Previous
Next

Part 1: Professional safeguarding responsibilities

Safeguarding in the independent or online/digital GP sector

Patients can choose to be seen via the NHS or via the independent sector, or in combination with the independent health appointments forming a 'complimentary service'. Some patients will elect for all of their care to be in the independent sector. There are also online/digital providers of GP services.

Legal and professional responsibilities around safeguarding are the same regardless of whether the healthcare setting is an NHS or non-NHS/independent/online/digital setting. For doctors, the GMC professional standards apply regardless of the healthcare setting.

GPs working in the independent or online sectors can face additional challenges in safeguarding patients due to:

  • Limited access to patients' NHS GP and hospital health records.
  • Patients may decline to share information regarding private consultations with their NHS GP which can lead to concerns and problems.
  • Unverified information being provided such as demographic information which may not be genuine because it is not always cross checked. This means that patients can 'disappear' or be hard to trace.
  • Less reliable computer systems to code non-attendance or 'was not brought' and other issues that might raise safeguarding suspicions. Multiple non-attendances are less likely to be flagged as a potential safeguarding issue.
  • Multi-agency safeguarding information is not routinely shared with the independent sector.
  • There may not be clear processes for reporting safeguarding concerns. This can be a particular issue for online providers who may see patients from across the UK.
  • Families not being registered with the same independent sector practice or an NHS GP practice and therefore not visible.
  • Parents or carers choosing not to share relevant information and no robust system to cross check with the more extensive NHS note keeping systems, such as hospital records or nursing and midwifery records that are often easily accessible within an NHS GP setting.
  • Lack of robust standardised systems to ensure referral outcomes are communicated back to the referring independent GP from consultants and specialists.
  • No robust system being in place for sharing information with their patient's usual NHS GP. This may be a problem if patients are seen when on holiday or out of their usual catchment area for other reasons.
  • Potentially underused standardised pathways and protocols for safeguarding referrals in the independent setting compared to regularly used protocols and pathways in the NHS.
  • Recognising abuse in affluent families can be difficult, for example child neglect can be much less visible. There can also be challenges working with parents from affluent and professional backgrounds.
  • Independent clinics may only see adults and therefore children and any dependent adults may be less visible.
  • Parents' perceptions that they are paying for a ring fenced specific medical service which does not invoke any safeguarding intervention by the independent GP.
  • Potential differences in private patients' medical cultural background and their understanding of UK standards and the doctor's statutory duties under UK safeguarding regulations.
  • Private patient expectations of 'control' over the private consultation and GP.

What can GPs working in the independent and online/digital sector do to ensure safeguarding is embedded into their practice?

Always consider safeguarding

  • Always consider child and adult safeguarding in every interaction with a patient.
  • Even if an independent setting only has adult patients, practitioners in these settings must always be mindful of children. The GMC in their guidance Protecting children and young people: The responsibilities of all doctors, states:
    “You must consider the safety and welfare of children and young people, whether or not you routinely see them as patients. When you care for an adult patient, that patient must be your first concern, but you must also consider whether your patient poses a risk to children or young people. You must be aware of the risk factors that have been linked to abuse and neglect and look out for signs that the child or young person may be at risk.”
  • Ensure knowledge and awareness of specific types of abuse where perpetrators may seek to use the independent health sector to obtain medical treatment for victims of abuse but evade wider multi-agency involvement. For example, modern slavery, trafficking, sexual and criminal exploitation, domestic abuse, ‘Honour-based’ abuse, Fabricated and Induced Illness.
  • Be aware that some patients may seek to use independent healthcare to evade statutory services, especially when there are safeguarding concerns.
  • Understand how abuse might present in affluent families.
  • Understand, and be able to respond to, the challenges of safeguarding in affluent communities.
  • Consider how safeguarding concerns will be further explored or followed up in a setting where patients pay for consultations. Where a cost may normally be attributed to patient contacts, this should never be a barrier for carrying out appropriate safeguarding activity. For example, in situations where you are ‘considering’ abuse or neglect as a possible cause for a patient’s presenting symptoms or situation, how will you explore and follow this up if the patient does not wish to pay for further consultations?
  • Work closely with colleagues and discuss any safeguarding concerns early.
Safeguarding training

