Clayton Brook Surgery – Social Media Policy
Introduction and Purpose
The aim of this policy is to provide a standard framework for the use of social media. It ensures that the Surgery’s staff and patients are not brought into disrepute, as a result of the inappropriate use of social media.
There are many social media platforms that are widely used by both staff and patients at Clayton Brook Surgery; these include Facebook, Twitter, Instagram and others.
At Clayton Brook Surgery we have a Facebook Page, Twitter account and a Surgery website, which provide a range of useful information for our patient population.
Clayton Brook Surgery has a duty to maintain patient confidentiality and to safeguard vulnerable patients. you can help us achieve this by adhering to the code of conduct outline in this Policy.
Patients are not permitted to take photographs or any media recordings in the waiting room or areas where other patients are present, nor are photographs or media recordings of any staff members permitted without their explicit consent.
The Practice requires all users of portable devices to use them in a courteous and considerate manner, respecting their fellow patient.
Patients should not use any social media platform to communicate medical information with the Practice as this is not secure.
Patients must not post comments on social media that identify staff who work at the Practice.
Patients are to use the nhs.uk website should they wish to leave a review about Clayton Brook Surgery. This will enable the Surgery to respond appropriately.
Defamatory comments about our Team are not to be shared on any social media platform. Legal advice will be sought and the appropriate action taken against any patient who posts defamatory comments.
CLayton Brook Surgery Expectations of Staff
Not bringing Clayton Brook Surgery into disrepute.
Refrain from online behaviour towards colleagues that could be construed as bullying.
Maintain confidentiality as you would within in the workplace.
Be mindful of your colleagues when posting, if you have colleagues as ‘friends’.
Also be thoughtful of what you post, for example you might have reported sick, and then you post something on line which shows that you are well. This could be reported to management and could be dealt with as gross misconduct.
Staff should not identify themselves as an employee of the Surgery on social media. Not only does this reduce the risk of you bringing the Surgery into disrepute, it also reduces the chances of you being inappropriately contacted by patients, etc.
Think carefully about what kind of information you want to share and with whom, and adjust your privacy settings accordingly.
Staff must not register for personal social media accounts with their nhs net email address.
The Surgery understands that employees may wish to use their own mobile devices while they are at work. Employees must limit their use of social media on their own equipment to lunch times.
The internet is constantly changing so it is not possible to cover all circumstances that may occur. Surgery staff who use social media are required to exercise proper judgement, act professionally and consider the appropriateness for any information or image they post in advance of posting it.
When posting on social media sites, there should be no expectation of privacy, regardless of your privacy settings applied to individual accounts. Content posted to, and opinions expressed via social media must be considered to be on the public domain.
Ensure that your privacy settings are set so that personal information you may not want to share is not available to your colleagues or members of the public.
Have a neutral picture of yourself as your profile image.
Do not use your work contact details (email or telephone) as part of your persona contact details as part of profile you use for work.
Complaints, Comments & Suggestions
We constantly strive to ensure that all our patients receive good care and attention and we welcome any suggestions or comments as to how we can improve our service.
We realise that sometimes things do not go as smoothly as we would wish and if you think this has happened please inform a member of staff who will inform either the Practice Manager who in turn will investigate the complaint and contact you directly. We do take all complaints very seriously and try to learn from them.
We would be pleased to send you a copy of our complaints procedure on request and will try to resolve your complaint at a local level.
It is understood that sometimes the complainant does not feel comfortable with raising their complaint or concern with the Surgery directly.
If you wish to raise your complaint outside the Practice please contact:
P.O. Box 16738
Tel 0300 31 22 33 (Monday to Friday 8.00 am – 6.00 pm, excluding English Bank Holidays)
You can be assured that anything you discuss with any member of the Practice staff will remain confidential. It is important that the NHS keeps accurate records about your health and treatment so that those treating you can give you the best possible care.
This information may be used for management and audit purposes. However, it is only usually available to, and used by, those involved in your care. You have the right to know what information we hold about you.
