Video Recording Policy

Document Control

Purpose

To provide a process for the safe management of video data to meet the requirements of GDPR, patient confidentiality and also learning needs of trainee GPs and other clinical staff.

Who is affected by the process and to what level?

Detailed understanding

All staff working at Penrhyn Surgery.

An Awareness

All clinicians working at Penrhyn Surgery.

Monitoring

The Practice Manager is responsible for monitoring this process.

Review Date

April 2023

Responsibility for Review

The Practice Manager or GP Trainer is responsible for reviewing this process.

Background

Recording patient consultations for teaching purposes is a recognised and valued part of education in general practice (GP) to help both GP Trainees and qualified GPs develop their communication and consulting skills. Now that the range of primary care professionals is expanding, the technique may also be increasingly used by other clinicians. This advice is intended to help GP practices maintain this learning activity whilst ensuring they meet their responsibilities within the current guidance for information governance, including the UK General Data Protection Regulation (GDPR) 2021.

This guidance is mainly intended for GP Trainees, hence the reference throughout to GP Trainees. The same procedure should be used by any other clinician within a practice recording patient consultations.

Guiding Principles

All recorded consultations must be accompanied by a valid signed consent form and a notice statement regarding recording highlighted both in the Privacy Policy and held on display in the Penrhyn Surgery building, preferably in the reception area. Both the notice statement and informed consent form must give patients the information they want, or need, about the purpose of the recording and their rights.
Recordings are only to be made where appropriate consent or other valid authority has been given.
Penrhyn Surgery must also ensure that patients are under no pressure to give their consent for the recording to be made; ensure that patients are aware that not completing the consent form to record consultation will not affect the healthcare they receive in any way.
Where possible, stop the recording if the patient asks you to, or if it is having an adverse effect on the consultation or treatment
The disclosure or use of recordings from which patients may be identifiable ONLY with consent or other valid authority for doing so.
Only patients who are capable of consent can have their consultations recorded. Consultations with children require signed parental/guardian consent. Special care should be taken with the consent procedure where there might be issues; such as with competency to consent or potential language barriers.
Recordings of consultations should be handled with the same level of security as patient record files. Recording devices must not be left unattended during the recording process. Appropriate secure arrangements for storing recordings will be implemented:
- A secure encrypted device must be used to store this data.
- Recordings are to be anonymised before using or disclosing them as video recordings. This is especially true when used for teaching purposes, as this is considered for ‘secondary purposes’, meaning the recording is not or no longer solely for the benefit of the patient.
Recordings of consultations should not include any examination of the patient where clothing needs to be removed. Adjustments to clothing may be allowable e.g. removing a hat or rolling up a sleeve, but not exposing more intimate body areas.

Penrhyn Surgery will not:

Make, or participate in making, recordings against a patient’s wishes, or where a recording may cause the patient harm,
Disclose or use recordings for purposes outside the scope of the original consent without obtaining further consent (except in the circumstances where consent is implicit or in circumstances where disclosure is required by law, for the benefit of public interests or for research purposes).

Process for obtaining and recording patient consent

All practices where consultations might be recorded should have a notice in their reception and/or waiting room areas stating that patient consultations might be recorded for training purposes. It should also state that patients have a choice as to whether they wish to be recorded without that choice impacting on the provision of their health care. (Appendix A - example of such a notice).

GP Trainees should identify in advance the times at which they intend to record patient consultations. Last minute arrangements should be discouraged wherever possible.

If possible, patients should be made aware at the time of booking their appointment that, should the patient agree, the doctor concerned seeks to record the consultation.

Where the facilities exist for this, when the patient arrives at the practice, they should be diverted to speak to a receptionist (as opposed to registering their arrival at an automatic booking device). The receptionist should give the patient information about the purpose for recording their consultation and then, should the patient agree, ask them to sign the consent form. (Appendix B - example of a consent form).

The patient will take the consent form into the consultation with them to allow the GP to ensure consent has been given. Once the consultation has been completed, the GP should ask the patient to sign the form again to ensure the patient is happy for the recording to be used for training purposes. The form is left with the GP, who will return it to the reception team for filing in the patient’s records. If, for any reason, this does not happen, the recording should be deleted the same day.

Patients need to be made aware that they can withdraw consent at any time following this, either verbally or in writing, and it is good practice to confirm that the consultation has been deleted.

Informed consent should mean that the patient understands that:

The recording might be stored by a secure encrypted method until the training event has taken place or for no longer than 3 months, whichever is the shortest period, unless there is a justifiable exception.
The recording will only be used for training purposes, including assessment of the doctor, usually within the practice building between trainer and trainee. Sometimes teaching sessions may be held outside the practice in a group setting where the recording may be viewed by other trainers and Trainees.
That the recording may be used for Trainer skill development in benchmarking their assessments of Trainees.
If a training session is being held outside the practice, the recording will be transported via a secure, encrypted method. This recording will be deleted after the GP training session.
The patient can request that the recording is stopped at any stage during the consultation.
That the patient can withdraw consent at any time even after completion of the consent form.
The recording in the practice will be erased after the time period specified above unless written consent is obtained from the patient to extend the specified period.

