Our practice has an in-house complaints procedure set out within guidelines from the Primary Care Trust. Hopefully you will not need to use this, but if you do, all initial complaints should be directed to the practice manager.

You can submit feedback online by completing the Feedback and Complaints triage.

Feedback Form – Triveni PMS

Complaints Policy

This Policy and Procedure complies with The Local Authority Social Services and National Health Service Complaints (England) Regulations 2009, introduced on 1st April 2009 across health and social care.

Policy

• The practice will take all reasonable steps to ensure that its staff are aware of and comply with this procedure.
• The practice has nominated Dr Anuj Chaturvedi as complaints lead, to be responsible for managing the procedures for handling and considering complaints in accordance with the policy and procedure.
• The practice has nominated Dr Anuj Chaturvedi, partner as its responsible person, to be responsible for ensuring compliance with the policy and procedure, and in particular ensuring that action is taken if necessary in the light of the outcome of a complaint.
• The practice will take all reasonable steps to ensure that patients are aware of:
  • The complaints and comments procedure
  • The roles of the practice, the Primary Care Trust (PCT) and the health service ombudsman with regard to patient complaints.
    This includes the alternative facility for the patient to complain directly to the PCT instead of making their complaint to the practice, as well as their right to escalate their complaint to the health service ombudsman when they are dissatisfied with the initial response.
  • All escalations must be directed to the health service ombudsman (so when a patient is dissatisfied with the practice response to their complaint, they must escalate their complaint to the health service ombudsman, not the PCT).
• Their right to assistance with any complaint from the Patient Advice and Liaison Service (PALS); The Independent Complaints Advocacy Service (ICAS); Citizens Advice Bureaux, NHS Direct and the Care Quality Commission
• The practice complaints and comments patient information leaflet, the practice patient information leaflet/booklet and the practice website will be the prime information sources for implementing this policy and will be kept up to date and be made freely available to all patients.
• Patients will be encouraged to complain in writing where possible.
• All complaints will be treated in the strictest confidence.
• Patients who make a complaint will not be discriminated against or be subject to any negative effect on their care, treatment or support.
• Where a complaint investigation requires access to the patient’s medical records and involves disclosure of this information to a person outside the practice, Jane Whitall (practice manager), the complaints manager, will inform the patient or person acting on their behalf.
• The practice will maintain a complete record of all complaints and copies of all related correspondence. These records will be kept separately from patients’ medical records.

Procedure

Complaint initiated on Practice Premises

• In the event that a practice staff member notices that a patient appears to be distressed/upset on the practice premises, they should immediately contact the practice manager, who will attempt to identify and resolve the problem personally at that time.
• In the event of a practice staff member being advised that a patient wishes to make a complaint, the patient should be passed a copy of the current practice complaints and comments patient information leaflet.
• The patient should be asked if they intend to complete the form in this leaflet there and then, or do they intend to complete it later.
  • If they intend to complete it later, the practice staff member should provide them with an envelope.
  • If they intend to complete it there and then, the practice staff member ask if they require assistance in completing it – if so, the practice manager should be contacted to provide such assistance.
• Whichever option is chosen, the patient will be assured that their complaint will be acknowledged within 3 working days from receipt of the form.

Receipt and acknowledgement of complaints

The practice may receive the following complaints:

• A complaint made directly by the patient or former patient, who is receiving or has received treatment at the practice.
• A complaint made on behalf of a patient or former patient (with his/her consent), who is receiving or has received treatment at the practice.
• Where the patient is a child:
  • By either parent, or in the absence of both parents, the guardian or other adult who has care of the child.
  • By a person duly authorised by a local authority into whose care the child has been committed under the provisions of the Children Act 1989.
  • By a person duly authorised by a voluntary organisation, by which the child is being accommodated.
• Where the patient is incapable of making a complaint, by a representative who has an interest in his/her welfare.
• All complaints, whether written or verbal will be recorded by the practice manager in the dedicated complaints record.
• All written complaints will be acknowledged in writing within 3 working days of receipt.
• If the practice identifies that the complaint will involve an additional provider it will agree with that provider which organisation will take the lead in responding and communicating with the complainant.

Periods of time within which complaints can be made

The periods of time within which a complaint can be made is normally:

• 12 months from the date on which the event/incident which is the subject of the complaint occurred.
• 12 months from the date on which the event/incident which is the subject of the complaint comes to the complainant’s notice.