Fair Processing and Privacy Notice
This Privacy Notice explains why Clayton Brook Surgery collects information about you, how we keep it safe and confidential and how that information may be used. This Practice handles medical records according to the laws on data protection and confidentiality.
Your Information, Your Rights
Being transparent and providing accessible information to patients and how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR).
The following notice reminds you of your rights in respect of the above legislation and how your information for lawful purposes in order to deliver your care and the effective management of local NHS system.
The notice reflects how we use information for:
- The management of patient records
- Communication concerning your clinical, social supported care
- Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review
- Participation in health and retrospective review
- Participation in health and social care research
- The Management and clinical planning of services to ensure the appropriate care is in place for our patients today and in the future
As your registered GP Practice, we are the data controller for any personal data that we hold about you.
Data Protection Officer (DPO)
The Data Protection Officer (DPO) ensures, in an independent manner, that Clayton Brook Surgery applies the laws protecting patient’s personal data. Hayley Gidman (mlcsu.dpo.nhs.net), is the named DPO for all GP Practices across Midlands and Lancashire:
Data Protection Officer
Midlands and Lancashire Commissioning Support Unit
120 Grove Road
Why we collect information about you
Health care professionals who provide you with care are required by law to maintain records about your health and any treatment or care you have received with any NHS organisation. These records help to provide you with the best possible health care.
How we use your personal information
This Fair Processing Notice explains why this GP Practice collects information about you and how that information may be used.
The health care professionals who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. NHS Trust, GP Surgery, Walk-in Clinic, etc.). These records help to provide you with the best possible healthcare.
NHS health records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Our GP records database is hosted by Emis Health Limited. All information is secured on their servers in Leeds, is protected by appropriate security and access is restricted to authorised personnel.
We use your mobile number to text you regarding matters of medical care such as appointment reminders unless you have opted out of this service. Records which this GP Practice holds about you may include the following information:
- Details about you, such as your address, carer, legal representative, emergency contact details.
- Any contact the Surgery has had with you such as appointments, clinic visits, emergency appointments, etc.
- Notes and reports about your health.
- Details about your treatment and care.
- Results of investigations such as laboratory tests, X-rays etc.
- Relevant information from other health professionals, relatives or those who care for you.
To ensure you receive the best possible care, your records are used to facilitate the care you receive. Information held about you may be used to help protect the health of the public and to help us manage the NHS. Information may be used within the GP Practice for clinical audit to monitor the quality of the services provided.
Some of this information will be held centrally and used for statistical purposes. Where we do this, we take strict measures to ensure that individual patients cannot be identified. Sometimes your information may be requested to be used for research purposes – the surgery will always gain your consent before releasing the information for this purpose.
Data about you is used to manage national screening campaigns such as Flu, Cervical Cytology and Diabetes Prevention.
Data about you, usually de-identified, is used to manage the NHS and make payments.
Your data is used to check the quality of care provided by the NHS.
Risk Stratification/Health Risk Screening
Risk stratification data tools are increasingly being used in the NHS to help determine a person’s risk of suffering a particular condition, preventing an unplanned or re-admission and identifying a need for preventative intervention. Information about you is collected from a number of sources including NHS Trusts and from this GP practice.
A risk score is then arrived at through an analysis of your de-identified information using the software managed by the local Commissioning Unit and/or a third party accredited Risk Stratification provider and is only provided back to your GP as a data controller in an identifiable form. Risk stratification enables your GP to focus on preventing ill health and not just the treatment of sickness. If necessary your GP may be able to offer you additional services. Please note that you have the right to opt out of your data being used in this way.
The Practice may conduct Medicines Management Reviews of medications prescribed to its patients. The service performs a review of prescribed medication to ensure patients receive the most appropriate up to date and cost effective treatments. This service is provided to practices within the Chorley and South Ribble Commissioning Group.
How we maintain the confidentiality of your records?
