Our Confidentiality Pledge
NHS Practitioner Health Service Confidentiality Policy
Commitment to confidentiality for practitioners using the NHS PH
Members of the workforce should be assured that NHS Practitioner Health (PH) is a confidential service and that those being treated in the service can expect the same level of confidentiality as all other patients. This means that the PH will not disclose information to any third party without the consent of the practitioner, unless required by a legal obligation. Medical practitioners will not be subject to a more or less stringent interpretation of the law than the general population.
This document sets out the commitment of NHS Practitioner Health (PH) to confidentiality and the necessary limits to confidentiality. More information is provided in the Memoranda of Understanding with the General Medical Council and the General Dental Council.
NHS Practitioner Health (PH) is a national, England wide service and PH treating clinicians and PH practitioner patients will be located across the country. To enable a centralised patient record and appointment system and coordinating policies and processes agreed confidentiality principles are essential.
NHS Practitioner Health (PH) will use a cloud based patient record system and a Booking App to securely store all patient information, including appointments, treatment, and consultations.
Security of patient records
All information (paper-based and electronic) about a practitioner will be kept in the PH secure clinical system and accessed only by PH staff. All paper records will be scanned into a secure electronic record and the paper version destroyed, except where required by law to retain originals.
Records will not be available through any record sharing arrangements such as the NHS Spine. Copies of electronic records will be held in the Cloud based patient record system.
Information will be shared between PH staff and preferred providers only through secure systems.
Providing identifying information
Where an individual contacts the service to seek information or advice, this will be provided regardless of whether they provide identifying information about themselves or the practitioner about whom they call.
Where a practitioner needs to be seen by PH for assessment or treatment, we would encourage the use of identifiable data however understand that some accessing the service will be worried about the same. In these circumstances, a pseudonym can be used to register.
Contact with employers
PH will seek consent from the practitioner if they wish to make contact with their employer/contracting organisation to gather information or where liaison with local health services is required.
Evaluation of PH and activity reporting
Evaluation of the PH will be vital to assess the effectiveness of the service and consider how it can be improved. The PH will be required to provide high level anonymised information about patterns of activity, types of cases seen, onward referral and outcomes. As part of this evaluation, the views of practitioners using the service will be sought. No information that may be attributed to named individuals will be included in any activity reporting or evaluation.
Exceptions to the duty of confidentiality
There are exceptions to the duty of confidentiality that may require the use or disclosure of confidential information. Such exceptions are very rare and should not undermine the trust that the practitioner can place in the service.
Rarely, disclosure in the public interest may be required. This will be in those circumstances where the practitioner’s health raises serious concerns about their own safety or the safety of their patients or the public. This will normally be limited to those cases where they are not complying with assessment, treatment or monitoring, or heeding advice to remain on sick leave.
In these cases PH will seek consent from the practitioner but where consent cannot be achieved and the public interest is paramount, disclosure may be made without consent. In such a case the practitioner will be informed that disclosure has occurred and the reasons for doing so. Disclosure will be kept to the minimum required for the purpose and passed only on a “need to know” basis.
Other requirements for disclosure
Other circumstances where disclosure may be required include cases where:
a) there is a legal requirement to disclose
b) a formal referral has been made to PH by an employer or contracting organisation, the Practitioner Performance Advice Service (PPAS) or the regulatory body, or
c) where the regulator requires reports from the PH about a practitioner’s health.
Again, the practitioner’s consent will be sought and disclosure kept to a minimum to satisfy the requirements.
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