Initial action upon receipt of a complaint

• All complaints, whether verbal or in writing must be forwarded immediately to the Practice Manager or the Assistant Practice Manager, if unavailable to a partner, the practice responsible person.
• Where the complaint is made verbally, a written record will be made of the complaint and a copy of this will be provided to the complainant.
• A verbal or written acknowledgement of receipt of the complaint must be made not later than 3 working days after the day on which the practice receives the complaint.
• This written acknowledgement will include:
  • The name and contact details of the practice member of staff who will be attending the meeting and investigating the complaint.
  • An offer to meet with the complainant, at a time and location convenient, to discuss the manner in which the complaint is to be handled and the response period within which the investigation of the complaint is likely to be completed and the full response is likely to be sent to the complainant.
• As much of the following information as possible will be obtained at this initial meeting, to enable their concerns to be assessed correctly, resolved quickly if possible and build a good ongoing relationship with them:
  • Ascertain how they would like to be addressed – as Mr, Mrs, Ms or by their first name.
  • Ascertain how they wish to be kept informed about how their complaint is being dealt with – by phone, letter, email or through a third party such as an Advocacy or support service.
    If it’s by phone, ascertain the times when it is convenient to call and verify that they are happy for messages to be left on their answerphone.
    If it’s by post, make sure that they are happy to receive correspondence at the address given.
  • Check if consent is needed to access someone’s personal records
  • Check if they have any disabilities or circumstances that need to be taken account of.
  • Ensure they are aware that they can request an advocate to support them throughout the complaints process, including at the first meeting.
  • Systematically go through the reasons for the complaint so that there is a clear understanding why they are dissatisfied.
  • Ascertain what they would like to happen as a result of the complaint (for example, an apology, new appointment, reimbursement for costs or loss of personal belongings or an explanation).
  • Advise them at the outset if their expectations are not feasible or realistic.
  • Formulate and agree a plan of action, including when and how the complainant will hear back from the practice.
• If it is considered that the matter can be resolved quickly without further investigation, the practice will do so, providing the complainant agrees and there is no risk to other service users.
• In the event the complainant does not accept the offer of a discussion, the practice will itself determine the response period and notify the complainant in writing of that period.

Investigation and response

• Complaints should be resolved within a “relevant period” i.e. 6 months from the day on which the complaint was received.
• However, at any time during the “relevant period”, the practice complaints manager or responsible person has the discretion to liaise with the complainant to extend this timeframe to a mutually agreeable date, provided it is still possible to carry out a full and proper investigation of the complaint effectively and fairly.
• When an extension to the 6 months timeframe is being considered, it is essential that the complaints manager or responsible person takes into account that either party may not be able to remember accurately the essential details of the event/incident and also the feasibility of being able to obtain other essential evidence specific to the time of the event.
• The practice will investigate the complaint speedily and efficiently and as far as reasonably practicable, keep the complainant informed of the progress of the investigation.
• After the investigation is completed, the practice will compile a written report which incorporates:
  • A summary of each element of the complaint
  • Details of policies or guidelines followed
  • A summary of the investigation
  • Details of key issues or facts identified by an investigation
  • Conclusions of the investigation: was there an error, omission or shortfall by your organisation? Did this disadvantage the complainant, and if so, how?
  • What needs to be done to put things right
  • An apology, if one is needed
  • An explanation of what will happens next (e.g. what will be done, who will do it, and when)
  • Information on what the person complaining should do if they are still unhappy and wish to escalate the complaint, including full contact information on the health service ombudsman.
• The practice will send the complainant a response within the 6 months “relevant period”, signed by the practice manager or the GP involved. The response will incorporate:
  • The written report
  • Confirmation as to whether the practice is satisfied that any necessary action has been taken or is proposed to be taken;
  • A statement of the complainant’s right to take their complaint to the parliamentary and health service ombudsman.
• If the practice does not send the complainant a response within the 6 month “relevant period”, it will
  • Notify the complainant in writing accordingly and explain the reason why; and.
  • Send the complainant in writing a response as soon as reasonably practicable after the 6 month “relevant period”.
• In the event that the complaint has been incorrectly sent to the practice, the practice will advise the patient of this fact within 3 working days from its initial receipt and ask them if they want it to be forwarded to the correct organisation. If it is sent on, the practice will advise the patient of the correct organisation’s full contact and address details.