We are committed to protection your privacy and only use the information collected lawfully in accordance with:
- Data Protection Act 1998 (from 25.05.2018 -GDPR)
- Human Rights Act 1998
- Common Law Duty of Confidentiality
- Health and Social Care Act 2021
- NHS Codes of Confidentiality, Information Security and Records Management
- Information: To Share or Not to Share Review
- Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations), where the law requires information to be passed on and; or in accordance with new information sharing principle following Dame Fiona Caldicott’s information sharing review (Information to share or not to share) where “The duty to share information can be as important as the duty to protect patient confidentiality.”
This means that health and social care professionals should have the confidence to share information in the best interests of their patients within the framework set out by the Caldicott principles. This should be supported by the policies of their employers, regulators and professional bodies.
Who are partner organisations?
- NHS Trusts/Foundation Trusts
- NHS Commissioning Support Units
- Independent Contractors such as dentists, opticians, pharmacies
- Private Sector Providers
- Voluntary Sector Providers
- Ambulance Trusts
- Clinical Commissioning Groups
- Social Care Services (Safeguarding)
- Health and Social Care Information Centre (HSCIC)
- Local Authorities
- Education Services
- Fire and Rescue Services
- Police and Judicial Services
- Voluntary Sector Providers
- Private Sector Providers
- NHS Digital (e.g. National Diabetes Audit)
Only with your explicit consent can Clayton Brook Surgery release information about from your GP record to relevant organisations. These may include:
- Your employer
- Insurance Companies
- Local Authorities
CCTV is installed covering both the internal and external areas of the building. Images are held to improve the personal security of patients and staff whilst on the premises, and for the prevention and detection of crime. The images are recorded onto an integral hard drive of the equipment and are overwritten on a rolling basis. Viewing of these digital images is password protected and controlled by the Practice Manager.
Consent and Objections
Do I need to give my consent?
The GDPR sets a high standard for consent. Consent means offering people genuine choice and control over how their data is used
You have the right to opt out or to object to ways in which your information is shared
For independent advice about data protection, privacy and data sharing issues you can contact:
The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 08456 306060
If you would like any further information about uses of your GP record or about any other aspect of NHS data sharing, then contact the Surgery’s Caldicott Guardian (Dr M Siddiqui) or the Information Governance Lead (Practice Manager).
Infection Control Statement
Clayton Brook Surgery is committed to the control of infection within the building and in relation to the clinical procedures carried out within it. This statement has been produced in line with the Health and Social Care Act 2008.
This statement will be reviewed annually.
- Any infection transmission incidents and any action taken (Significant Event)
- Details of any infection control audits and any actions taken
- Details of staff training
- Any review and update of policies, procedures and guidelines
This protocol applies to all staff employed by Clayton Brook Surgery
Infection Control Lead
Deborah Meade Mcloughlin is the Surgery’s Infection Control Lead, who carries out annual audits.
Training relating to Infection Control
All Clayton Brook Surgery staff members have received instruction, information or training relating to Infection Prevention and Control. we provide annual online training as well as training required by our Infection Control Lead during the practice education meetings.
As a practice we ensure that all our clinical staff are up to date with their Hepatitis B immunisations and offered any occupational health vaccinations applicable to their role. We take part in the National immunisations campaigns for patients and we offer vaccinations in house and via home visits our patient population.
Our cleaning contractor, work to cleaning specifications laid out in their contract along with frequencies and an annual audit takes place to ensure these are being met. Cleaning equipment is stored in accordance with the NHS Cleaning Specifications.
In the clinical rooms the modesty screens are paper type material and changed six monthly.
Spill kits for blood, vomit or urine are provided in the reception area complete with all necessary PPE.
PPE (Personal Protective Equipment)
- Clayton Brook Surgery provides PPE for all members of the team in line with their role:
- Clinical staff are provided with aprons and several different types and sizes of gloves.
- Reception Staff are provided with gloves for the handling of sample pots.
