To ensure the smooth running of our practice, Patients are requested to give as much notice as possible. If you need to cancel/reschedule your appointment a minimum of 24hrs notice, 48hrs if the appointment is for 30mins or longer is required.

Please be aware that if two or more appointments are cancelled without 24hrs notice or failed without notice (without good reason), within a 12 month period, then no further appointments shall be offered at the practice.

A fee shall be charged for missed or short notice cancellation of private appointments.

We are committed to protect children from harm. Our dental team accepts and recognises our responsibilities to develop an awareness of the issues that cause children harm.

We will endeavour to safeguard children by

• An awareness of and adopting child protection guidelines through our practice procedures and policies

• A code of conduct for the dental team

• Making both staff and patients aware that we take child protection seriously and respond to all concerns about the welfare of children

• Sharing information about concerns with agencies who need to know and involving parents and children appropriately

• Following carefully the practice procedures for staff recruitment and selection, including requesting enhanced criminal records checks and ISA Adult First checks

• Providing effective management for staff by ensuring access to supervision, support and training in child protection issues.

Within our practice Anastasija Petkevica is responsible for ensuring our procedures for safeguarding children and vulnerable adults are kept up to date and is our point of contact for raising concerns.

We are also committed to reviewing our policy and good practice at regular intervals

Please see our main Safeguarding Children & Vulnerable Adults Policy.

Our practice is committed to providing a safe, supportive environment for patients. All patients will have a chaperone present for every consultation, examination or procedure. Usually this will be the Nurse but it may also be a family member or friend.

A Chaperone must assist the patient to the practice if they are;

• Under 16 years old

• A vulnerable adult

A nurse can not be responsible for chaperoning them and assisting the clinician to ensure their treatment is carried out to the best quality.

The role of a chaperone includes:

• Providing emotional comfort and reassurance to patients

• To act as an interpreter

• To provide protection to healthcare professionals against unfounded allegations of improper behaviour.

This clinical governance policy describes the way our practice strives to continuously improve the quality of our service and delivers a consistent standard of care for our patients.

Our clinical governance policy follows the Department of Health’s framework, adapted for primary dental care and focuses on aspects concerning (i) the practice team, (ii) our patients, (iii) practice safety, and (iv) clinical issues.

Clinical governance is about managing quality and developing practice management systems to help us track our progress by –

• knowing what is supposed to be done, how it should be done and why

• knowing who it is supposed to be done by

• being able to show that it has been done in the right way every time, and

• learning from mistakes to prevent them happening again.

The lead for clinical governance issues at the practice is undertaken by Anastasija
Petkevica.

This policy is reviewed annually and more regularly if changes occur within the practice.

Anastasija Petkevica

Practice Owner & Clinical Governance Lead

The practice team

Staff involvement and staff development

• The practice has systems in place for the safe recruitment of employed and selfemployed workers.

• Every member of the team has an up-to-date job description and contract of employment

• The practice has the full range of employment policies

• All new members of the dental team undertake induction training in the practice procedures and protocols

• Annual appraisals are held and all staff have personal development plans

• Individual, team and practice training needs are identified and, where appropriate, training is provided

• Records of training are maintained for each team member

• There are regular staff meetings to share information and make plans for the practice and the team

• The team is open in dealing with issues of performance

• There is a reporting line for staff who have concerns about any aspect of the practice or another member of the team

• There is a practice policy for handling complaints.

Clinical staff requirements and development

• All qualified clinical staff are registered with the GDC. Trainee dental nurses are working towards a qualification that will allow registration with the GDC

• Registration/practising certificates are checked annually

• GDC requirements for CPD are complied with

• The practice has a training policy

• The practice has a policy for dealing with underperformance.Patients

  Patient information and involvement

  • Patient treatment plans and care are always developed in consultation with the patient; the patient’s choice is followed, wherever possible. Where it is not possible to comply with the patient’s choice and explanation is provided

  • The costs involved with various treatment options are made known to patients and where there are changes to the costs, the patient is informed and their consent to proceed is sought

  • Patients feel involved in decisions about their care

  • All patient records show clearly how consent was obtained, whether written or oral

  • Patients having extensive treatments, receive written treatment plans

  • Patients are actively involved in developing the practice’s services

  • There is an annual cycle of patient surveys

  • The team has looked at the possibility of holding focus groups and, where appropriate, organised them

  • All complaints are acted upon and used as learning tools for the team

  • All staff at the practice have undergone criminal records checks

  • The practice has a safeguarding patients’ policy and members of the team know what to do if child abuse is suspected.

  Clinical records and confidentiality

  • The practice undertakes regular random audits of patient records

  • All new clinical staff have an induction session on practice record-keeping standards

  • Data protection notification is up-to-date

  • All staff understand and apply the data protection principles

  • The practice computer or manual records systems are secure

  • The practice computer or manual records systems are secure

  • All staff understand and apply the principles of confidentiality

  • Requests for access to medical records by patients are dealt with promptly

  • The practice has a publication scheme under the Freedom of Information Act.

  Fair and accessible care

  • The practice makes every effort to welcome patients in wheelchairs, with hearing or vision impairments, with learning difficulties, patients who are frail and/or elderly patients and who have other special needs

  • The practice has an equal opportunities policy that includes provisions for patients and other customers requiring routine and urgent care to be seen.

  Practice safety

  Infection control

  • The practice has an infection control policy that complies with current guidelines. All team members have a copy

  • Everyone receives training in infection control with regular updates to ensure that the practice procedures are understood by everyone and implemented rigorously

  • Records of training are maintained

  • Appropriate personal protection is provided

  • There is a practice protocol for dealing with inoculation injuries

  • Anastasija Petkevica is responsible for implementing infection control procedures throughout the practice.

  Dental radiography

  • Everyone involved with dental radiography is appropriately trained and has attended update courses as required. Records of staff training and updates are maintained

  • The radiation protection file is maintained

  • The practice protocol for referring patients is followed routinely

  • All radiographs are justified

  • Guidelines exposure settings for all types of radiographs are in place

  • Guidelines exposure settings for all types of radiographs are in place

  • Equipment is maintained and tested according to manufacturer’s recommendations

  • A quality assurance programme is in place.

  Staff, patient, public and environmental safety assessment

  • There is a written safety policy, which has been brought to the attention of everyone that works in the practice

  • Systems are in place for reporting accidents and injuries

  • Employees using display screen equipment are assessed

  • A fire risk assessment has been carried out

  • A first-aider or appointed person is present when the practice is open

  • Stress-related complaints are treated seriously and investigated fully

  • Autoclaves and air-receivers are inspected according to written schemes of examination

  • A practice risk assessment has been carried out and everyone is aware of its findings

  • Waste is segregated and stored safely prior to disposal

  • Everyone receives training in dealing with a medical emergency

  • The practice has a patient safety policy and systems are in place for reporting and investigating patient safety incidents

  • Systems are in place for the storage, recording and dispensing of medicines

  • The practice has a protocol for selecting new equipment and reporting incidents involving medical devices

  Clinical issues

  Evidence-based practice and research

  • The practice has access to Evidence-based dentistry

  • NICE guidelines are adopted, where appropriate

  • SIGN publications are referred to, where appropriate

  • The team can demonstrate that it delivers care according to selected clinical guidelines.

  Clinical audit and peer review

  • There is an annual cycle of clinical audit involving the team

  • The team can demonstrate changes they have made as a result of the audits

  • Referrals to DCPs are made in writing on a standardised form

  • Laboratories used by the practice are registered with the Medicines and Healthcare products Regulatory Agency

  • Procedures are in place for dealing with serious and untoward incidents

  • There is a system for dealing with poor performance.

  Prevention and public health

  • We aim to provide services in line with local and national strategies

  • Oral cancer screening is carried out routinely

  • Advice on tobacco use cessation is available

  • The practice participates in National Smile Week.

In this practice we take complaints very seriously and try to ensure that all our patients are pleased with their experience of our service. When patients complain, they are dealt with courteously and promptly so that the matter is resolved as quickly as possible. This procedure is based on these objectives.

Our aim is to react to complaints in the way in which we would want our complaint about a service to be handled. We learn from every mistake that we make and we respond to patients’ concerns in a caring and sensitive way.

• The person responsible for dealing with any complaint about the service that we provide is Dr A Petkevica, the practice Complaints Manager.