Handling Unreasonable Complaints

In situations where the person making the complaint can become aggressive or unreasonable, the practice will instigate the appropriate actions from the list below and will advise the complainant accordingly:

• Ensure contact is being overseen by an appropriate senior member of staff who will act as the single point of contact and make it clear to the complainant that other members of staff will be unable to help them.
• Ask that they make contact in only one way, appropriate to their needs (e.g. in writing).
• Place a time limit on any contact.
• Restrict the number of calls or meetings during a specified period.
• Ensure that a witness will be involved in each contact.
• Refuse to register repeated complaints about the same issue.
• Do not respond to correspondence regarding a matter that has already been closed, only acknowledge it.
• Explain that you do not respond to correspondence that is abusive.
• Make contact through a third person such as a specialist advocate.
• Ask the complainant to agree how they will behave when dealing with your service in the future.
• Return any irrelevant documentation and remind them that it will not be returned again.
• When using any of these approaches to manage contact with unreasonable or aggressive people, provide an explanation of what is occurring and why.
• Maintain a detailed record of each contact during the ongoing relationship.

Complaints Register

To ensure the practice monitors, handles and reviews complaints in a logical and timely manner, and to keep an Audit trail of steps taken and decisions reached, the practice records all complaints received on a dedicated complaints register.

Annual Review of Complaints

In line with national guidance, the practice will supply the following information to the PCT:

• The number of complaints received;
• The issues that these complaints raised;
• Whether complaints have been upheld;
• The number of cases referred to the Ombudsman.

Reporting a Summary of Complaints to the Care Quality Commission

The practice will adhere to the Care Quality Commission’s requirement of producing a summary of complaints at a time and in a format set out by the CQC and then send the summary within the timeframe specified.

We ask for your personal information so that you can receive appropriate care and treatment. This information is recorded on computer and we are registered under the Data Protection Act 2018.

The practice will ensure that patient confidentiality is maintained at all times by all members of the practice team. However, for the effective functioning of a multi-disciplinary team it is sometimes necessary that medical information about you is shared between members of the team.

Privacy Notice: Enhanced Access

Your Information, Your Rights

Being transparent and providing accessible information to patients about how we will use your personal information is a key element of the Data Protection Act 2018 and the EU General Data Protection Regulations (GDPR).

The following notice reminds you of your rights in respect of the above legislation and how your GP Practice will use your information for lawful purposes in order to deliver your care and the effective management of the local NHS system.

This notice reflects how we use information for:

• The management of patient records;
• Communication concerning your clinical, social and supported care;
• Ensuring the quality of your care and the best clinical outcomes are achieved through clinical audit and retrospective review;
• Participation in health and social care research; and
• The management and clinical planning of services to ensure that appropriate care is in place for our patients today and in the future.

Data Controller

As your registered GP practice, we are the data controller for any personal data that we hold about you.

What information do we collect and use?

All personal data must be processed fairly and lawfully, whether is it received directly from you or from a third party in relation to the your care.

We will collect the following types of information from you or about you from a third party (provider organisation) engaged in the delivery of your care:

• ‘Personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from the data.  This includes, but is not limited to name, date of birth, full postcode, address, next of kin and NHS number;

And

• ‘Special category / sensitive data’ such as medical history including details of appointments and contact with you, medication, emergency appointments and admissions, clinical notes, treatments, results of investigations, supportive care arrangements, social care status, race, ethnic origin, genetics and sexual orientation.

Your healthcare records contain information about your health and any treatment or care you have received previously (e.g. from an acute hospital, GP surgery, community care provider, mental health care provider, walk-in centre, social services).  These records may be electronic, a paper record or a mixture of both.  We use a combination of technologies and working practices to ensure that we keep your information secure and confidential.

Why do we collect this information?

The NHS Act 2006 and the Health and Social Care Act 2012 invests statutory functions on GP Practices to promote and provide the health service in England, improve quality of services, reduce inequalities, conduct research, review performance of services and deliver education and training.  To do this we will need to process your information in accordance with current data protection legislation to:

• Protect your vital interests;
• Pursue our legitimate interests as a provider of medical care, particularly where the individual is a child or a vulnerable adult;
• Perform tasks in the public’s interest;
• Deliver preventative medicine, medical diagnosis, medical research; and
• Manage the health and social care system and services.

How is the information collected?

Your information will be collected either electronically using secure NHS Mail or a secure electronic transferred over an NHS encrypted network connection.  In addition physical information will be sent to your practice.  This information will be retained within your GP’s electronic patient record or within your physical medical records.

Who will we share your information with?

In order to deliver and coordinate your health and social care, we may share information with the following organisations:

• Local GP Practices in order to deliver extended primary care services
• NHS England
• 111 and Out of Hours Service
• Local Social Services and Community Care services
• Voluntary Support Organisations commissioned to provide services by South East London CCG

Your information will only be shared if it is appropriate for the provision of your care or required to satisfy our statutory function and legal obligations.

