At Galway Bay Medical Centre we are committed to providing you and all our patients with a safe and comfortable environment in which to discuss their health concerns, when an intimate examination may be necessary. 

You want you to always feel at ease and with all aspects of your interactions with all our clinical staff. 

Maybe there are times when having a chaperone present would help you? 

A chaperone can be a family member or a friend or alternatively, our nurse or another member of staff, if available. 

If you would like a chaperone present during your consultation, please advise our reception team when booking your appointment.

You may also ask for a chaperone on arrival for an appointment, although the practice cannot guarantee a chaperone being available at short notice. 

If this is the case your examination can be cancelled. 

We know that sometimes we can make mistakes or fail to meet expectations.
We know there will be times when patients or their families will feel a need to express dissatisfaction with the service or care provided at Galway Bay Medical Centre.
This complaints policy aims to provide an open and transparent pathway to make us aware of occasions when we may not have performed to our usual high standards. 

It is our practice policy to do our best to resolve any such complaints as quickly as possible and to ensure that each member of staff fulfils their duty to listen to our patients concerns. 

All complaints whether verbal or written will be taken seriously and handled appropriately, sensitively and in confidence by our doctors, nurses and administrative staff. 

We commit to safeguarding the rights and dignity of our patients and members of staff in the implementation of this policy.
We encourage our patients to let us now when we have failed to meet expectations as this helps us to continuously improve our service.
We will implement changes in response to shortcomings where possible and in a timely manner. 

 

Open Disclosure 

It is the policy of this Practice to disclose to patients all information relating to shortcomings in care and treatment. If we discover that we have failed in our duty of care to you, we commit to disclose this to you and not to wait for you to find out by some other means. 

We will say sorry if we mess up. 

It is the policy of this practice to offer an apology when we have failed to meet our commitments to patients. 

We support open disclosure and will communicate with our patients and their families in an open, honest, and transparent manner if things go wrong. 

We believe it is the right thing to do. 

We believe it is the correct and ethical response to an adverse event. 

We believe it allows patients and their families to make informed decisions regarding their subsequent treatment and care. 

Managing complaints openly and quickly 

We are committed to resolving complaints at the earliest possible opportunity and all members of our practice team will treat feedback, both positive and negative, with courtesy respect and efficiency and follow the Standard Operating Procedure (SOP) which accompanies this policy. Similarly, we expect patients to treat all members of our practice team with courtesy when making a complaint.
We will publicise our procedure so that people know how they can raise an issue and with whom. 

We will always try to resolve complaints in person and at the earliest opportunity. 

If the appropriate person is not available to deal with a complaint immediately, we will ensure that a member of our practice team will contact the patient and/or family at the earliest possible opportunity.
Where an investigation is indicated patients and families will be included from the outset. 

Anonymous Complaints 

In the interest of fairness, we cannot investigate anonymous complaints. We are happy for a complaint to be made in confidence to one of our GPs in the consultation room but there may be a limit to how confidential it can remain if such a complaint is to be investigated thoroughly. 

Vexatious Complaints 

If following investigation, a complaint is found to be frivolous or vexatious, we will not pursue the complaint any further. If a complaint is found to be vexatious or malicious, there will be no record of the complaint in the file of the staff member / service about which the complaint was made. Before the complaint is deemed vexatious the member of staff who receives it must bring it to the attention of the designated person in the Practice. 

 

Principles 

Fairness and Equity:
The investigation of complaints will be fair and transparent, and patients should not fear recrimination for raising an issue of concern to them. A consistent and standardised approach will be adopted for the management of all complaints. 

Respect:
We will treat patients and families with respect and dignity as we also expect to be treated by patients and their families 

Accessibility:
We will publicise our policy and make it accessible to patients and their families. Special attention will be paid to the needs of people with specific requirements e.g., older people, children, people with physical and sensory disability, literacy issues and disadvantaged groups. A copy of this policy will be available on request at reception. 

Effectiveness and Efficiency:
We will try to resolve all complaints effectively and within clearly stated timeframes without compromising other principles. 