• If a patient complains by telephone or in person, we will listen to their complaint and offer to refer him or her to the Complaints Manager immediately. If the Complaints Manager is not available at the time, then the patient will be told when they will be able to talk to the Complaints Manager and arrangements will be made for this to happen. The member of staff will make a written record of your complaint and provide the patient with a copy as well as passing it on to the Complaints Manager. If we cannot arrange this within a reasonable period or if the patient does not wish to wait to discuss the matter, arrangements will be made for someone else to deal with it.

• If the patient complains in writing or by e-mail it will be passed on immediately to the Complaints Manager.

• If a complaint is about any aspect of clinical care or associated charges it will normally be referred to the dentist concerned, unless the patient does not want this to happen.

• We will acknowledge the patient’s complaint in writing and enclose a copy of this code of practice as soon as possible, normally within 3 working days. We will offer to discuss the complaint at a time agreed with the patient, asking how the patient would like to be kept informed of developments, for example, by telephone, face to face meetings, letters or e-mail. We will inform the patient about how the complaint will be handled and the likely time that the investigation will take to be completed. If the patient does not wish to discuss the complaint, we will still inform them of the expected timescale for completing the process.

• We will seek to investigate the complaint speedily and efficiently and we will keep the patient regularly informed, as far as is reasonably practicable, as to the progress of the investigation. Investigations will normally be completed within 6 months.

• When we have completed our investigation, we will provide the patient with a full written report. The report will include an explanation of how the complaint has been considered, the conclusions reached in respect of each specific part of the complaint, details of any 2 necessary remedial action and whether the practice is satisfied with any action it has already taken or will be taking as a result of the complaint.

• Proper and comprehensive records are kept of any complaint received as well as any actions taken to improve services as a consequence of a complaint

• If patients are not satisfied with the result of our procedure then a complaint may be referred to:

NHS Complaints

• NHS England PO Box 16738 Redditch B97 9PT, Email: England.contactus@nhs.net Tel: 0300 311 2233 or the Parliamentary and Health Service Ombudsman, Millbank Tower, Millbank London SW1P 4QP, telephone: 0345 015 4033 or www.ombudsman.org.uk for complaints about NHS treatment.

• Parliamentary and Health Service Ombudsman, Millbank Tower, Millbank London SW1P 4QP, telephone: 0345 015 4033 or www.ombudsman.org.uk for complaints about NHS treatment.

Private Complaints

• Dental Complaints Service, Stephenson House, 2 Cherry Orchard Road, Croydon CR0 6BA (Telephone: 08456 120 540) for complaints about private treatment

• The General Dental Council, 37 Wimpole Street, London, W1M 8DQ the dentists’ registration body.

NHS & Private

• Care Quality Commission, Tel: 03000 616161, Address: CQC National Customer Service Centre, Citygate, Gallowgate, Newcastle upon Tyne, NE1 4PA

The practice follows the GDC guidelines Standards for the Dental Team: ‘Principle 3, Obtain Valid Consent’. We treat patients politely and with respect, in recognition of their dignity and rights as individuals. We also recognise and promote our patients’ responsibility for making decisions about their bodies, their priorities and their care and make sure we do not take any steps without a patient’s consent (permission).

The clinical team member will always obtain valid consent before starting treatment or physical investigation, or providing personal care for a patient, because patients have a right to choose whether or not to accept advice or treatment. Clinical team members are
adequately trained to ensure that the patient has:

• Enough information to make a decision (informed consent)

• Made a decision (voluntary decision-making)

• The ability to make an informed decision (capacity)

The nature of treatment [NHS or private] and all charges are clarified to the patient before it commences and the patient is provided with a written treatment plan and cost estimate. All team members are aware that:

• Once the consent has been given it may be withdrawn at any time

• Giving and getting consent is a process, not a one-off event. It is an ongoing discussion between the clinician and the patient

• It is necessary to find out what the patient wants to know, as well as saying what the clinician thinks the patient needs to know. Examples of information which patients may want to know include: why a proposed treatment is necessary; the risks and benefits of the proposed treatment; what might happen if the treatment is not carried out and alternative forms of treatment, their risks and benefits, and whether or not the treatment is considered appropriate

• If an estimate has been agreed with a patient, but it is necessary to change the treatment plan, the patient’s consent to any further treatment and extra cost will always be obtained prior to providing the changed treatment. This will be achieved by the provision of an amended written treatment plan and estimate

Everyone aged 16 or over is presumed to have capacity to make their own decisions unless it can be shown that they lack capacity to make a particular decision at the time it needs to be made. If the treating clinician thinks that someone lacks capacity to make a treatment decision, s/he will carry out a mental capacity assessment and, if appropriate, make a decision in the person’s best interests.

Children’s consent

A child is a person under 18.

Children aged 16 and over are presumed to have capacity and able to consent or, refuse to treatment in their own right. If the practitioner thinks a child aged 16 or over may lack capacity, a mental capacity assessment will be carried out and the results recorded in the clinical notes.

If a child is under 16, it is the first choice to obtain the consent of the parent or carer. But for various reasons this may not be possible. A child who is under 16 can give consent if the practitioner considers that the child is ‘Gillick competent’.

Consent for processing personal data

There is a separate policy that coverts consent for processing the personal data of nonpatients. See the Data Protection and Information Security Policy, which covers marketing and its communication methods.

Training on consent is provided to team members at staff meetings. Consent procedures are reviewed and monitored by the practice manager.

Mental Capacity Policy

In our practice, we treat patients politely and with respect, recognising their dignity and rights as individuals. We also encourage patients to be involved in decisions about their care and, before embarking on any aspect of patient care, we seek their consent to do so – recognising the rights of patients to decide what happens to their bodies. We recognise that patients have the right to refuse advice or treatment.

Informed consent
We aim to provide each patient with sufficient information in a way that they can understand to allow them to make a decision about their care. We will use various communication tools to ensure that the patient understands what is being suggested.

In our discussions with patients, we explore what they want to know to help them make their decisions and explain:

• why we feel the treatment is necessary

• the risks and benefits of the proposed treatment

• what might happen if the treatment is not carried out

• the alternative treatment options and their risks and benefits

We encourage patients to ask questions and aim to provide honest and full answers. We
always allow patients time to make their decisions.

We always make sure that the patient understands whether they are being treated under the NHS or privately and what the costs will be. Where a patient embarks on a course of treatment, we provide a written treatment plan and cost estimate.

Where changes to the treatment plan are needed, we obtain the patient’s agreement and consent, including to any changes in the costs. The patient is given an amended treatment plan and estimate.

Voluntary decision making
Decisions about their care must be made by the patient, and without pressure. We respect the patient’s right to:

• refuse to give consent to treatment

• change their minds after they have given consent.

When this occurs we will not put pressure on the patient to reconsider but where we feel it is
important, we will inform the patient of the consequence of not accepting treatment.

Ability to give consent

Every person aged 16 or over has the right to make their own decisions and is assumed to be able to do so, unless they show otherwise. We recognise that, in some circumstances, children under 16 years may be able to give informed consent to examination and treatment. If a child under the age of 16 has “sufficient understanding and intelligence to enable him/herto understand fully what is proposed” (GILLICK COMPETENCE), then he/she will be competent to give consent for him/herself. Young people aged 16 and 17, and legally ‘competent’ younger children, may therefore sign a Consent Form for themselves but may like a parent to countersign as well.

Mental Capacity

The Mental Capacity Act 2005 is designed to protect and empower individuals who may lack the mental capacity to make their own decisions about their care and treatment. Dental practitioners are required to act under the provisions of the new act and follow its code of practice when treating mental incapacitated adults. Dentists may be required in most cases to make their own capacity assessments and determine when treatment is in the patients best interests.

Examples of people who may lack capacity include those with;

• DEMENTIA

• A SEVERE LEARNING DISABILITY

• A BRAIN INJURY

• A MENTAL HEALTH CONDITION

• A STROKE

• UNCONSCIOUSNESS CAUSED BY AN ANAESTHETIC OR SUDDEN ACCIDENT

The law says someone lacking capacity CANNOT do one or more of the following four things;

• Understand information given to them

• Retain that information long enough to be able to make a decision

• Weigh up the information available to make a decision

• Communicate their decision

Where we have doubts about a patient’s ability to give informed consent, we will seek advice from our defence organisation.

Acting in the patients best interest
If a patient needs care or treatment someone can give you the care or treatment you need.

This may happen because the patient needs help to decide what care or treatment they want because they cannot decide on your own because they do not have capacity at the time.

