This accessibility statement applies to the website and/or domain associated with Bedford Hill Family Practice. Our website is hosted by Iatro and we work in conjunction with our host to enable as many people as possible to use our website. This means that users should be able to:

• Change colours, contrast levels and fonts
• Zoom in, by up to 300%, without the text splitting off the screen
• Navigate most of the website using only the keyboard
• Navigate most of the website using speech-recognition software
• Listen to most of the website using a screen reader (including but not limited to: JAWS, NVDA and VoiceOver)

In addition, we have made our website text as simple as possible to understand. If you need any further advice on making your device easier to use, particularly if you have a disability, click on the following link: AbilityNet

The accessibility of our website

We are aware that some parts of our website are not fully accessible and unfortunately this cannot be rectified. The issues on some areas are:

• The text will not reflow in a single column if you change the size of the browser window
• You are unable to modify the line height or the spacing of text
• Older versions of PDF documents are not fully accessible to screen-reader software
• Live video streams do not have captions
• Some (not all) online forms may prove difficult to navigate when using only a keyboard
• The main content page cannot be skipped when using a screen reader
• There are magnification limitations on the map (on our ‘contact us’ page)

Feedback and how to contact us

If you need information that is shown on our website in a different format, such as large print, easy read, audio recording, Braille or as a PDF, you can contact us by:

• Email: [email protected]
• Phone 020 8673 1720

Once we receive your request, we will get back to you as quickly as possible. Please note that if you are unable to view the map on our ‘contact us’ page, you are requested to call or email us using the details shown above for directions.

Reporting accessibility problems with this website

We are constantly looking to improve the accessibility of our website. Should you find any problems not listed on this page, or think we are not meeting the accessibility requirements, please contact the practice.

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you are not happy with the way in which we respond to your complaint, contact the Equality Advisory and Support Service (EASS).

Contacting us by phone or visiting us in person

Find out how to contact us on our ‘contact us’ page via this link [insert link]. Please be advised that we provide a text relay service for people who are D/deaf, hearing impaired or have a speech impediment. Our reception rooms has an audio induction loop, or if you contact us prior to your appointment we can arrange to have a British Sign Language (BSL) interpreter.

Technical information about this website’s accessibility

Bedford Hill Family Practice is committed to making its website accessible, in accordance with The Public Sector Bodies (Websites and Mobile Applications) (No.2) Accessibility Regulations 2018.

Compliance status

We are committed to making our website accessible, in accordance with The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

This website is fully compliant with the Web Content Accessibility Guidelines version 2.1 AA standard.

Examples of non-compliance include:

Some images do not have a text alternative, so people using a screen reader cannot access the information. This fails WCAG 2.1 success criterion 1.1.1 (non-text content). We plan to add alternative text for all images.

Disproportionate burden [amend as required]

Navigation and accessing information

• There is no way to skip the repeated content in the page header (for example, a ‘skip to main content’ option).
• It is not always possible to change the device orientation from horizontal to vertical without making it more difficult to view the content.
• It is not possible for users to change the text size without some of the content overlapping.
• Interactive tools and transactions
• Some of our interactive forms are difficult to navigate using a keyboard – e.g. because some form controls are missing a ‘label’ tag.
• Our forms are built and hosted through third-party software and ‘skinned’ to look like our website.

PDFs and other documents

Some of our PDFs and Word documents are essential to providing our services. For example, we have PDFs with information on how users can access our services, and forms published as Word documents. By September 2020, we plan to either fix these or replace them with accessible HTML pages.

The accessibility regulations do not require us to fix PDFs or other documents published before 23rd September 2018 if they are not essential to providing our services. For example, we do not plan to fix [provide example of non-essential document].

Any new PDFs or Word documents we publish will meet accessibility standards.

Live video

We do not plan to add captions to live video streams because live video is exempt from meeting the accessibility regulations.

Preparation of this accessibility statement

This statement was prepared on [date when it was first published]. It was last reviewed on [date when it was last reviewed].

This website was last tested on [date]. The test was carried out by [add name of organisation that carried out test, or indicate that you did your own testing, i.e. using the WAV (Web Accessibility Tool)].

We used this approach to decide on a sample of pages to test [add link to explanation of how you decided which pages to test, e.g. we tested our home page and a random sample of eight content pages from our site]

Bedford Hill Family Practice – Care Quality Commission (cqc.org.uk)

Tell us what you think

Have you got a Suggestion, Compliment or Complaint?