Your information will not be transferred outside of the European Union.

Whilst we might share your information with the above organisations, we may also receive information from them to ensure that your medical records are kept up to date and so that your GP can provide the appropriate care.

In addition we received data from NHS Digital (as directed by the Department of Health) such as the uptake of flu vaccinations and disease prevalence in order to assist us to improve “out of hospital care”.

How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information that has been collected lawfully.  Every member of staff who works for an NHS organisation has a legal obligation to keep information about you confidential.  We maintain our duty of confidentiality by conducting annual training and awareness, ensuring access to personal data is limited to the appropriate staff and information is only shared with organisations and individuals that have a legitimate and legal basis for access.

Information is not held for longer than is necessary.   We will hold your information in accordance with the Records Management Code of Practice for Health and Social Care 2016.

Consent and Objections

Do I need to give my consent?

The GDPR sets a high standard for consent.  Consent means offering people genuine choice and control over how their data is used. When consent is used properly, it helps you build trust and enhance your reputation.  However consent is only one potential lawful basis for processing information.  Therefore your GP practice may not need to seek your explicit consent for every instance of processing and sharing your information, on the condition that the processing is carried out in accordance with this notice.  Your GP Practice will contact you if they are required to share your information for any other purpose which is not mentioned within this notice.  Your consent will be documented within your electronic patient record.

What will happen if I withhold my consent or raise an objection?

You have the right to write to withdraw your consent to any time for any particular instance of processing, provided consent is the legal basis for the processing.  Please contact your GP Practice for further information and to raise your objection.

Health Risk Screening / Risk Stratification

Health Risk Screening or Risk Stratification is a process that helps your GP to determine whether you are at risk of an unplanned admission or deterioration in health.  By using selected information such as age, gender, [NHS number/HCN number/ CHI number], diagnosis, existing long term condition(s), medication history, patterns of hospital attendances, admissions and periods of access to community care your GP will be able to judge if you are likely to need more support and care from time to time, or if the right services are in place to support the local population’s needs.

To summarise Risk Stratification is used in the NHS to:

• Help decide if a patient is at a greater risk of suffering from a particular condition;
• Prevent an emergency admission;
• Identify if a patient needs medical help to prevent a health condition from getting worse; and/or
• Review and amend provision of current health and social care services.

Your GP will use computer based algorithms or calculations to identify their registered patients who are at most risk, with support from the local Commissioning Support Unit and/or a third party accredited Risk Stratification provider.  The risk stratification contracts are arranged by South East London CCG/NHS England in accordance with the current Section 251 Agreement. Neither the CSU nor your local CCG will at any time have access to your personal or confidential data.  They will only act on behalf of your GP to organise the risk stratification service with appropriate contractual technical and security measures in place.

Your GP will routinely conduct the risk stratification process outside of your GP appointment.  This process is conducted electronically and without human intervention.  The resulting report is then reviewed by a multidisciplinary team of staff within the Practice.  This may result in contact being made with you if alterations to the provision of your care are identified.

A Section 251 Agreement is where the Secretary of State for Health and Social Care has granted permission for personal data to be used for the purposes of risk stratification, in acknowledgement that it would overburden the NHS to conduct manual reviews of all patient registers held by individual providers.

As mentioned above, you have the right to object to your information being used in this way.  However you should be aware that your objection may have a negative impact on the timely and proactive provision of your direct care.  Please contact the Practice Manager to discuss how disclosure of your personal data can be limited.

Sharing of Electronic Patient Records within the NHS

Electronic patient records are kept in most places where you receive healthcare.  Our local electronic systems (such as SystmOne, EMIS and Eclipse) enables your record to be shared with organisations involved in your direct care, such as:

• GP practices
• Community services such as district nurses, rehabilitation services, telehealth and out of hospital services.
• Child health services that undertake routine treatment or health screening
• Urgent care organisations, minor injury units or out of hours services
• Community hospitals
• Palliative care hospitals
• Care Homes
• Mental Health Trusts
• Hospitals
• Social Care organisations
• Pharmacies

In addition, NHS England have implemented the Summary Care Record which contains information including medication you are taking and any bad reactions to medication that you have had in the past.

In most cases, particularly for patients with complex conditions and care arrangements, the shared electronic health record plays a vital role in delivering the best care and a coordinated response, taking into account all aspects of a person’s physical and mental health.  Many patients are understandably not able to provide a full account of their care, or may not be in a position to do so.  The shared record means patients do not have to repeat their medical history at every care setting.