Individual patient consent forms should be scanned on to the patient’s electronic notes record after the GP Trainee has completed their surgery. Additionally, a note should be made about the anticipated retention period for the recording.

Security of recorded consultations

Recordings of consultations should be handled with the same level of security as patient record files. It should be recognised that there is a potential risk of breach of confidentiality with any recorded consultation and procedures need to be in place to minimise this.

The practice has a dedicated recording device for the sole purpose of recording consultations. Personal smartphones or tablets must NOT be used.

On no account should the consultations be stored on the GPs PC or any place on the Practice server.

The Practice will issue a secure PIN authenticated encrypted portable hard drive to any trainee GP at the start of their time in the practice. It is the responsibility of the trainee to manage the safety of the pendrive and the data held on it. Instructions for accessing the PIN authenticated encrypted portable hard drive are available in Appendix D.

On no account should consultations recordings be left on the video camera at any time. Once recorded, the recordings should be transferred to the PIN authenticated encrypted portable hard drive, via a PC, and deleted from the video camera media.

The practice will record in the patient record that consent has been given and should maintain an asset log detailing all recorded consultations that are being stored on any secure encrypted device or drive.

Appendix C – example of an asset log

Storage of Data must comply with current UK GDPR guidance. The camera will be the responsibility of the Registrar. This responsibility includes the security of the camera (it should be in a locked location when not in use) and also responsibility for
deleting any consultations on the recording equipment after use. Deleting consultation from
the camera is particularly important if the camera is to be used by others.
The length of time that a recording can be stored on the secure device/drive is as specified in
the previous section.
Providing that the practice has ensured that the GP Trainee is fully aware of their policy for
recording consultations, the GP Trainee should be responsible for the erasure of all recorded
consultations at the appropriate time interval and should update the practice asset log when
that has happened. The practice will designate a member of staff to have oversight of this
too.
The practice will review the log prior to the Trainee leaving the practice to ensure all
recordings have been deleted.
The GP Trainee should follow any additional internal practice procedures as
appropriate.

Consultations

You will be allocated to an appropriate member of the clinical team based on your health needs.

Our clinical team includes a variety of professionals including Doctors, Nurses, Nurse Practitioners, Physician Associates, Pharmacists, Physiotherapists, Social Prescribers, and Mental Health Practitioners

All members of our clinical team are qualified, trained and accredited by their respective regulatory bodies.

Be aware of our one problem per consultation policy. Kindly click on this link for more information.

Each clinician’s consultation is within an allocated time period. GPs (10 minutes), ANPs (15 minutes), Physician’s Associates, Clinical Pharmacists and Physiotherapist (15 minutes), and Practice nurses (20 minutes) as examples.

Sometimes, the doctors and nurses may be running late, please bear with us. If you have an issue with time, please calmly discuss this with our receptionists.

Prescriptions

The practice will endeavour to process and issue ‘routine and uncomplicated’ repeat prescription requests within 2 whole working days (excluding weekends and bank holidays) of their receipt.

Urgent prescription requests are dealt with during consultations and usually arise as a direct requests from hospitals e.g. antenatal requests, palliative teams or from A and E attendances. These will be dealt with on a case-by-case basis.

Private prescription scripts- certain (not all) can be converted to NHS Prescriptions but this is decided on a case-by-case basis.

Following a consultation with you, where we have requested a test (Blood test, X-ray, Scan etc.), please click on the link for more information about what to expect.

Referrals

Why have I been referred?

Your GP will discuss with you and, if appropriate, your carer, why a referral is being recommended. It is usually because your GP wants a specialist’s help in deciding on the best way to treat your condition.

This might involve referring you for tests or investigations that cannot be carried out in a GP surgery. Your GP will also discuss with you what choices there are for where you can be referred.

How will I hear about where and when the appointment is?

GP practices and hospitals use different ways of arranging appointments:
We may give you a reference number and a password you can use to book, change or cancel your appointment online or by phone. Our secretary will send this to you usually by text.
You may receive a letter from the hospital confirming your appointment. You need to reply as soon as possible and tell the hospital if you can attend on the date offered.
Alternatively, sometimes patients receive a letter asking them to phone the hospital to make an appointment with a specialist.
Unfortunately, there are instances where you may have to be placed on a waiting list for a service/investigation you have been referred to, and the management of these waiting lists is not within the remit of the GP Surgery. Whilst we can confirm that you are indeed on a waiting list, there is not much we can do to expedite these waiting lists.
The staff will make every effort to follow up on your requests for information from third parties (such as the hospitals) but can only relay back to you the information that third parties are prepared to release.