The person caring or giving treatment must follow the best interests checklist to decide what is in your best interest. For example in dentistry this could be;

• Treating the patient to get them out of pain (swelling, abscess etc)

• Dealing with trauma from an accident

If the patient has made a Lasting Power of Attorney, an advance decision to refuse treatment, or have a deputy, then they would make these decisions if you lack mental capacity.

Lasting Power of Attorney
Lasting Power of Attorney (LPA) is a legal document where you can say in writing who you want to make certain decisions for you, if you cannot make them for yourself. This person is called an attorney.

You can only make this legal document if you understand what it means.

You can already do this for property and money. You would do this using an Enduring Power of Attorney (EPA).

The Mental Capacity Act has a new kind of power of attorney called a Lasting Power of Attorney (LPA). The attorney must act in the best interests of the person lacking mental capacity.

If a clinician in our practice is treating a patient with mental capacity who has an LPA, we need to ensure that their rights cover Health and Welfare.

If you would like any other information on The Mental Capacity Act, you can google ‘Mental Capacity Act: Easy Read’ or ask our practice manager for more information.

This practice is committed to complying with the Data Protection Act 2018, the General Data Protection Regulation (GDPR), GDC, NHS and other data protection requirements relating to our work. We only keep relevant information about employees for the purposes of employment and about patients to provide them with safe and appropriate health care.

The person responsible for Data Protection is the Information Governance Lead Anastasija Petkevica Our lawful basis for processing personal data is:

• Consent of the data subject

• Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract

• [Other]

Our lawful basis for processing special category data is:

• Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of Union or Member State law or a contract with a health professional.

Consent
The practice offers individuals real choice and control. Our consent procedures put individuals in charge to build
customer trust and engagement. Our consent for marketing requires a positive opt-in, we don’t use pre-ticked boxes
or any other method of default consent. We make it easy for people to withdraw consent, tell them how to and keep
contemporaneous evidence of consent. Consent to marketing is never a precondition of a service.

Data protection officer (DPO)
NHS practice: Our DPO is the Information Governance Lead is Emilia Kalantari-Saghafi

Fully private practice: We do not have a Data Protection Officer as we do not process large volumes of data.

Pseudonymisation
Pseudonymisation means transforming personal data so that it cannot be attributed to an individual unless there is
additional information.

• Pseudonymisation – the data can be tracked back to the original data subject

• Anonymisation – that data cannot be tracked back to the original data subject

Examples of pseudonymisation we use are:

• We never identify patients in research, patient feedback reports or other publicly available information

• When we store and transmit electronic data it is encrypted and the encryption key is kept separate from the data

Data breaches
We report certain types of personal data breaches to the relevant supervisory authority within 72 hours of becoming
aware of the breach, where feasible. If the breach results in a high risk of adversely affecting individuals’ rights and
freedoms we also inform those individuals without undue delay. We keep contemporaneous records of any personal
data breaches, whether or not we need to notify.

Right to be informed
We provide ‘fair processing information’, through our Privacy Notice, which provides transparency about how we
use personal data.

Right of Access
Individuals have the right to access their personal data and supplementary information. The right of access allows
individuals to be aware of and verify the lawfulness of the processing. If an individual contacts the practice to access
their data they will be provided with, as requested:

• Confirmation that their data is being processed

• Access to their personal data

• Any other supplementary information or rights as found below and in our Privacy Notice

Right to erasure
The right to erasure is also known as ‘the right to be forgotten’. The practice will delete personal data on request of
an individual where there is no compelling reason for its continued processing. The right to erasure applies to
individuals who are not patients at the practice. If the individual is or has been a patient, the clinical records will be
retained according to the retention periods in Record Retention.

Right of rectification
Individuals have the right to have personal data rectified if it is inaccurate or incomplete.

Right to restriction
Individuals have a right to ‘block’ or suppress the processing of their personal data. If requested we will store their
personal data but stop processing it. We will retain just enough information about the individual to ensure that the
restriction is respected in the future.

Right to object
Individuals have the right to object to direct marketing and processing for purposes of scientific research and
statistics.

Data portability
An individual can request the practice to transfer their data in electronic or other format.

Privacy by design
We implement technical and organisational measures to integrate data protection into our processing activities. Our
data protection and information governance management systems and procedures take Privacy by design as their
core attribute to promote privacy and data compliance.

Records
We keep records of processing activities for future reference.

Privacy impact assessment
To identify the most effective way to comply with their data protection obligations and meet individuals’
expectations of privacy we review our Privacy Impact Assessment annually

Information security
Information Governance Procedures includes the following information security procedures:

• Team members follow the ‘Staff Confidentiality Code of Conduct’, which clarifies their legal duty to maintain confidentiality, to protect personal information and provides guidance on how and when personal or special category data can be disclosed

• Team members follow the ‘Staff Confidentiality Code of Conduct’, which clarifies their legal duty to maintain confidentiality, to protect personal information and provides guidance on how and when personal or special category data can be disclosed

• How to manage a data breach, including reporting

• A comprehensive set of procedures, risk assessments and activities to prevent the data we hold being accidentally or deliberately compromised and to respond to a breach in a timely manner

• The requirements and responsibilities if team members use personal equipment such as computer, laptop, tablet or mobile phone for practice business

Review
This policy and the data protection and information governance procedures it relates to are reviewed annually.

Our vision is for our practice to be a successful, caring and welcoming place for patients to receive dental care and advice. We want to create a supportive and inclusive environment where our staff can reach their full potential and care is provided in partnership with patients, without prejudice or discrimination. We are committed to a culture where respect and understanding is fostered and the diversity of people’s backgrounds and circumstances will be positively valued.

This policy will help us to achieve this vision.

Legal responsibilities

The rights of our patients and our staff with regards to discrimination are protected by antidiscrimination legislation including:

• The Equality Act 2010

• Part-time Workers (Prevention of Less Favourable Treatment) Regulations 2000

• Employment Rights Act 1996

By adopting this policy, we accept our responsibility to ensure that discrimination does not take place and that everyone is treated fairly and equally

Aim

The aim of this policy is to achieve equality of care experience by removing any potential discrimination in the way that people are cared for and treated by the Practice, including:

• people with disabilities

• people of different sexual orientations

• transgendered and transsexual people

• people of different races

• people on the grounds of their sex

• people of faith and of no faith

• people in relation to their age

• people in relation to their social class or medical condition

• people who work part-time

• people who are married or in a civil partnership

• women who are pregnant, have recently given birth or are breastfeeding

Putting this policy into practice

We aim to develop and support equality and diversity measures by:

• providing patient information in a variety of languages, if required

• having translation services available for patients who need this

• providing services that are accessible to patients with disabilities

• ensuring that care of individuals is planned with their specific needs at the centre

• tackling oral health inequalities through positive promotion and care

• involving patient groups and individuals in the design of our service

• involving patienresponding positively to the diverse needs and experiences of our patients and the community even when those needs are challenging to deal with t groups and individuals in the design of our service

• ensuring that we join up with services involved with the care of patients with particular medical and social care needs.

Comments and concerns

If you believe you have been treated in any way contrary to this policy or you have any comments on how we can ensure that it works better, please contact Dr Anastasija Petkevica at the practice. We will investigate your concerns and take appropriate action.

Monitoring and review

We will monitor the effectiveness of this policy and the impact on all other relevant policies and practice. This review will happen when necessary and as a minimum annually.

The practice may be asked to disclose information, documents, or records that we hold. Requests for personal information are made under the data protection legislation and under the freedom of information legislation for information about the NHS services provided by the practice.

Requests should be passed to Dr A Petkevica for personal information or for information about the practice that is not included in the practice information leaflet.

Requests for personal information

What is Personal Information? – Personal information is any information that allows a person to be identified. This includes information where the person is not named but a cross-reference to other information held by the practice would allow identification.

Date protection legislation allows individuals to request access to their personal information. Those eligible to request access include:

• A person aged 16 years or older

• The parents or guardians of a child under the age of 16 years and in connection with the health and welfare needs of the child

• A child under the age of 16 years who has the capacity to understand the information held by the practice. Children aged 11 years and under are deemed too young

• A third party, such as a solicitor, who has the written consent of individual concerned – checks should be undertaken to ensure that the consent is genuine – for example, by checking the patient’s signature or contacting the patient directly to confirm that they have given consent for the information to be disclosed.