Your record will be automatically setup to be shared with the organisations listed above, however you have the right to ask your GP to disable this function or restrict access to specific elements of your record.  This will mean that the information recorded by your GP will not be visible at any other care setting.

You can also reinstate your consent at any time by giving your permission to override your previous dissent.

Invoice Validation

If you have received treatment within the NHS, the local Commissioning Support Unit (CSU) may require access to your personal information to determine which Clinical Commissioning Group is responsible for payment for the treatment or procedures you have received.  Information such as your name, address, date of treatment and associated treatment code may be passed onto the CSU to enable them to process the bill.  These details are held in a secure environment and kept confidential.  This information is only used to validate invoices in accordance with the current Section 251 Agreement, and will not be shared for any further commissioning purposes.

Your Right of Access to Your Records

The Data Protection Act and General Data Protection Regulations allows you to find out what information is held about you including information held within your medical records, either in electronic or physical format.  This is known as the “right of subject access”.  If you would like to have access to all or part of your records, you can make a request in writing to the organisation that you believe holds your information.  This can be your GP, or a provider that is or has delivered your treatment and care.  You should however be aware that some details within your health records may be exempt from disclosure, however this will in the interests of your wellbeing or to protect the identity of a third party.  If you would like access to your GP record please submit your request in writing to:

Triveni PMS. Escreet Grove, Woolwich SE18 5TE

Complaints

In the event that your feel your GP Practice has not complied with the current data protection legislation, either in responding to your request or in our general processing of your personal information, you should raise your concerns in the first instance in writing to the Practice Manager at:

Triveni PMS, Escreet Grove, Woolwich SE18 5TE

If you remain dissatisfied with our response you can contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wimslow, Cheshire SK9 5AF – Enquiry Line: 01625 545700 or online at www.ico.gov.uk

The Freedom of Information Act 2000 obliges the practice to produce a Publication Scheme. A publication scheme is a guide to the ‘classes’ of information the practice routinely make available.

Your responsibility to us:

• Help us to help you.
• Please let us know if you change your name, address or telephone number. You can update these details online by completing the Change of Personal Details form.
• Please do everything you can to keep appointments. Tell us as soon as possible if you cannot. Otherwise, other patients may have to wait longer. You can cancel an appointment online by completing the Cancel an Appointment form.
• We need help too, please ask for a home visit only when the person is too ill to visit the surgery.
• Please keep your phone call brief and avoid calling during peak morning time for non-urgent matters.
• Test results take time to reach us, so please do not ring before you have been asked to do so. Enquiries about tests ordered by the hospital should be directed to the hospital, not the practice. If you would like to request your test results online, you can do so by completing the Test Results triage.
• We ask that you treat the doctors and the practice staff with courtesy and respect.
• Please read our practice booklet. This will help you to get the best out of the services we offer. It is important you understand the information given to you. Please ask us questions by completing our online form if you are unsure of anything.
• Remember you are responsible for your own health and the health of your children. We will give you our professional help and advice; please act upon it.
• Please ask if you wish to see your doctor.

Our Responsibility to you:

• We are committed to giving you the best possible care.
• People involved in your care will give you their names and ensure that you know how to contact them.
• We run an appointment system in this practice. You will be given a time at which the doctor or nurse hopes to be able to see you. You should not wait more than 30 minutes in the waiting room without receiving an explanation for the delay.
• We will try and answer the telephone promptly and to ensure that there are sufficient staff available to do this. You should be able to speak to a doctor by phone.
• If you have undergone tests or x-rays ordered by the practice, we will inform you of the results at your next appointment. If no further appointment needs to be arranged, we will advise you when and how to obtain the results.
• Patients will be treated as individuals and partners in their health care, irrespective of their ethnic origin or religious and cultural beliefs.
• We will give you full information about the services we offer. Every effort will be made to ensure that you receive the information which directly affects your health and the care being offered.
• The practice will offer patients advice and information on health promotion:
  • Steps they can take to promote good health and avoid illness.
  • Self-help which can be undertaken without reference to a doctor in the case of minor ailments.

Please note that all our telephone calls are recorded for staff training and medico-legal purposes.

Also, please make sure we have an up-to-date telephone number at all times. If you need to update your details, you can do so online by completing the Change Personal Details form.

We strongly support the NHS policy on zero tolerance. Anyone attending the surgery who abuses the GPs, staff or other patients be it verbally, physically or in any threatening manner what-so-ever, will risk removal from the practice list. In extreme cases we may summon the police to remove offenders from the practice premises.