2-week wait referral

In the special circumstance, however, where we have referred you on the 2-week pathway, the aim is to ensure that you get your first appointment within the 2 weeks of the referral being made.
We kindly ask all patients who have been referred by this pathway to contact the surgery if they have not heard anything about their appointment within 1 week of the referral being made.

Advice and Guidance

Sometimes we may ask a specialist to give us further advice and guidance on how to manage your condition.

The specialists usually respond to this request within 2 weeks

The specialist may advice a number of things including

Continue with your current treatment and management.
Request that you have additional tests e.g. blood tests, X-rays or Scan
Request we make changes to your current medication and/or prescribe additional medication.
We will contact you to let you know what advice they have offered.
Sometimes they may request that we refer you directly to the hospital for further assessment and management. Don’t panic, this usually means they want to do more assessments and tests which can only be done by a hospital specialist.

Please note, if they ask us to refer you, we will usually notify you by text.

Futher information on referrals for specialist care

What happens during my appointment?

Please ensure that you prepare adequately to maximise your time with the specialist. You may want to write down all your concerns and questions regarding your ailment and possible treatment. We recommend that you take a notepad along with you to write down things so you don’t forget.

Unfortunately we cannot answer queries about the management plan your specialist has agreed with you, as we are not specialist in that field and can only reiterate whatever they have agreed with you at the appointment.

Investigations requested by hospital/specialist doctors (including scans, blood tests, X-rays etc.)

When an investigation has been requested by a specialist doctor from the hospital, they are responsible for following it up and will usually offer the patient a follow-up appointment. As we are not specialist doctors, it will not be appropriate for us to offer an explanation or management of an investigation requested by a specialist doctor, so please don’t ask us.

Therefore we kindly request you await your follow-up with the specialist doctor who requested the investigation or await any written correspondence they may sendto us regarding your management.

Training Practice

Penrhyn Surgery is an approved training practice and we can provide training for a variety of clinical roles including medical students, GP trainees and internationally trained Medical Graduates.

In view of this, from time to time, you may be assessed by a trainee (working under the direct supervision of a GP Trainer).

All trainees are bound by the same confidentiality rules of GPs and NHS Staff. You will always be informed prior to your appointment if students/trainees are present. They will not be present during your consultation if you so wish.

Recording of Consultations (as part of training)

As part of this training programme, we will regularly use telephone and video for patient consultations as this forms part of the educational training process for assessing consultations with trainees.

The telephone and video recording is only of you and the doctor talking together. Intimate examinations will not be recorded and video recording can be switched off on request. All recordings are carried out according to guidelines issued by the General Medical Council.

More information about recordings of patients

Only those persons who have legal access to your medical records will see the video or hear the recording, as also doctors and advisers involved in the assessment. Its use will be limited to the assessment of the doctor with whom you are consulting and possibly for research, learning and teaching purposes.

All telephone calls to the practice are recorded securely on our telephony provider's server and are fully GDPR compliant.

We will be using appropriate applications for the recording of video consultations, and uploading them to secure sites for assessment. They are both subject to the same degree of confidentiality and security as medical records. Recordings will be erased as soon as practicable and in any event within three years.

You do not have to agree with your consultation with the doctor being recorded. If you want the video recording turned off, or change your mind about the telephone recording being used, please tell the doctor. This is not a problem, and will not affect your consultation in any way. But if you do not mind your consultation being recorded, we are very grateful to you.

Please confirm your consent to having your video consultation recorded for training assessment purposes when requested. This agreement will be recorded in your medical record. Improving the assessment of GPs should lead to better service to patients. Thank you very much for your help.

We are open to constructive feedback

While we strive towards providing an excellent service we recognise that we will sometimes get things wrong.

We have found out that engaging with patients, who provide us with constructive feedback on how we can improve the system when things go wrong is a valuable resource for our practice.

We have an informal, non-confrontational way for patients to discuss concerns or provide feedback which can allow us to address any issues raised in full, and hopefully avoid escalation to a formal complaint.

We encourage patients to go through this route first for all complaints if possible. This will assist us in making changes and improving service provision to our patients, thereby enhancing your satisfaction with the service received from us.

These informal opportunities allow patients to discuss their care and also let us reassure them, manage their expectations, and build trust. Please ask for the Practice Manager who can help facilitate this process.

We also have a formal complaint policy, and we encourage patients to go through this also for complaints if they are unwilling to pursue the informal route.

As a practice, we do recognise a minority of patients whose expectations we cannot meet no matter what we do.

How to complain to the NHS

Breakdown in the relationship between the patient and the surgery

We are of the opinion that if a patient considers that the practice as a whole has failed him or her and there is a fundamental lack of trust in the practice team, then in order for them to ensure they continue to receive the desired health care they have not received from our surgery, it will be better for them to find an alternative practice that will serve their needs better.

This is considered a better outcome for both parties.

Please ask the practice manager for assistance on this matter.

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