.

Scope 

This policy applies to all practice staff including any contracted or temporary workers.

All external incoming and outgoing calls made by practice staff via the telephone system will be recorded.

Recording will automatically stop when the practice staff member terminates the call.

Callers will be advised that the call will be recorded for training and monitoring purposes in the form of an automated voice message and via an information notice displayed at the surgery plus information contained on the surgery website.

Playback, Monitoring and Storage of Recorded Calls 

Monitoring of the call recordings will be undertaken by the Practice Manager.

Any playback of recordings will take place in a private setting and where applicable, individuals should be given the opportunity to listen to the relevant recordings to receive feedback and developmental support.

All recordings and call recording equipment will be stored securely on site at the practice and access to these will be controlled and managed by the Operations Manager.

Recordings will be accessed by logging into a dedicated, password protected computer system.

Call recordings will be retained by the provider for 3 years.

Confidentiality 

The Data Protection Act allows patients access to information that is held about them. This includes recorded telephone calls.

Requests for copies of telephone conversations can be made under the Data Protection Act as a “Subject Access Request”. After assessing whether the information can be released, the requestor can be invited to the practice premises to hear the recording. As data subjects have the right to the erasure of personal data concerning them. ‘The right to be forgotten’ does not override legal and compliance obligations. 

If there is a request from an external body relating to the detection or prevention of a crime (e.g. police), then requests for information should be directed to the Practice Manager.

Under GDPR, organisations are prohibited from recording the personal conversations of staff, even with consent, and therefore need to ensure that while business calls are recorded, personal calls always remain private.

If you live or move outside our catchment area and want to register as an “out-of-area” patient, please take note of the following conditions:

• If your medical concern requires attention, you must be able to visit the surgery during our opening hours. Phone consultations may not be appropriate for certain issues.
• Your own health should not pose any personal factors or concerns that could prevent you from attending the surgery.
• At present, you should not require access to any community health or social care services, as these are organized geographically.
• It is your responsibility to visit the surgery to collect items like pathology forms and make suitable arrangements.
• Home visits cannot be provided under any circumstances.

We will generally not consider the following patients : This includes (but not limited to) patients / services in the following services:

• Pregnant women/ Antenatal services
• Families with children aged 15 years or younger
• Patients with serious mental health problems (e.g. Psychosis, Bi-Polar, Schizophrenia) who many need support from mental health specialist teams (e.g. Community Mental Health Team)
• Patients or Families with Child Safeguarding needs/ Children’s Social Care
• Patients with Adult Safeguarding needs/ Adult Social Care
• Patients with complex community-based packages of care/ Adult Social Care
• Patients aged over 50 with complex issues.

In the event that you need a GP but are too unwell to come to the surgery, please contact us initially. If we determine that you require services in your local area, we will direct you to the appropriate local service established by NHS England. This service could be a GP practice near your home, a local walk-in or urgent care centre, or a minor injuries unit.

You must reside within Ealing or Hillingdon

Please understand that if your health needs change we may review your registration and ask you to register with a GP closer to your home.

Registration with our practice is subject to our discretion. If we find that your care needs become more complex after registration, we reserve the right to review your registration and ask you to register with a GP closer to your home.

In the event that we become aware of your out-of-area residence, we will notify you and ask for your agreement to the above conditions. If we don’t receive a response, we will send a reminder. Failure to comply may result in deregistration.

We at ALL times have discretion to not register or to remove patients who live outside of our catchment area.

NHS Staff must be able to come to work without fear of violence, abuse or harassment from patients or their relatives. The NHS has a zero tolerance attitude towards violence .

Violent, threatening or abusive behaviour including shouting and swearing will not be tolerated at this practice.

Patients who act in such a manner will be asked to leave the premises; the Police may be called and you could be removed from our patient list.

Our staff are here to help you, please treat them with respect.

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 their 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 and their 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 verbal 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.

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 Surgery, 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.

Removing other members of the household

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 doctors or their staff at risk.

Patient’s Rights

We are committed to giving you the best possible service. This will be achieved by working together. Help us to help you. You have a right to, and the practice will try to ensure that:

• You will be treated with courtesy and respect
• You will be treated as a partner in the care and attention that you receive
• All aspects of your visit will be dealt with in privacy and confidence
• You will be seen by a doctor of your choice subject to availability
• In an emergency, out of normal opening hours, if you telephone the practice you will be given the number to receive assistance, which will require no more than one further call
• You can bring someone with you, however you may be asked to be seen on your own during the consultation
• Repeat prescriptions will normally be available for collection within two working days of your request
• Information about our services on offer will be made available to you by way of posters, notice boards and newsletters
• You have the right to see your medical records or have a copy subject to certain laws.