If a request concerns information about a deceased person, those eligible to request access
include:

• The administrator or executor of the deceased person’s estate

• A person who has a legal claim arising from the person’s death – the next of kin, for example. The person should explain why the information requested is relevant to their claim.

If the information requested includes information about third parties, it can be disclosed if the third party gives consent or is a health professional involved in the care of the patient.

The request

All requests must be made in writing and describe the type of information required with dates, if possible, and include sufficient information to ensure correct identification (name, address, date of birth, for example). You must check that the person asking for information has the right to do so and, if necessary, ask for proof of identity.

We will provide the requested information within one month of receiving the request or confirming the individual’s identity.

The information
We will usually provide the information requested in electronic form using secure means, unless
the individual asks for the information in paper format or otherwise agreed. The individual may
also come to the practice to view the original version under supervision and on practice
premises.

We will provide the information in a way that can be understood by the individual making the requests and may need to provide an explanation to accompany dental clinical notes.

Unfounded or excessive requests

Where requests are manifestly unfounded or excessive (particularly if they are repetitive), we can:

• Charge a reasonable fee taking into account the administrative costs of providing the information; or

• Refuse to respond.

If we refuse to respond to a request, we will explain the reasons and informing the individual of their right to complain to the Information Commissioner’s Office and to a judicial remedy.

Requests for information about the practice

Freedom of information legislation allows anyone to ask for information about the provision of NHS services. The available information is described fully in the practice guide to information available under FOIA and the model publication scheme. If the requested information is part of a larger document, we will disclose only the relevant part.

A freedom of information request cannot include clinical records or financial records.

The request

The request must be made in writing and should describe the information that they want and with dates, if possible. The individual making the request does not have to give a reason.

The charges for information provided under a freedom of information request are included in the practice guide and the model publication scheme

We will provide Information within 20 working days of receiving the request or confirmation of identity or, if applicable, from the receipt of the fee.[England, Wales and Northern Ireland only: it may be possible to extend this timescale if we need more information about the request or are taking legal advice on whether an exemption applies. We must inform the person making the request if we need to extend the 20-working-day deadline.]

The information

Most of the information covered by a freedom of information request is available in the practice information leaflet or on the practice website. Requests for other information should be referred to Dr A Petkevica. If we do not hold the information requested, we will inform the individual within the 20-working-day time limit.

We will provide information in a way that is convenient for the person who requested it, which may be in writing, by allowing the applicant to read it on the premises, or, if the information is held electronically, in a useable electronic format.

We are not required to respond to

• Vexatious requests for information, for example, requests that are designed to cause inconvenience, harassment, or expense.

• Repeated requests for the same or similar information (unless the information changes regularly, for example performance or activity information)

In either situation, you should seek advice from Dr A Petkevica.

NB: This policy was taken from the BDA

WE WILL KEEP YOUR RECORDS SAFE

This dental practice complies with the Data Protection Act (2018) and General Data Protection Regulations (GDPR) 2018. This means that we will ensure that your information is processed fairly and lawfully.

WHAT PERSONAL INFORMATION DO WE NEED TO HOLD?

• Past/current medical and dental history, personal information such as address, phone numbers, age and name of your GP.

• Details of your NHS number and healthcare treatment entitlement.

• Details of your NHS number and healthcare treatment entitlement.

• Details of your exemption status if applicable.

• X-rays, clinical photographs and study models.

• Treatment plans and correspondence regarding treatment we have provided or proposed plus its costs.

• Notes of conversations or incidents that might occur for which a record needs to be kept.

• Consent of treatment.

• Any correspondence relating to you with other health care professionals ie: hospitals or community services.

Why do we hold information about you?

We need to keep comprehensive and accurate personal data about patients to provide you with safe and appropriate dental care. We will ask you yearly to update your medical history and contact details.

Retaining information

We will retain your dental records and orthodontic study models while you are a practice patient and after you cease to be a patient, for at least eleven years, or for children until age 25, whichever is the longer.

Security of information

Personal data about you is held in the practice’s computer system and/or in a locked manual filing system. The information is only accessible to authorized team members. Our computer system has secure audit trails and we back up information routinely

Disclosure of information

To provide proper and safe dental care we may need to disclose personal information about you to:

• Your general medical practitioner

• Other Dental Services

• Other health professionals caring for you

• Private dental schemes of which you are a member

• Medical Specialist Group

• Agents and Third parties as required by legal and law

In very limited circumstances or when required by law or a court order, personal data may have to be disclosed to a third party not connected with your health care. In all other situations, disclosure that is not covered by this Code of Practice will only occur when we have your specific consent. Where possible you will be informed of these requests for disclosure.

IF YOU DO NOT AGREE

If you do not wish us to use your information, you should discuss the matter with your dentist or the practice manager, Dr Imran Gulamhusein. If you object to the way we collect and use the information, we may not be able to continue to provide your dental care.

If you have any concerns about how we use the information and your do not feel able to discuss it with your dentist or the practice manager, you should contact The Information Commissioners Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Tel: 0303 123 1113 or 01625 545745.

Access to your records

You have the right of access to the data that we hold about you and to receive a copy. Parents may access their child’s records if this is in the child’s best interests and not contrary to a competent child’s wishes. Formal applications for access must be in writing to The Practice Manager.

If you do not agree

If you do not wish personal data that we hold about you to be disclosed or used in the way that is described in this Code of Practice, please discuss the matter with your dentist. You have the right to object; however, this may affect our ability to provide you with dental care.

You have a right to withdraw your consent at any time, however this will not be retrospective.

You have a right to withdraw your consent at any time, however this will not be retrospective.

You have the right to withdraw your consent to allowing the practice to contact you with practice newsletters, special offers, marketing, promotions, practice updates & appointment reminders.

From May 2018 Europe’s data protection rules will undergo their biggest changes in two decades. Since they were created in the 1990s, the amount of digital information we create, capture, and store has vastly increased. Simply put, the old regime was no longer fit for purpose.

The solution is the mutually agreed European General Data Protection Regulation (GDPR), which will come into force on May 25th, 2018 and become part of UK Law. It will change how businesses and public-sector organisations can handle the information of customers.

GDPR means that we at Finedon Dental practice will be more accountable for handling of people’s personal information and as such we have updated our data protection policies.

DATA PROTECTION CODE OF PRACTICE

Our data protection code of practice lays out our procedures that ensure Finedon Dental Practice and our employees comply with Data Protection Laws and The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)

WHAT PERSONAL DATA DO WE HOLD?

To provide patients with a high standard of dental care and attention, we need to hold their personal information. This personal data can include:

• Past and current medical and dental condition; personal details such as age, address, telephone number and general medical practitioner

• Radiographs, clinical photographs, and study models

• Information about their treatment that we have provided or propose and its cost

• Notes of conversations or incidents that might occur for which a record needs to be kept

• Records of consent to treatment

• Any correspondence relating to them and other health care professionals, for example in the hospital or Medical Specialist Group.

WHY DO WE HOLD INFORMATION ABOUT YOU?

We need to keep comprehensive and accurate personal data about patients to provide you with safe and appropriate dental care. We will ask you yearly to update your medical history and contact details.

RETAINING INFORMATION

We will retain your dental records and orthodontic study models while you are a practice patient and after you cease to be a patient, for at least eleven years, or for children until age 25, whichever is the longer.

SECURITY OF INFORMATION

Personal data about you is held in the practice’s computer system and/or in a locked manual filing system. The information is only accessible to authorized team members. Our computer system has secure audit trails and we back up information routinely.

DISCLOSURE OF INFORMATION

To provide proper and safe dental care we may need to disclose personal information about you to:

• Your general medical practitioner

• Other Dental Services

• Other health professionals caring for you

• Private dental schemes of which you are a member

• Medical Specialist Group

• Agents and Third parties as required by legal and law

Disclosure will take place on a ‘need-to-know’ basis. Only those individuals/organisations who need to know to provide care for you and for the proper administration of Government (whose personnel are covered by strict confidentiality rules) will be given the information.

In very limited circumstances or when required by law or a court order, personal data may have to be disclosed to a third party not connected with your health care. In all other situations, disclosure that is not covered by this Code of Practice will only occur when we have your specific consent. Where possible you will be informed of these requests for disclosure.

ACCESS TO YOUR RECORDS

You have the right of access to the data that we hold about you and to receive a copy. Parents may access their child’s records if this is in the child’s best interests and not contrary to a competent child’s wishes. Formal applications for access must be in writing to The Practice Manager.