Impartiality:
We will deal with all complaints in an impartial manner. Complainants will have the opportunity to be heard and complaints will be investigated without prejudice to either the complainant, the doctor or member of staff. 

Confidentiality:
We will treat all information obtained through the course of complaint management in a confidential manner and meet the requirements of the Data Protection Acts 1988 and 2003. 

Consent:
We will ensure that consent to access patient-confidential information is obtained (or implied) from the complainant and/or the person on whose behalf the complaint is made. 

Accountability:
Procedures will be transparent to the complainant during the process of all complaint investigation. Recommendations arising from any investigation will be implemented where resources allow. Recommendations relating to Patient Safety will be given priority and an appropriate action plan will be implemented in a timely manner. Complaints will be recorded, and action plans will be monitored ensuring learning from complaints. 

Right of Appeal:
Patients will be informed of their rights in relation to appeals processes and of other avenues to pursue their complaint if dissatisfied with the local investigation 

Confidentiality is a time-honoured principle of medical ethics and is a principle that all doctors take very seriously. 

  

• Your records are confidential to you, even after your death, except for certain limited circumstances. 

• Your doctor will not breach that confidentiality without your permission, subject to rare exceptions. 
• Your doctor is obliged to keep your records stored safely and securely. Patient records in GBMC are stored in digital format on our patient management system. Any paper-based information we receive related to your records is scanned to your file and the original paper copy is securely shredded. 
• Your doctor must ensure that your records are accurate and up to date. 

  

Should there be a request for a copy of your records, either from yourself or from a third party (such as your medical insurer) this policy details how we will deal with that request. 

  

Personal requests 

As a general principle you are entitled to a copy of your records. 

There are exceptions where the release would compromise your health or breach our duty of confidentiality to others. 

As your GP we must first ascertain whether the request is from you, the patient, or from a third party. 

In all such situations we require that any request for records be submitted to us in writing and this request will be held on your file. 

There are rare circumstances where we can release the records without your consent which include: 

  

• On foot of a Court order 
• Legislative exceptions such as notifiable diseases 

• Children First guidelines where children may be of risk of neglect or harm 
• Acting in the best interest of incapacitated patients 
• Where the public is at risk of serious harm to health or death 

  

Your doctor will normally obtain your consent to share relevant medical records with other health professionals to ensure the safe delivery of care. 

You are entitled to refuse to consent to the sharing of this information. This refusal and the basis for same will be recorded on your file. 

  

Third party requests. 

There are many occasions when other health professionals, family members, insurance companies or solicitors contact us to seek a copy of your records or reports. 

In these cases, it is our policy to inform you of the request and to seek your consent. 

If you refuse, we will consider the reason for refusal and document the fact of refusal. 

Family members sometimes require copies of records. 

This information will not be provided without your consent. For example, where adult children are involved in the care of their elderly patients, we will always seek consent from the parent before disclosing any information. 

Insurance companies and solicitors often seek information or reports relating to claims made by patients on the basis that consent has been given. 

In these cases, and regardless of what consent is being claimed, it is our policy to redact (remove) any information that we consider irrelevant to the matter at hand from your records. 

We will then ask you to read the redacted copy and approve it for release before we draft any report or agree to any transfer of information. 

However, we cannot redact information relevant to the matter at hand and cannot provide a medical report should you decide to not provide consent in these cases. 

Further detail on matters of privacy and confidentiality can be found in our Confidentiality Statement. 

GBMC wants to ensure the highest standard of medical care for our patients. 

We understand that confidentiality is a fundamental principle of medical ethics and is central to the trust between patients and doctors. 

The privacy practices we adopt in our practice are in line with the Medical Council guidelines, the privacy principles of the Data Protection Acts and General Data Protection Regulation (GDPR) and the ICGP Guide to Data Protection Legislation for Irish General Practice. 

We see our patients’ consent as being the key factor in dealing with their health information. 

This statement is about making consent meaningful by advising you of our policies and practices on dealing with your medical information. 

Managing your information 

• To provide for patient care we need to collect and keep information about patients and their health on our records. 
• We commit to retaining patient information securely. 