  • Attend regular safeguarding training and ensure training is up to date and relevant to role – GPs and all general practice staff, regardless of whether they work in the NHS, independent or online sector, require the same level of safeguarding training as set out in the RCGP Safeguarding Standards. These standards include child and adult safeguarding equally and are applicable even if the independent GP service sees only adult patients.
  • Consider how the organisation keeps itself up to date with safeguarding national guidance and case reviews.
Safeguarding policies and procedures
  • Ensure safeguarding responsibilities and policies are clear and visible on the organisation’s website and available to staff in consulting rooms.
  • Ensure there are policies in place regarding information sharing and that these are clear and visible on the organisation’s website.
  • Ensure all staff members are aware of and have read the organisation’s safeguarding policies.
  • Ensure local safeguarding referral processes and contact numbers are kept up to date and easily accessible to all staff members. In England, the NHS Safeguarding App (4) is a comprehensive resource and includes links to all safeguarding partnerships within England.
  • Providers of online and remote GP services should be aware of the specific challenges this brings with regards to safeguarding such as providing care across a large geographical area including delivering care across national and international borders – providers should ensure they have processes in place to identify safeguarding concerns and respond appropriately.
  • The following documents will be helpful for online providers to ensure they are providing a safe service:
  • If the organisation provides virtual consultations, be clear on how safeguarding concerns can be identified and followed up.
  • If the organisation provides questionnaire-based interactions with clinicians, consider how safeguarding concerns can be identified and followed up.
  • Encourage patients to also register with an NHS GP.
Verifying patient identity

  • Have clear policies in place regarding checking identities. This is of particular importance when there are prescription requests that could indicate a safeguarding concern such as for addictive drugs or for recurrent sexually transmitted infections.

Safe prescribing
  • Have clear safe prescribing policies in place, especially regarding drugs with the potential for misuse as well as addiction.
  • Have clear policies in place regarding checking identities, especially when there are prescription requests that could indicate a safeguarding concern such as for addictive drugs or for recurrent sexually transmitted infections.
Organisational safeguarding lead

  • Have a organisational safeguarding lead.
  • Ascertain who safeguarding advice can be sought from when needed and have this information easily accessible to all staff members. This includes seeking advice from within the organisation and from external safeguarding professionals.
  • Ascertain whether the organisational safeguarding lead can be part of any local peer support networks such safeguarding lead forums.
Safeguarding documentation and information sharing

  • Information sharing is fundamental to safeguarding children and adults. Those working in the independent sector should have an understanding of the multi-agency process of information sharing when there are safeguarding concerns and how they will ensure they are included in this process. For example, when there is a concern that a child or adult is being abused or neglected, multi-agency partners need all the relevant information from health services to be able to make safe and accurate decisions about that child or adult’s welfare. Local authorities will generally request relevant information from NHS health partners such as GPs, health visitors, midwives, mental health trusts and hospital trusts. Independent providers should consider how they can ensure that the information they hold can be part of the multi-agency safeguarding process and response.
  • Ensure safeguarding concerns are documented clearly in the patient record including appropriate safeguarding coding and flags on records so that when there are safeguarding concerns, these are immediately identifiable to any clinician caring for the patient.
  • Professionals and providers should seek consent to share information wherever appropriate to do so but also be aware of their responsibility to share information without consent when necessary to do so, particularly when there are safeguarding concerns.
  • If a patient does not want to share information with their NHS GP or other healthcare providers, this should be fully explored to understand the reasons for this.
  • Safeguarding relies on appropriate and effective communication between different healthcare providers. Providers should therefore ensure there is good communication and information sharing between independent GPs and other independent sector staff and between NHS sector staff including NHS GPs, hospital staff and social care. This is a professional responsibility and placing the onus on patients to do this is inappropriate.

Think family approach

  • Make children visible and use a 'think family' approach in consultation. Have conversations with the parents that discuss their children at an early stage in the doctor patient relationship.
  • Understand the constraints of seeing families and children with limited access to full information and think about asking for more contextual information if necessary to support your 'think family' approach.
Further resources
References


Previous
Next