IF YOU DO NOT AGREE

If you do not wish personal data that we hold about you to be disclosed or used in the way that is described in this Code of Practice, please discuss the matter with your dentist. You have the right to object; however, this may affect our ability to provide you with dental care.

You have a right to withdraw your consent at any time, however this will not be retrospective.

You have the right to withdraw your consent to allowing the practice to contact you with practice newsletters, special offers, marketing, promotions, practice updates & appointment reminders.

The practice is committed to providing a high standard of treatment and service to our patients whilst ensuring that treatment fees are collected on time. Team members are expected to make every effort to avoid a difficult situation arising with a patient over payment of fees. The use of court action or debt collectors as a means of obtaining settlement of outstanding accounts will only be considered when all reasonable steps to obtain payment have first been taken in writing.

Patients will be made aware of the fees, payment methods and conditions when their appointments are made. It will be explained to all patients that they will be expected to pay fees as the treatment progresses with the full balance due before the final appointment.

In case of an outstanding fee after the end of treatment the following procedure will be followed:

• The patient will be mailed a bill by first class post

• If the bill is not paid within 4 weeks a second bill will be sent

• If the account is still outstanding 2 weeks after the second bill, a reminder will be sent by mail asking for payment by return.

• If payment is not received after a further 2 weeks, the patient will be contacted by telephone or letter to enquire if there is any reason for non- payment. If there is a complaint about treatment this will need resolution and the bill may have to be waived. It is also possible that the patient’s financial situation has changed, there would be no point in pursuing a patient who cannot pay. If there is no problem or complaint the patient should be requested to pay by return

• If the account is still outstanding after another 2 weeks, the practice will send a letter advising of legal action if the account is not paid by return

• If the account is still outstanding after another suggest 2 weeks’ small claims court action will be instigated or a debt collector will be asked to collect the fees

Records of all correspondence and contacts with the patients must be kept in order to be able to prove that all reasonable steps were taken should the matter be referred to the GDC.

Special attention should be paid to patient confidentiality in relation to fees and fee recovery. The matter must not be raised with third parties, including relatives, unless the patient is a minor and the parent is responsible for the payment of fees. This is particularly relevant in relation to telephone calls.

Our policy is to provide and maintain safe and healthy working conditions, equipment and systems of work for all our employees and to provide such information, training and supervision as they need for this purpose. We also accept our responsibility for the health and safety of other people who may be affected by our work activities. This policy applies to all employees of the practice, dental associates, dental hygienists and other contractors providing services to the practice, such as anaesthetists.

The allocation of duties for safety matters and the particular arrangements that we will make to implement the policy are set out below.

This policy will be kept up to date, particularly as changes occur within the practice. To ensure this, the policy and the way in which it has operated will be reviewed every year.

Anastasija Petkevica

This is the quality assurance policy of Finedon Dental Practice

Our practice aims to provide dental care of a consistent quality for all patients; we strive to meet the high standards expected in any clinical setting. We expect all members of our dental team to work to these standards to help us achieve our aim of providing a quality service. Our management systems define each practice member’s responsibilities when looking after you.

The policies, systems and processes in place in our practice reflect our professional and legal responsibilities and follow recognised standards of good practice.

At our practice, we aim to achieve the best results for our patients through clear policies and systems and appropriately trained and competent team members. We evaluate our practice on a regular basis through audit, peer review and patient feedback and monitor the effectiveness of our quality assurance procedures.

Quality standards and procedures

Our practice has effective procedures for assuring and enhancing the quality of the services we provide for our patients.

In providing our patients with care of a consistent quality, we will:

• Provide a safe and welcoming environment

• Ensure all members of the dental team are appropriately trained

• Provide patients with information about the practice and the care available and ensure that the patient understands the terms on which care is offered

• Display indicative treatment charges

• Explain all treatment options and agree clinical decisions with the patient, explaining the possible risks involved with each option

• Provide treatment plans based on the agreed treatment with an estimate of the likely costs

• Obtain valid consent for all treatment. Written consent will be sought for extensive or expensive treatments and treatment provided under conscious sedation

• Refer to specialists for investigation or treatment as appropriate and without undue delay

• Maintain contemporaneous clinical records with an up-to-date medical history for all patients

• Provide secure storage of patient records to maintain patient confidentiality

• Explain the procedure to follow for raising a complaint about the service, identifying the practice contact

For our dental team, we undertake to:

• Provide a safe working environment through hazard identification and risk assessment

• Provide induction training for all new team members

• Provide job descriptions and contracts of employment to all members of staff.

• Review and update job descriptions annually to reflect current duties and responsibilities

• Agree in writing the terms for all self-employed contractors working at the practice

• Provide ongoing training and identify opportunities for development for all employees

• Maintain staff records ensuring the following information is up to date:

• relevant medical history information

• emergency contact details

• absence through holiday and sickness

• performance reviews

• in-house and external training

• Ensure that all staff are kept up to date with all practice policies and procedures, including patient charges and the relevant forms.

The dental team

Team members implement and adhere to the practice policies and procedures which are readily accessible in policy and CQC files.

All new members of the team receive training in practice-wide procedures, policies and quality assurance activities as part of their induction. Appraisal meetings take place annually and include an assessment of training needs.

We expect everyone working at the practice to

• Understand our aims and objectives

• Have an understanding of the skills and competencies required to deliver the services successfully

• Understand and participate in our quality assurance activities.

• Dealing with emergencies, including a collapsed patient.

Dentists and, where appropriate, hygienists also understand the policies and procedures for:

• Referring patients

• Requesting work from laboratories

• Ordering materials and equipment

• Clinical governance requirements and CQC standards of quality and safety

• Professional and legal requirements affecting dentistry.

All GDC registrants meet their continuing professional development requirements and, as required by the GDC, maintain records of their individual CPD activity. In addition, the practice maintains records of all practice-wide training it provides and training provided for individual members.

Policies and procedures

The following policies and procedures are in place in the practice and reviewed at least annually to ensure their relevance and currency.

• Child protection

• Commitment to staff

• Complaints handling

• Confidentiality

• Consent

• Data protection and data security

• Email and internet usage

• Employment policies and procedures:

• Adoption, maternity, paternity and parental leave

• Annual leave

• Bullying and harassment

• Disciplinary matters

• Grievance

• Redundancy

• Retirement

• Sickness/injury absence and pay

• Stress

• Staff appraisals

• Training

• Underperformance (whistleblowing)

• Equal opportunities

• Health and safety policies and protocols

• Electrical appliance test records

• Fire precautions and risk assessment

• Health and safety

• Infection control

• Radiation safety

• Risk assessment, including COSHH

• Healthcare waste disposal

• Patient feedback questionnaire

• Patient fees – collecting money and refunds

• Patient referral

• Staff satisfaction survey.

• Violence and aggression policy

Audit

We undertake regular audits of our procedures and protocols to monitor our service to our patients. On a regular basis, we consider:

Inputs

• Number of patients treated

• Number of patients treated by specific groups.

Outcomes

• Oral health achievements as a direct result of our intervention.

Effectiveness

• Patient views of effectiveness in improving their oral health

• Patient satisfaction levels.

Efficiency

• Patient retention rate

• Referrals to other healthcare professionals for advice and/or treatment

• Quality of data collection.

Quantitative data

On a monthly basis, we record the following:

• Total number of patients seen

• New patients seen

• Failed appointments (and unused time)

• Waiting list numbers – for assessment and for treatment

• Patient safety incidents and the outcome of investigations

• Positive feedback and compliments

• Complaints and negative comments.

Qualitative data

We record & act upon the following qualitative data:

• Results of patient and service audits and improvements

• Complaint trends and actions taken to improve the service

• Waiting times and evidence of demand management

• Staffing and staff turnover

• CPD activity on individual and practice-wide basis

• Case mix of clinical presentation and procedure outcome

• Results of annual patient satisfaction survey on a sample number of patients.

Clinical Governance

Our practice uses clinical governance to ensure we deliver a consistent standard of care to our patients. Our clinical governance framework incorporates the following:

• Infection control

• Child protection

• Dental radiography

• Staff, patient, public and environmental safety assessment

• Evidence-based practice and research

• Prevention and public health

• Clinical records, patient privacy and confidentiality

• Staff involvement and staff development

• Patient information and involvement handling, patient feedback

• Fair and accessible care

• Clinical audit and peer review

In relation to clinical governance:

• Everyone understands what the practice is supposed to do

• Everyone understands their role in delivering the service

• We monitor all our policies and procedures and how these are implemented

• We review our policies and procedures on a regular basis to identify where improvements can be made

• We conduct internal audits

• We share information and encourage staff members to raise any issues

• We allow for CPD, staff training and development

• We allow for (and encourage) patient suggestions.