• We will only ask for and keep information that is necessary. We will try to keep it as exact and up to date as possible. We will explain the need for any information we ask for if a patient is not sure why it is needed. 
• We ask all patients to inform us about any relevant changes that we should know about. This would include such things as any new treatments or investigations being carried out that we are not aware of. Patients are asked to inform us of change of address and phone numbers. 
• All persons in the practice (not already covered by a professional confidentiality code) sign a confidentiality agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty. 
• Access to patient records is regulated to ensure that they are used only to the extent necessary to enable the employee in question, whether secretary, manager, or healthcare professional to perform their tasks for the proper functioning of the practice. 

Patients should understand that practice staff may have access to their records for... 

• Identifying and printing repeat prescriptions for patients. These are then reviewed and signed by the GP. 

• Generating a social welfare certificate for the patient. This is then checked and signed by the GP. 
• Typing referral letters to hospital consultants or allied health professional such as physiotherapists, occupational therapists, psychologists, and dieticians. 
• Opening letters from hospitals and consultants. The letters could be appended to a patient’s paper file or scanned into their electronic patient record. 

• Scanning clinical letters, radiology reports and any other documents not available in electronic format. 
• Downloading laboratory results and Out of Hours Co-op reports and performing integration of these results into the electronic patient record. 
• Photocopying or printing documents for referral to consultants, attending an antenatal clinic or when a patient is changing GP 
• Checking for a patient if a hospital or consultant letter is back or if a laboratory or radiology result is back, in order to schedule a conversation with the GP. 
• When a patient contacts the practice, checking if they are due for any preventative services, such as vaccination, ante natal visit, contraceptive pill check, cervical smear tests, etc. 

• Handling, printing, photocopying, and postage of medico legal and life assurance reports, and of associated documents. 

 

At all times we will.... 

• Take into consideration Freedom of Information and Data Protection principles. 
• The practice is committed to guarding against accidental disclosures of confidential patient information. Before disclosing identifiable information about patients, the practice will: 

• Be clear about the purpose for disclosure. 
• Have the patient’s consent or other legal basis for disclosing the information. 
• Have considered using anonymised information and be certain it is necessary to use identifiable information. 
• Be satisfied that we are disclosing the minimum information to the minimum amount of people necessary 
• Be satisfied that the intended recipient is aware the information is confidential and that they have their own duty of confidentiality. 

Disclosure with consent 

If a patient is capable of making their own decisions about their healthcare, we will get their consent before giving confidential information that identifies them to the patient’s relatives' close friends, or for research or to disease registers. 

If the patient does not consent to disclosure of identifiable information, we will respect that decision except where failure to make the disclosure would put the patient or others at risk of serious harm or the disclosure is required by law or in the public interest as outline below. 

Patients should understand and accept that their healthcare information must be shared within the healthcare team and with support staff to provide effective and safe care. If disclosure of a patient’s information within our practice or to other health care providers is necessary as part of a patient’s treatment and care, we will explain this to the patient and disclose the information to an appropriate person making sure they are aware of their duty of confidentiality. If a patient objects to the transfer of the information we deem necessary, we will explain to the patient that we cannot arrange referral or treatment without disclosing the information. 

We recognise that clinical audit, quality assurance, education and training are essential for providing safe and effective healthcare. If we are providing patient information pursuant to of any of these activities, we understand the information must be anonymised or coded before it is disclosed outside the healthcare team. If that is not possible, we will make sure a patient is told about the disclosure in advance and given the opportunity to object. We will respect a patient’s wishes in respect of the disclosure. 

Disclosure without consent 

In certain circumstances we will be required to disclose patient information by law or in the public interest. We will inform the patient in advance of such an intended disclosure unless this would cause the patient serious harm or would undermine the purposes of the disclosure. 

We will disclose patient information where required by law, for example, pursuant to a court order or infectious disease notification or if we hold a reasonable belief that a crime involving a sexual assault or other violence has been committed against a child or other vulnerable person. We may make a disclosure in the public interest to protect a patient, other identifiable people, or the wider community. Before making such a disclosure the practice will be satisfied that the possible harm the disclosure may cause to the patient is outweighed by the benefits that are likely to arise for the patient or others. The disclosure will be limited to the minimum information and minimum number of people necessary. 