Clinical waste is collected weekly, waste transfer sheets are retained for five years.
Domestic waste is disposed of via a commercial contractor. Collections take place weekly.
Fixtures, Fittings and Furniture
All decorating renewals and repairs will be made in line with infection control guidelines.
The seating and examination couches in the clinical rooms are of wipeable materials.
It is the responsibility of each individual to be familiar with this statement and their roles and responsibilities under this. It is also the responsibility of the Practice Manager to ensure staff are familiar with the contents,
Additional Measures – Covid 19
During Covid 19 we are instituting extra cleaning and infection control measures to reduce the risk and minimise transmission of infections, including wiping down of workstations before and after use and operating a zoning system for face to face appointments, to reduce the amount of movement around the surgery. The staff have been provided with suitable personal protective equipment (PPE) for their role and exposure levels.
All routine appointments are strictly assessed by telephone or via video consultation. Patients will only be invited to attend the surgery if the Doctor/Advanced Nurse Practitioner deems that a physical examination is required. All patients will be assessed prior to their attendance at the surgery for Covid related symptoms. All patients and visitors will be requested to wear a face covering when attending the surgery and to come alone (or with one parent if a child).
2 metre social distancing is in place throughout the surgery (where possible) and all staff to wear a face covering when moving about the practice or where the 2 metre rule cannot be applied. Alcohol gel is available at the entrance of the building. Both patients and staff are encouraged to apply this before entering the surgery/clinical rooms.
Statement of Intent
New contractual requirements came into force from 01 April 2014 requiring that GP Practices should make available a statement of intent in relation to the following IT developments:
- 1 Summary Care Record (SCR)
- 2 GP to GP Record Transfers
- 3 Patient Online Access to their GP Record
- 4 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 to our patient by 30 September 2014.
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 31 March 2015.
Having your Summary Care Record available will help anyone treating you without your full medical record. They will have access to information about your 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 on the Summary Care Website www.nhscarerecords.nhs.uk or telephone 0300 123 3020 .
Clayton Brook Surgery confirms that your Summary Care Record is automatically updated on a lest a daily basis to ensure that your information is up to date.
GP to GP Record Transfers
NHS England requires practices to utilise the GP2GP facility for the transfer of patient records between practices, when a patient registers or de-registers (excluding 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 GP via NHS England. It can take your paper records up to two weeks to reach new your new Surgery.
With GP to GP record transfers your electronic record is transferred to your new practice much sooner.
Clayton Brook Surgery 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 requires practices to promote and offer the facility to enable patients online access to appointments, prescriptions, allergies and adverse reactions.
Clayton Brook Surgery currently offers the facility for ordering your repeat prescriptions online and booking appointments.
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 users and data sharing for secondary uses.
GMS/PMS 2015 – 2016 Contractual Requirements for Patient Online Service
From the 01 April 2016 Clayton Brook Surgery will also provide patients with online access to their medical records. This includes Immunisations, Summary, Problems, Test Results and Consultations.
To gain access to your medical record you must be aged sixteen and over.
Please ask one of our administration team for more details.
As a practice we must continue to follow the strict infection, prevention and control measures to limit the risk of the virus to you as patients and to our staff. This means that where possible staff and clinicians will remotely triage and assess your needs before determining if a face to face appoint is needed. If your needs can be met safely via the telephone or video consultations then this will take place. If a clinician feels you require a face-to-face appointment then this will be arranged. We have been opening this way since the start of the pandemic in order to continuing providing all patients with access to our services.
The current pandemic situation is challenging for everyone in different ways and we appreciate that the situation we all find ourselves can be frustrating sometimes. Unfortunately a number of our staff have recent experience foul and abusive language or behavior from a minority of patients. This is not acceptable and we will not tolerate this sort of behavior towards our staff of whom continue to work tirelessly during the pandemic. In line with our Zero Tolerance Policy if you are found to be abusive towards member of staff then appropriate action will be taken.