• We aim to provide dental care of a consistently good quality for all patients

• We only provide care that meets our patients’ needs and wishes

• We aim to make our patients’ treatment as comfortable and convenient as possible

• We will look after our patients’ general health and safety while they receive dental care

• We follow national guidelines on infection control

• We check for mouth cancer and tell patients what we find

• We take part in continuing professional development to keep our skills and knowledge up to date

• We train all staff in practice-wide work systems and review training plans once a year

• We welcome feedback and deal promptly with any complaints

• Every member of the practice is aware of the need to work safely under GDC guidelines.

Review

This policy will be subject to regular review and will be updated annually.

The practice is committed to complying with the statutory and professional guidelines including, but not limited, to Access to Health Records 1990, Caldicott Guidelines 2017, the Data Protection Act 2018, the Freedom of Information Act 2000, the Public Interest Disclosure Act 1998 and current guidelines from the General Dental Council. Patients can be confident that their personal records, including medical records, are accurate, fit for purpose, contemporaneous, held securely and remain confidential and that other records, kept to protect their safety and wellbeing, are maintained and held securely. This policy applies to all team members and is maintained by the Practice Manager.

The practice:

• Will keep records securely and confidentially

• Will not keep records for longer than necessary

• Will store records in a secure, accessible way that allows them to be located when required

• Will securely destroy records at the end of the retention period

• If using a data processor have sufficient guarantees regarding information security; take reasonable steps to ensure compliance with those measures; and have an appropriate contract

This policy relates to the following records:

• Clinical records including medical history forms radiographs, consent forms, photographs, models, audio or visual recordings of consultations, laboratory prescriptions, referral letters

• Accident records

• Administration records, including: personnel, financial, accounting, contracts, litigation and complaint handling

• Risk assessments and audits, including: health and safety, COSHH, fire safety, etc.

• Keep any other records as required by authorities such as the GDC, RQIA, HIW, HIS and other regulatory bodies

All records are:

• Factual, consistent and accurate

• Noted immediately after the event has occurred and therefore contemporaneous

• Noted clearly in a way that cannot be erased

• Documented in such a way that the author and date of any amendments can be identified

• Free of jargon, irrelevant speculation and offensive comments

• Readable on scanned or photocopied images

All team members follow the guidelines of record retention and follow the practice polices of confidentiality, archiving and secure destruction.

Retention Period

Clinical records are retained for 10 years unless the treatment was complex or particularly difficult patients in which case for up 30 years.

Paper records are disposed of by incineration or shredding, followed by secure disposal or fire with appropriate safeguards for confidentiality during the procedure.

Electronic records are destroyed by secure file shredding or physical destruction of the storage media. Where the practice cannot delete clinical records from patient software the practice:

• Will not attempt, to use the personal data to inform any decision in respect of any individual or in a manner that affects the individual in any way

• Will not give any other organisation access to the personal data

• Will surrounds the personal data with appropriate technical and organisational security.

• Will permanently delete the information if, or when, this becomes possible.

Storage of patient records if the practice closes

If a practice closes the Practice Owner will consider providing details of these arrangements to their solicitor and is obliged to store records securely until the
Retention Period expires.

[England, Northern Ireland and Wales]

Prior to the closure of the practice, Dr A Petkevica will arrange for records to be stored securely [state method, e.g. archive facility] for the Retention Period and then they will be confidentially destroyed unless a decision is taken to continue storage, with all details of the arrangements recorded and kept.

[Scotland]

Prior to the closure of the practice, Dr A Petkevica will liaise with the Records Manager at [Health Board] to discuss the secure transfer of the NHS records to a designated storage location and will record the arrangements made, including the Health Board contact details.

Prior to the closure of the practice, Dr A Petkevica will arrange for private records to be stored securely [state method, e.g. archive facility] for the Retention Period. At the end of the retention period records will be confidentially destroyed unless a decision is taken to continue storage with all details of the arrangements recorded and kept.

We are committed to safeguarding children and vulnerable adults and to protecting them from harm. Our dental team accepts and recognises our responsibilities to develop awareness of the issues which may cause harm to children and vulnerable adults.

The Child Protection and Adult Safeguarding Lead at our practice is Anastasija Petkevica. Their deputy is Emilia Kalantari-Saghafi.

They are the relevant points of contact for raising concerns. They also have responsibility for ensuring that our policies and procedures for safeguarding children and vulnerable adults are kept up-to-date and operated correctly

We will endeavour to safeguard children and vulnerable adults by:

• developing an awareness of safeguarding issues

• promoting good safeguarding practice through all our practice policies and procedures

• following the guidelines set out below

• making team members and patients aware that we take child and vulnerable adult protection seriously and respond to concerns about the welfare of children and vulnerable adults.

• sharing information about concerns with agencies who need to know and involving parents and children appropriately

• following carefully the procedures for staff recruitment and selection (including referencing and DBS disclosure)

• providing effective management for staff by ensuring access to supervision, support and training.

This policy is underpinned by the following principles:

• patients have access to information and knowledge to ensure that they can make an informed choice

• patients are given the opportunity to consider the various treatment options available to them and are encouraged to fully participate in their care at the practice

• patients are supported to make their own decisions and to give or withhold consent to treatment - unless provided for otherwise by law, no-one can give or withhold consent on behalf of another adul

• information about patients held by the practice is managed appropriately and all members of the team understand the need for confidentiality.

• the individual needs of the patient are respected

• the background and culture of all patients is respected

• practice procedures ensure the safety of patients at all times

• recruitment and selection procedures at the practice are followed routinely and ensure that all required checks are carried out.

• We will review this policy and guidance annually.

Safeguarding guidance

Definitions

• CHILD- A child is anyone who has not yet reached their 18th Birthday

• VULNERABLE ADULT-A vulnerable adult is a person aged 18 or over who is, or may be, in need of community care services or is resident in a continuing care facility by reason of mental or other disability, age or illness or who is, or may be, unable to take care of him or herself or unable to protect him or herself against significant harm or exploitation.

Introduction

Members of the dental team are in a position where they may observe the signs of abuse or neglect or hear something that causes them concern about a child or vulnerable adult. The dental team has an ethical responsibility to follow the procedures for safeguarding set out in this guidance wherever a child or vulnerable adult is or might be at risk of abuse or neglect: this includes a responsibility to ensure that children and vulnerable adults are not at risk from
members of the profession itself.

If a team member becomes aware of anything that makes them suspect a child or vulnerable adult is being abused, they must immediately refer the matter to the Child Protection and Adult Safeguarding Lead. If it is not possible to refer the matter to them, the team member must refer the matter to the Deputy Lead. They will decide the most appropriate manner in which to deal with the situation. If there is any doubt about how a matter should be handled, they can obtain additional information from the Child Protection and the Dental Team website or the local Safeguarding team.

Any allegations made against or suspicions about a team member must be reported to the Child Protection and Adult Safeguarding Lead in the same way as if they had involved a child’s parent, a vulnerable adult’s carer or another person. If an allegation is made against or you have suspicions about the Child Protection and Adult Safeguarding Lead, this should be reported to her Deputy. If an allegation is made against or you have suspicions about the Deputy
Lead, this should be reported to the Child Protection and Adult Safeguarding Lead in the usual way. Where allegations involve any team member, the Child Protection and Adult Safeguarding Lead or her Deputy (as appropriate) will make decisions about the need for referral in the same manner as in any other case but may also invoke disciplinary procedures.

If neither the Child Protection and Safeguarding Lead nor her Deputy are available to consult, you may have to make a referral yourself

Forms of abuse & Signs of abuse

The dental team is not responsible for making a diagnosis of abuse or neglect, just for sharing concerns appropriately,but here are some examples of what might amount to abuse, so that you have some idea of what to look for :

Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm. It may also be caused by a parent or carer fabricating the symptoms of, or deliberately causing, illness.

Fabricated or Induced illness is where someone, often a parent or carer, exaggerate or deliberately cause symptoms of illness in a child or an adult at risk.

