RCGP Safeguarding toolkit
The aim of this toolkit is to enhance the safeguarding knowledge and skills that GPs already have to enable them to continue to effectively safeguard children and young people, as well as adults at risk of harm.
Part 5: Information Sharing and multiagency working
Who should we share information with, and how?
WHO
HOW
General practice team
- Documenting safeguarding concerns clearly within the medical record. Part 4 of the RCGP Safeguarding toolkit provides further guidance on recording safeguarding concerns in the patient medical record.
- Sharing safeguarding concerns in practice safeguarding meetings.
- Seeking advice from the practice safeguarding lead and/or Caldicott Guardian regarding safeguarding information management issues.
Wider healthcare team, e.g. midwives, health visitors, secondary care health teams.
- Sharing safeguarding concerns as relevant in referral letters/communication with other health professionals.
- Proactive sharing of safeguarding concerns as they arise with:
- other health professionals/teams involved in the care of the patient such as midwives, health visitors, mental health teams
- other professionals such as social workers, if they are already involved with the patient.
Multi-agency safeguarding partners
- Sharing safeguarding concerns with our multi-agency safeguarding partners, e.g. via safeguarding referrals. This is most likely to be with the local authority/social care in England, Scotland and Wales, and with Health and Social Care Trusts in Northern Ireland. Local agreed multi-agency processes should be followed.
- Sharing relevant information as part of multi-agency safeguarding assessments.
- There are other agencies with whom information sharing will be necessary at times. These include education, drug and alcohol teams, care homes, care agencies, domestic abuse agencies and providers of services to those experiencing homelessness.
Multi-agency processes in place to reduce the risk of serious harm, e.g. MARAC, MAPPA, PPANI.
- These are specific multi-agency processes set up to protect victims of high-risk domestic abuse (MARAC) and to manage the risks posed by those convicted of violent, sexual and terrorism offences who are living in the community, in order to protect the public (MAPPA, PPANI).
- Information sharing with, and from, general practice into these processes varies across different parts of the UK and practitioners should be aware of how these work in their locality.
Police
- Any decisions to disclose personal or confidential patient information to the police must be taken on a case-by-case basis.
- Be aware of, and abide by, the advice on public interest disclosures provided by your professional regulator (GMC: Confidentiality: good practice in handling patient information. Paragraphs 22, 23).
- Know who deals with requests from the police in your organisation, who you can ask for advice, and who should authorise the disclosure of information to the police. Know what to do if these people are unavailable (for example, you are working out of hours). If a decision really cannot wait because someone is at imminent risk of serious harm, use your professional judgement.
- Seek advice from your practice safeguarding lead/Caldicott guardian/information governance lead/data protection officer/medical defence organisations if you are unsure how to proceed.
- Understand that there may be times when it is appropriate to challenge an information sharing request from the police.
- Additional guidance on sharing information with the police: Sharing information with the police. Doctors should also refer to the GMC guidance: Confidentiality: good practice in handling patient information.
- The ICO has a useful toolkit: Can I share personal data with a law enforcement authority, such as the police?
General principles for consideration of information sharing requests from other professionals or agencies for the purposes of safeguarding
- Has the request come from a verified source?
- Has the process for the request followed any locally agreed multi-agency information sharing processes including for requesting personal information from general practice?
- Has sufficient information been provided about the current situation, what the safeguarding concerns are and the current level of risk/harm?
- Has information been provided about consent (under the common law) from the patient/parents/carers/lasting power of attorney (depending on the situation, the patient’s age, competence and capacity) to share their personal information?
- If this consent has not been sought, have the reasons for this been given?
- If this consent has been sought and given, are you confident the patient (or relevant person who has given consent) is aware of what information is contained in the medical record, i.e. what information they have consented to sharing?
- If this consent has been sought but not given, have any of the other conditions for the disclosure of confidential information under the common law been met, i.e. it is required by law, or in response to a court order, or it is justified in the public interest?
Information sharing about perpetrators
This is an area of particular complexity, in particular when the individual is not aware of the allegations being made against them or that they are not aware that other agencies are sharing information about them.
The RCGP has guidance on recording and managing information about perpetrators (alleged or confirmed) of domestic abuse.
There is also additional guidance on this issue in Part 4 of the toolkit: Documenting safeguarding concerns and information.