Zero Tolerance Policy
The Practice recognises that they have a legal duty to ensure so far, as a reasonably practicable the health, safety and welfare of their employees (Health and Safety At Work Act 1974). This policy is intended to embrace all current guidance and legislation in regard to the management of violence and aggression within the practice and will form part of the practice’s overall Health and Safety Policy.
Definition of Violence
Any incident where a GP or his/her staff are abused threatened or assaulted in circumstances related to their work, involving an explicit or implicit challenge to their safety, wellbeing or health.
- Verbal abuse or threat where this is judged to turn into actual violence.
- Serious or persistent harassment including racial and sexual harassment.
- Threaten with anything which could be regarded as a weapon.
- Major and minor injuries.
- Harassment (sexual, racial or disability) this also includes harassment by other members of staff.
The Practice recognizes the difficulty and complex nature of health care delivery by its staff, including dealing with patients/clients (who may be physically or mentally ill, under stress or confused and that relatives of friends of their patients/clients may contribute to the potential for violence. In the past violence at work in General Practice has often been accepted as part of the job. The Practice would view such a situation as being totally unacceptable.
The Practice recognizes and accepts their responsibilities, in accordance with the Health and Safety Work Act 1974 and Good Employment Practice, to provide as far as is reasonably practicable the following conditions related to the prevention and containment of violence.
Effective and comprehensive systems at work must include:
- A working environment including the provision of adequate levels of staff, conducive to the management of potential or actual violence.
- Provision of information and training for staff/GP s o handling potential or actual violence, including summoning of assistance.
- Positive support for staff/GPs involved in violent incidents.
- A system of monitoring and reviewing violent incidents.
It should be clearly understood by all concerned that is any situation, the prevention and avoidance of violence is of paramount importance and that active defence will be a last resort. Where patients are involved, the emphasis must be on safeguarding them from harm, even in the cases where they contribute to the disturbance.
The overall responsibility within the practice to deal with violence and aggression lies with the GP’s as the employer. The practice will provide a coherent framework within which to assess the risk of violence and aggression, and wherever practical avoid the situation arising. It will develop clear strategies for the risks that remain and provide a suitable training and response strategies.
Individual Personal Responsibility
Notwithstanding the Practice’s responsibilities defined in the earlier section – this policy makes it clear that employees have a personal responsibility for their own safety and that of others i.e. patients, visitors, colleagues, Section 7 Health and Safety at Work Act 1974.
Extract From The Surgery’s Removal of patients From Practice List Policy
The Surgery aims to provide the best possible care for patients. However there may be circumstances when it would be considered reasonable, or in the best interests of the patient, to remove them from the list.
The purpose of this policy, is to define the practice guidelines for when it is reasonable to remove a patient from the practice list and to ensure that any concerns about removing patients from the list are dealt with fairly.
Situations which justify removal
Violence – when a patient:
Is physically violent or threatening towards a GP, practice staff or other patients on the practice premises.
Causes physical damage to practice premises or other patient’s property.
Gives verbal abuse or makes threats towards the GP, practice staff or other patients.
Gives racist abuse or makes threats towards the GP, practice staff or other patients.
Gives racist abuse, orally or physically.
Is violent or uses or condones threatening behaviour to GP’s (or other members of the primary care health team) while visiting the patient’s home. Such behaviour may involve the patient, a relative, a household member or pets (such as unchained dogs).
Crime and Deception – where a patient
Fraudulently obtain drugs for non-medical reasons.
Deliberately lies to the GP or other members of the primary health team (e.g. by giving a false name or false medical history) in order to obtain a service or benefit by deception.
Attempts to use the GP to conceal or aid criminal activity.
Steals from the practice.
Irretrievable breakdown of the Doctor-patient relationship – where a patient’s
behaviour falls outside of that which is normally considered reasonable and leads to an irretrievable breakdown of the doctor – patient relationship –
When a patient puts excessive demands on the Surgery i.e. inappropriate and excessive requests for medication – drug misuse