Emotional abuse is persistent emotional maltreatment causing severe and persistent adverse effects on emotional development. It may involve conveying to children or vulnerable adults that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of the other person. It may feature:

• age or developmentally inappropriate expectations

• interactions that are beyond the child’s or vulnerable adult's developmental capability;

• over protection and limitation of exploration and learning

• preventing participation in normal social interaction

• allowing a child or vulnerable adult to see or hear the ill-treatment of another

• causing a child or vulnerable adult frequently to feel frightened or in danger

• exploitation or corruption.

Sexual abuse involves forcing or enticing a child or vulnerable adult to take part in sexual activities, whether or not they are aware of what is happening. The activities may involve physical contact, including penetrative (for example rape, buggery) or non-penetrative acts. They may include non-contact activities, such as involving children or vulnerable adults in looking at, or in the production of, pornographic material or watching sexual activities, or encouraging them to behave in sexually inappropriate ways.

Neglect is the persistent failure to meet basic physical and/or psychological needs, likely to result in the serious
impairment of health or development. It may occur in pregnancy as a result of maternal substance abuse. Neglect
may also involve a parent or carer

• failing to provide adequate food, clothing and shelter;

• failing to protect a child or vulnerable adult from physical and emotional harm or danger

• failure to ensure adequate supervision

• failure to ensure access to appropriate medical care or treatment

• neglect of, or unresponsiveness to, basic emotional needs.

Financial abuse involves stealing from a vulnerable adult by, for example, a carer using benefit money to buy things for themselves.

You may become aware of potential abuse in a number of different ways:

• through a direct allegation (often referred to as a "disclosure") made by a child, vulnerable adult, parent, carer or some other person

• through signs and symptoms which suggest physical abuse or neglect (see above)

• through observations of child behaviour or parent-child interaction

• through observation of a vulnerable adult and the relationship they have with their carer.

If you are worried about a child or vulnerable adult – practical steps

It is uncommon for dentists to see patients with signs of abuse but where you have concerns about a patient who may have been abused and there is no satisfactory explanation, prompt action is important: immediately discuss your concerns with the Child Protection and Adult Safeguarding Lead, or their Deputy. They will decide whether a formal referral is required.

Abuse or neglect may present to the dental team in a number of different ways:

• a direct allegation (sometimes termed a ‘disclosure’) made by the child, a parent or some other person

• signs and symptoms which are suggestive of physical abuse or neglect

• or through observations of child behaviour or parent-child interaction

• signs of domestic abuse of a parent, such as bruises or an injury, or the parent (female or male) may disclose domestic abuse to you

• concerns about the mental or general health (alcohol, substance misuse or deteriorating health condition) of the parent.

Because of the frequency of injuries to areas routinely examined during a dental check-up, the dentist has an important role in intervening on behalf of an abused child. It is assumed that the dentist will be examining a child who is fully dressed

In some instances, the diagnosis of child abuse is clear. However, there are occasions when evidence is inconclusive and the diagnosis merely suspected. Members of the dental team are not responsible for making a diagnosis of child abuse or neglect, just for sharing concerns appropriately.

Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty & mutual respect 7 tolerance of different faiths & beliefs.

Discriminatory abuse is harassment, deliberate exclusion or unequal treatment on the grounds of a protected characteristic.

Institutional abuse is the use of systems & routines which neglect a person receiving care. It does not have to be intentional.

Domestic violence & abuse is any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. It includes Honour Based Violence (HBV), an unwritten code of conduct that involves domination, aggression and control by 1 or several members of an individual’s extended family or community and may be physical, emotional, sexual or financial. The use of the term ‘Honour’ or ‘Izzat’ describes the concept of protecting the prestige and reputation of a family or community. The term embraces a variety of crimes of violence which are mainly, but not exclusively, against women. These include assault, imprisonment and murder, where the person is being punished by their family or community.

FGM (Female Genital Mutilation) Constitutes all procedures which involve partial or total removal of the external female genitalia, or injury to the female genital organs for cultural or non-therapeutic reasons. FGM is illegal in the UK under the Female Genital Mutilation Act (2003) and the Children Act. PLEASE SEE MORE INFORMATION ABOUT FGM AT THE END OF THIS POLICY

Forced marriage describes a relationship in which 1 or more of the parties are married without consent or against their will which violates the principle of the freedom and the autonomy of individuals. FM differs from an arranged marriage in which both parties consent to someone helping them to find a partner. FM is illegal under the Forced mMarriage Act (2007) which enables victims of forced marriage to apply for court orders for their protection or marriage termination.

Modern slavery Includes holding a person in a position of slavery, servitude, or forced or compulsory labour. It is illegal under the Modern Slavery Act (2015) which includes human trafficking (the arrangement or facilitation of travel with a view to exploitation). Although human trafficking often involves a cross-border element, it is possible for someone to be a victim within their own country or even where consent has been given to be moved. The Modern Slavery Helpline on 08000 121 700 can be contacted for any information that could lead to the identification, discovery and recovery of victims in the UK. PLEASE SEE MORE INFORMATION ABOUT MODERN SLAVERY AT THE ENDOF THIS POLICY.

Raise Concerns If Patients Are At Risk

• Always put patients’ safety first

• Act promptly if patients or colleagues are at risk 7 take measures to protect them

• Make sure if you employ, manage or lead a team that you encourage and support a culture where staff can raise concerns openly & without fear of reprisal.

• Make sure if you employ manage or lead a team that there is an effective procedure in place for raising concerns, that the procedure is readily available to all staff and that it is followed at all times

• Take appropriate action if you have concerns about possible abuse of children or vulnerable adults (adults at risk).

Concerns related to a parent/carer

Concerns about the mental or general health (alcohol, substance misuse or deteriorating health condition) of the parent should prompt a discussion with the parent and a referral to children’s services, particularly when other signs of abuse and neglect are present. Children’s services will assess the need for child and family support and identify remedial action.

In respect of domestic abuse, if a parent makes a disclosure to you or a member of your staff, and requests help, contact your local children’s services office. If you suspect domestic abuse, enquire about this with the parent and inform them of your concern for their own and their child’s welfare. You are obliged to make a referral to the local children’s services office if you have concerns about domestic abuse and to inform the parent you are doing so. This is a very sensitive area and must be dealt with carefully so as not to increase any risks for the parent and child. Take advice from your named nurse or doctor for child protection, your local children’s services office or the local police domestic abuse unit.

Permission to refer:

The Child Protection and Adult Safeguarding Lead or their Deputy will consider whether to seek permission to refer. It is good practice to explain concerns to the child or vulnerable adult and their parents or carers, informing them of the intention to refer and seeking their consent – being open and honest from the start results in better outcomes. Wherever possible, patients should be separated from the alleged abuser before such conversations take place.

We will not, however, discuss concerns with the parents or carers where:

• the discussion might put the child or vulnerable adult at greater risk

• the discussion may impede a police investigation or social work enquiry

• sexual abuse by a family member/carer, or organised or multiple abuse is suspected

• fabricated or induced illness is suspected

• parents or carers are being violent or abusive and discussion would place you or others at risk

• it is not possible to contact parents or carers without causing undue delay in making the referral.

Where there is serious physical injury arising from suspected abuse:

• we will refer the individual to the nearest hospital Emergency Department (in the case of a child, with the consent of the person having parental responsibility or care)

• advise the Emergency Department in advance (by telephone) that the patient is coming.

• if consent is not obtained, the Duty Social Worker at the local Social Services Department or the police should be told of the suspected abuse by telephone so that the necessary action can be taken to safeguard the welfare of the individual.

• a telephone referral to Social Services must be confirmed in writing within 48 hours, repeating all relevant facts of the case and an explicit statement of why there are concerns. The telephone discussion should be clearly documented – who said what, what decisions were made and the agreed unambiguous action plan.

Where less serious injury is recorded or there is concern for the physical or emotional well-being of the individual, the Child Protection and Adult Safeguarding Lead (or her Deputy) will discuss the appropriate reporting procedures and our concerns with local Social Services (contact details below).

Recording and reporting

We will not attempt to investigate any allegations or suspicions ourselves but will instead refer matters to the appropriate authorities. It is important NOT to ask a child or vulnerable adult leading questions but to simply record what they say and what has happened. Asking leading questions may jeopardise any future criminal proceedings arising out of the allegation of abuse.

Where an injury is involved, reports will be restricted to:

• the nature of any injury;

• facts to support the possibility that the injuries are suspicious.

Attendance of the referring dentist may be required by the Social Services Department at a case conference or if there is a court hearing, so comprehensive written records of the injuries and its history (as reported) must be kept together with clinical photographs, where available.