Patient’s Responsibilities

With these rights come responsibilities and for patients we would respectfully request that you:

• Treat practice staff and doctors with the same consideration and courtesy that you would like yourself. Remember that they are trying to help you
• Please ensure that you order your repeat medication in plenty of time allowing 2 working days.
• Please ensure that you have a basic first aid kit at home and initiate minor illness and self-care for you and your family.
• Please attend any specialist appointments that have been arranged for you or cancel them if your condition has resolved or you no longer wish to attend
• Please follow up any test or investigations done for you with the person who has requested the investigation
• Attend appointments on time and check in with Reception
• Patients who are more than 10 minutes late for their appointment may not be seen.
• If you are unable to make your appointment or no longer need it, please give the practice adequate notice that you wish to cancel. Appointments are heavily in demand and missed appointments waste time and delay more urgent patients receiving the treatment they need
• An appointment is for one person only. Where another family member needs to be seen or discussed, another appointment should be made
• Patients should make every effort to present at the surgery to ensure the best use of nursing and medical time. Home visits should be medically justifiable and not requested for social convenience
• Please inform us when you move home, change your name or telephone number, so that we can keep our records correct and up to date
• Read the practice leaflets and other information that we give you. They are there to help you use our services. If you do not understand their content please tell us
• Let us have your views. Your ideas and suggestions whether complimentary or critical are important in helping us to provide a first class, safe, friendly service in pleasant surroundings.

NHS Constitution

The NHS Constitution establishes the principles and values of the NHS in England. For more information see these websites:

• UK – The NHS Constitution for England
• NHS Choices – NHS Constitution

Introduction

The purpose of this document is to set out the policy of the Practice in relation to the protection of vulnerable adults. Further guidance may be available on local inter-agency procedures via the Primary Care Organisation and / or Social Services.

What is a vulnerable adult?

The definition is wide, however this may be regarded as anyone over the age of 18 years who may be unable to protect themselves from abuse, harm or exploitation, which may be by reason of illness, age, mental illness, disability or other types of physical or mental impairment.

Those at risk may live alone, be dependent on others (care homes etc.), elderly, or socially isolated.

Forms of Abuse

• Neglect – ignoring mental or physical needs, care, education, or basic life necessities or rights
• Bullying – family, carers, friends
• Financial – theft or use of money or possessions
• Sexual – assault, rape, non-consensual acts (including acts where unable to give consent), touching, indecent exposure
• Physical – hitting, assault, man-handling, restraint, pain or forcing medication
• Psychological – threats, fear, being controlled, taunts, isolation
• Discrimination – abuse based on perceived differences and vulnerabilities
• Institutional abuse – in hospitals, care homes, support services or individuals within them, including inappropriate behaviours, discrimination, prejudice, and lack of essential safeguards

Abuse may be deliberate or as a result of lack of attention or thought, and may involve combinations of all or any of the above forms. It may be regular or on an occasional or single event basis, however it will result in some degree of suffering to the individual concerned. Abuse may also take place between one vulnerable adult and another, for example between residents of care homes or other institutions.

Indications

• Bruising
• Burns
• Falls
• Apparent lack of personal care
• Nervousness or withdrawn
• Avoidance of topics of discussion
• Inadequate living conditions or confinement to one room in their own home
• Inappropriate controlling by carers or family members
• Obstacles preventing personal visitors or one-to-one personal discussion
• Sudden changes in personality
• Lack of freedom to move outside the home, or to be on their own
• Refusal by carers to allow the patient into further care or to change environs
• Lack of access to own money
• Lack of mobility aids when needed

Action Required

Where abuse of a vulnerable adult is suspected the welfare of the patient takes priority. In deciding whether to disclose concerns to a third party or other agency the GP will assess the risk to the patient.

•  Ideally the matter should be discussed with the patient involved first, and attempt made to obtain consent to refer the matter to the appropriate agency. Where this is not possible, or in the case of emergency where serious harm is to be prevented, the patient’s doctor will balance the need to protect the patient with the duty of confidentiality before deciding whether to refer.
• The patient should usually be informed that the doctor intends to disclose information, and advice and support should be offered.
• Where time permits, the medical defence organisation will be telephoned before any action is taken.

Due regard will be taken of the patient’s capacity to provide a valid consent.

In assessing the risk to the individual, the following factors will be considered:

• Nature of abuse, and severity
• Chance of recurrence, and when
• Frequency
• Vulnerability of the adult (frailty, age, physical condition etc.)
• Those involved – family, carers, strangers, visitors etc.
• Whether other third parties are also at risk (other members of the same household may being abused at the same time)

Subject to the local procedures in force, consideration will be given to;

• Report to Social Services Mental Health team
• Report to Police
• Report to PCT lead

About your Summary Care Record

Your Summary Care Record contains important information about any medicines you are taking, any allergies you suffer from and any bad reactions to medicines that you have previously experienced.