If a patient lacks capacity to give consent and is unlikely to regain capacity, we may consider making a disclosure only if it is in the best interests of the patient. 

As a rule, we will always tell the patient in advance that we are disclosing information without the patient’s consent and why the GP is doing so, unless to do so would put the patient or third party at risk of serious harm. 

Request for records from a patient or third party before and after death of a patient. 

If the practice receives a request from a patient to release a copy of a patient’s records, we will carefully consider the obligation to remove all references to third parties. 

In the case of requests for disclosures to insurance companies or requests made by solicitors for a patient’s records we will only release the information with the patient’s signed consent. 

We are aware that patient information remains confidential even after death. If it is not clear if a patient consented to the disclosure of information after death, we will consider how the disclosure might benefit or cause distress to the family or carers, the effect of disclosure on the reputation of the deceased and the purpose of disclosure. We will require written consent to disclosure of a deceased’s patient’s records from the personal representative or executor of the deceased’s will. We are aware that a GP’s discretion may be limited if a disclosure of a patient’s records is required by law. 

Medical reports 

• We will only prepare a medical report on a patient with a patient’s consent. 
• A report will be specific to the episode for which the report has been requested. 
• We understand that a medical report requested by a third party such as an employer, insurance company or legal representative must be factual, accurate and not misleading.  
• We will seek to ensure that the patient understands the scope and purpose of the report and that the GP cannot omit relevant information. 

• We will also seek to ensure the patient is aware of our duty of care to them and to the person/company from whom the report was requested. 

Recordings 

 

It should be noted that we do not make or allow to be made, recordings of any kind during a consultation with our GPs. 

If any such recording were made, we are committed to ensuring that any audio, visual or photographic recordings of a patient or relative of a patient, in which the person is identifiable, should only be made with express consent of that person. The recordings will be kept confidential as a part of the patient’s record. We will do all we can to protect confidentiality of the recording. We will get consent before sharing such videos, photos, or other images of a patient. 

We will only take images of patients on a GP’s personal mobile device when necessary for the patient’s care and with the express permission of the patient. 

Such images will not identify a patient and shall only be kept for the minimum time necessary.  

Medical certificates 

In general, work-related Medical Certificates from a GP will only provide a confirmation that a patient is unfit for work with an indication of when the patient will be fit to resume work. Where it is considered necessary to provide additional information, we will discuss that with the patient. However, Social Welfare Certificates of Incapacity for work must include the medical reason the patient is unfit to work 

Your right of access to your health information 

You have the right of access to all the personal information held about you by this practice. If you wish to see your records in most cases, it is the quickest to discuss this with your doctor who will outline the information in the record with you. You can make a formal written access request to the practice and the matter can be dealt with formally. 

Transferring to another practice 

If you decide at any time and for whatever reason to transfer to another practice we will facilitate that decision by making available to your new doctor a copy of your records on receipt of your signed consent from your new doctor. For medico-legal reasons we will also retain a copy of your records in this practice for an appropriate period which may exceed eight years. 

It is of the utmost importance that we protect both our vulnerable patients and our staff members who may be at higher risk from exposure to the Covid19 virus. 

It is the policy of Galway Bay Medical Centre that all patients and staff always wear a facemask, whether in consultation, in the waiting room or moving around the building. 

We encourage the use of hand-sanitising stations which are available throughout the building. 

Entry to the building will be refused to anyone who declines to wear a mask. You must wear a mask for the duration of your visit unless your GP asks you to remove it during your consult. 

If you have a letter of Medical Exemption, we ask that you notify us of this when booking your consultation so that we can carry out a risk assessment prior to your visit. This may mean that you will be asked to attend only at a specific time or that your GP will need to wear full PPE (Personal Protective Equipment) for your visit. 

In line with our Discrimination Policy, we strive to treat all patients fairly, regardless of disability, but we also maintain a duty of care to our staff and other patients. 

Sincerely 

GBMC