Record keeping

Recording physical signs

Dental professionals are likely to observe and identify injuries to the head, eyes, ears, neck, face, mouth and teeth as well as other welfare concerns. Bruising, burns, bite marks and eye injuries are the types of injury that suggest a concern should be raised. Dental professionals are also well placed to identify the risks to oral and general health associated with poor oral hygiene and dental neglect. A patient may also disclose abuse or other indicators of it; such safeguarding concerns should always be recorded.

Accurate record keeping is an essential part of the accountability for safeguarding. Documentation within dental practices should accurately reflect not only the care provided but also any concerns in respect of a child, young person or adult at risk. It may feature information on anyone attending with the patient, any injury observed using diagrams where appropriate and a record of discussions concerning the patient. In cases of abuse records should include:

• description and location of injury

• nature of injury, such as bruise or laceration

• size and shape of injury

• comments and observations made by the patient, parent or carer

• the behaviour or presentation of, or comments concerning, the accompanying parent or carer

Concerns may also be raised in respect of how a parent or carer has related to, or behaves towards, a child or adult at risk. These should be recorded along with any actions taken including seeking advice and noting the advice given. If a decision is taken not to share safeguarding concerns, it is best to discuss this with a defence organisation or professional association.

Recording missed appointments

When a child or adult at risk misses an appointment, it should be recorded as “Was Not Brought” rather than “Did Not Attend”.

The purpose of the appointment and the consequences to the patient of it being missed are important considerations. Where there is a history of “Was Not Brought” for a particular patient it may indicate that action is needed to protect them, to ensure they get the treatment they require. This could involve talking to safeguarding services where there is a risk of neglect.

Recording non-compliance

‘Disguised compliance’ involves a parent or carer giving the appearance of cooperating with a patient’s dental
treatment to avoid raising suspicions of unsafe parenting or caring. The aim is to avoid social care interventions by
allaying professional concerns. Disguised compliance can make it very difficult for dental teams to maintain an
objective view of the welfare of the patient by preventing an understanding of the severity of harm being experienced
by the patient from being gained. Examples of behaviours which indicate disguised compliance include:

• repeated cancelling or rescheduling of appointments

• Sporadic compliance such as attending appointments or engaging with dental professionals for a limited period of time

• Patients or carers agreeing to make the changes needed to improve the patients oral health but then making little or no effort with this

Listening to children and vulnerable adults

We aim to create an environment in which children and vulnerable adults know their concerns will be listened to and taken seriously. We communicate this by:

• asking children for their views when discussing dental treatment options and seeking their consent to dental treatment in addition to parental consent;

• involving children and vulnerable adults when we ask patients for feedback about our practice; and

• listening carefully and taking them seriously if they make a disclosure of abuse.

Providing a safe and friendly environment for children and vulnerable adults

We will provide a safe and friendly environment by:

• taking steps to ensure that areas where patients are seen are welcoming and secure (with facilities for children to play where appropriate);

• considering whether young people or vulnerable adults would wish to be seen alone or accompanied by their parents or carers;

• ensuring that staff never put themselves in vulnerable situations by seeing young people or vulnerable adults without a chaperone; and

• operating safe recruitment procedures (refer to recruitment policy).

Use of interpreters and translators

Where a practitioner does not speak the same language as a patient, a patient has limited proficiency in English or requires British Sign Language, the services of an interpreter, either in person or through a telephone-based service (if appropriate), should be engaged. If an interpreter is not used, the reasons for this should be clearly recorded.

In some cases, patients may request that family members, friends or untrained members of their community interpret for them. However, the risk of relying on someone close to the patient, in what may be a highly personal and confidential situation, is that they may not be able to interpret accurately and may allow their own views of the situation to colour their translation. It may also be difficult, or even impossible, for the patient to disclose issues such as abuse
in their presence. Therefore, it is not considered good practice to use family members, friends or untrained members
of the community as interpreters as there can be no assurance of exactly what is being said and translated, especially
where abuse has occurred.

Not providing an interpreter can affect patient experience and health outcomes, increase missed appointments and make consultations less effective. Under the Equality Act 2010 it can also be considered indirect discrimination. Where a dental practice refuses to provide an interpreter for NHS care, they must have considered their interpreting provision and conclude that fulfils a test of ‘due regard’ under the public-sector equality duty.

Other relevant policies and procedures

Clinical governance policies that we already have in place contribute to the practice being effective in safeguarding children and vulnerable adults. Relevant policies and procedures include :

• safe staff recruitment procedures: carrying out checks with the DBS, making job applicants aware of our policy on child protection and safeguarding vulnerable adults, checking gaps in employment history, requesting proof of identity, taking up references;

• our complaints procedure: so that children or parents attending our practice can raise any concerns about the actions of team members that may put children at risk of harm;

• whistleblowing policy (underperformance policy): so that team members can raise concerns if practice procedures or the action of colleagues put patients at risk of harm.

• confidentiality policy, consent policy, equal opportunities policy, equality and diversity policy, patient safety policy, etc.

More information re: FGM (Female Genital Mutilation)

On the 31st October 2015, a new mandatory duty to report FGM cases to the police came into force.

Who does it apply to?

• All registered healthcare professionals and social workers in England, and Wales, including all dental professionals registered with the GDC who practice in England & Wales

• This is a personal duty: the health professional who first identifies FGM or is told by a girl under 18 years of age, that she has been subject to FGM, must report it to the police.

What does it involve?

The new duty applies where a dental professional, in the course of their work, either:

• Is informed directly by a girl under the age of 18 that an act of FGM has been carried out on her, or

• Observes physical signs which appear to show FGM – due to the nature of their work this aspect of the duty will apply principally to doctors, nurses and midwives.

There are 4 main types of FGM

• Type 1 – CLITORIDECTOMY – removing part or all of the clitoris

• Type 2 – EXCISION – removing part or all of the clitoris and the inner labia, with or without removal of the labia majora.

• Type 3 – INFIBULATION – narrowing of the vaginal opening by creating a seal, formed by cutting & repositioning the labia.

• OTHER HARMFUL PROCEDURES – to the female genitals, which include pricking, piercing, cutting, scraping and burning the area.

Effects of FGM

There are no health benefits to FGM. Removing and damaging healthy and normal female genital tissue interferes with the natural functions of girls’ and women’s bodies.

Immediate effects

• severe pain

• shock

• bleeding

• wound infections, including tetanus and gangrene, as well as blood-borne viruses such as HIV, hepatitis B and hepatitis C

• inability to urinate

• injury to vulval tissues surrounding the entrance to the vagina

• damage to other organs nearby, such as the urethra (where urine passes) and the bowel FGM can sometimes cause death.

• Long-term consequences

• chronic vaginal and pelvic infections

• abnormal periods

• difficulty passing urine, and persistent urine infections

• kidney impairment and possible kidney failure

• damage to the reproductive system, including infertility

• cysts and the formation of scar tissue

• complications in pregnancy and newborn deaths

• pain during sex and lack of pleasurable sensation

• psychological damage, including low libido, depression and anxiety (see below)

• flashbacks during pregnancy and childbirth

• the need for later surgery to open the lower vagina for sexual intercourse and childbirth

• Psychological and mental health problems

Case histories and personal accounts taken from women indicate that FGM is an extremely traumatic experience for girls and women, which stays with them for the rest of their lives. Young women receiving psychological counselling in the UK report feelings of betrayal by parents, as well as regret and anger.

More information re: Modern slavery

Modern slavery – Including; slavery, human trafficking, forced labour & domestic servitude, Traffickers & slave
masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse,
servitude & inhumane treatment

• PHYSICAL APPEARANCE: victims may show signs of physical or psychological abuse, look malnourished or unkempt, appear withdrawn

• ISOLATION: Victims will rarely be allowed to travel on their own, may seem under the control of others, rarely interact, may seem unfamiliar with their neighbourhood

• POOR LIVING: May be living in dirty, cramped, overcrowded accommodation. May be living and working at the same address.

• FEW OR NO PERSONAL EFFECTS: They may have no identification or documents, few personal possessions, wear same clothes day in & day out.

• RESTRICTED FREESOM OF MOVEMENT: Victims may have little opportunity to move freely, may have had passports taken away.

• UNUSUAL TRAVEL TIMES: May require strange/unusual appointment times

• RELUCTANT TO SEEK HELP: May avoid eye contact, appear frightened or hesitant to talk.