Allowing authorised healthcare staff to have access to this information will improve decision making by doctors and other healthcare professionals and has prevented mistakes being made when patients are being cared for in an emergency or when their GP practice is closed.

Your Summary Care Record also includes your name, address, date of birth and your unique NHS Number to help identify you correctly.

You may want to add other details about your care to your Summary Care Record. This will only happen if both you and your GP agree to do this. You should discuss your wishes with your GP practice.

Healthcare staff will have access to this information, so that they can provide safer care, whenever or wherever you need it, anywhere in England.

FAQs

Who can see my Summary Care Record?

Healthcare staff who have access to your Summary Care Record:

• need to be directly involved in caring for you
• need to have an NHS Smartcard with a chip and passcode
• will only see the information they need to do their job and
• will have their details recorded every time they look at your record

Healthcare staff will ask for your permission every time they need to look at your Summary Care Record. If they cannot ask you (for example if you are unconscious or otherwise unable to communicate), healthcare staff may look at your record without asking you, because they consider that this is in your best interest.

If they have to do this, this decision will be recorded and checked to ensure that the access was appropriate.

What are my choices?

You can choose to have a Summary Care Record or you can choose to opt out.

If you choose to have a Summary Care Record and are registered with a GP practice, you do not need to do anything as a Summary Care Record is created for you.

If you choose to opt out of having a Summary Care Record and do not want a SCR, you need to let your GP practice know by filling in and returning an opt-out form (PDF, 245.9kB). Opt-out forms can be downloaded from the website or from your GP practice.

If you are unsure if you have already opted out, you should talk to the staff at your GP practice. You can change your mind at any time by simply informing your GP practice and either filling in an opt-out form (PDF, 245.9kB) or asking your GP practice to create a Summary Care Record for you.

Children and the Summary Care Record

If you are the parent or guardian of a child under 16, you should make this information available to them and support the child to come to a decision as to whether to have a Summary Care Record or not.

If you believe that your child should opt-out of having a Summary Care Record, we strongly recommend that you discuss this with your child’s GP. This will allow your child’s GP to highlight the consequences of opting-out, prior to you finalising your decision.

Where can I get more information?

For more information about Summary Care Records you can

• talk to the staff at your GP practice
• phone the Health and Social Care Information Centre on 0300 303 5678
• Read the Summary Care Record patient information

New contractual requirements came into force from 1 April 2014 requiring that GP Practices should make available a statement of intent in relation to the following IT developments:

• Summary Care Record (SCR)
• GP to GP Record Transfers
• Patient Online Access to Their GP Record
• Data for commissioning and other secondary care purposes

The same contractual obligations require that we have a statement of intent regarding these developments in place and publicised by 30 September 2014.

Please find below details of the practices stance with regards to these points.

Summary Care Record (SCR)

NHS England require practices to enable successful automated uploads of any changes to patient’s summary information, at least on a daily basis, to the summary care record (SCR) or have published plans in place to achieve this by 31st of March 2015.

Having your Summary Care Record (SCR) available will help anyone treating you without your full medical record. They will have access to information about any medication you may be taking and any drugs that you have a recorded allergy or sensitivity to.

Of course, if you do not want your medical records to be available in this way then you will need to let us know so that we can update your record. You can do this via the opt out form.
The practice confirms that your SCR is automatically updated on at least a daily basis to ensure that your information is as up to date as it can possibly be.

GP to GP Record Transfers

NHS England require practices to utilise the GP2GP facility for the transfer of patient records between practices, when a patient registers or de-registers (not for temporary registration).
It is very important that you are registered with a doctor at all times. If you leave your GP and register with a new GP, your medical records will be removed from your previous doctor and forwarded on to your new GP via NHS England. It can take your paper records up to two weeks to reach your new surgery.

With GP to GP record transfers your electronic record is transferred to your new practice much sooner.

The practice confirms that GP to GP transfers are already active and we send and receive patient records via this system.

Patient Online Access to Their GP Record

NHS England require practices to promote and offer the facility to enable patients online access to appointments, prescriptions, allergies and adverse reactions or have published plans in place to achieve this by 31st of March 2015.

We currently offer the facility for booking and cancelling appointments and also for ordering your repeat prescriptions and viewing a summary of your medical records on-line. If you do not already have a user name and password for this system – please register your interest with our reception staff.

Data for commissioning and other secondary care purposes

It is already a requirement of the Health and Social Care Act that practices must meet the reasonable data requirements of commissioners and other health and social care organisations through appropriate and safe data sharing for secondary uses, as specified in the technical specification for care data.

At our practice we have specific arrangements in place to allow patients to “opt out” of care.data which allows for the removal of data from the practice. Please see the page about care data on our website

The Practice confirm these arrangements are in place and that we undertake annual training and audits to ensure that all our data is handled correctly and safely via the Information Governance Toolkit.