If you have a suggestion, compliment or complaint about the service you have received from the doctors or any of the personnel working in this practice, please let us know.

How To Make a Suggestion, Compliment or Complaint

Speak to someone here at the surgery, ask for the Complaints Manager or use the form below to submit your feedback to the practice.

How To Make a Complaint

• Step One
  Most complaints can be sorted out by talking the problem through with someone at the surgery. So if you wish to complain about the way you have been treated or about the advice or information we have given you, please speak to our Complaints Manager.
• Step Two
  If you prefer you to write in, use the form below. You will be sent a letter of acknowledgement and be contacted by the Complaints Manager to discuss the complaint. The matter will is investigated within an agreed timescale.
• Step Three
  If you want advice, or still feel that your complaint has not been resolved, you can talk to The Complaints Manager at NHS South West London ICB or contact the Health Service Ombudsman.
• NHS South West London Integrated Care Board Telephone: 0800 026 6082 E-mail: [email protected], NHS South West London ICB, 120 The Broadway London SW19 1RH
• The Health Service Ombudsman
  Millbank Tower,
  Millbank,
  London,
  SW1P 4QPTel: 0345 015 4033
  www.ombudsman.org.uk

Have You Got a Suggestion, Compliment or Complaint?

We want you to be satisfied with our services. We welcome suggestions or ideas to help us improve. You can use this space to let us know what you think, or to complain.

All GP practices are required to declare the mean earnings (eg average) for GPs working to deliver NHS services to patients at each practice.

The average pay for GPs working at Bedford Hill Family Practice in the last financial year before tax and national insurance is £72,500.

It should be noted that the prescribed method for calculating earnings is potentially misleading because it takes no account of how much time doctors spend working in the practice, and should not be used to form any judgement about GP earnings, nor to make any comparison with any other practice.

Register your Type 1 Opt-out preference

The data held in your GP medical records is shared with other healthcare professionals for the purposes of your individual care. It is also shared with other organisations to support health and care planning and research.

If you do not want your personally identifiable patient data to be shared outside of your GP practice for purposes except your own care, you can register an opt-out with your GP practice. This is known as a Type 1 Opt-out.

Type 1 Opt-outs may be discontinued in the future. If this happens then they may be turned into a National Data Opt-out. Your GP practice will tell you if this is going to happen and if you need to do anything. More information about the National Data Opt-out is here: https://www.nhs.uk/your-nhs-data-matters/

You can use this form to:

• register a Type 1 Opt-out, for yourself or for a dependent (if you are the parent or legal guardian of the patient) (to Opt-out)
• withdraw an existing Type 1 Opt-out, for yourself or a dependent (if you are the parent or legal guardian of the patient) if you have changed your preference (Opt-in)

This decision will not affect individual care and you can change your choice at any time, using this form. This form, once completed, should be sent to your GP practice by email or post.

Read/Download our Practice Booklet

• To provide the best possible quality service to our patients, within a confidential, safe and compassionate environment irrespective of gender, race, disability, age, sexual orientation, religion or belief and respect their human rights.
• To focus on prevention of disease by promoting health and wellbeing and offering care and advice to our patients.
• To show patients courtesy and respect and promote choice by involving patients in decisions about treatment and referral options and the right to express a preference for a particular doctor in the practice.
• We will provide the same standard of care irrespective of age, disability, ethnicity, gender, religion or sexual orientation.
• To encourage patients to get involved in the practice through an annual survey and encouragement to comment on the care they receive.
• To ensure that we have the right skill mix and training to carry out duties competently and to continually improve.
• To create a positive team spirit by encouraging open and honest communication and fostering employee interaction.

What we expect from our patients

• To treat the doctors and practice staff with courtesy.
• To be punctual for your appointment time.
• To give the practice as much notice as possible if you are unable to keep a booked appointment
• To make more than one appointment if more than one person needs to be seen.
• To be prepared to make further appointments if you have numerous or complicated problems.
• To be patient if appointment times are running late. It may be you who needs extra time on another occasion.
• To ask for a home visit only if the illness prevents you from attending the surgery. Children can usually be brought to the surgery.
• To contact the doctor out of surgery hours ONLY in the case of an emergency, which cannot wait until the next working day.

Above all else we do not accept violence or the threat of violence from patients – we try to provide a high standard of care and do not deserve to be threatened.

The Information We Hold On You

Our practice keeps data on you relating to who you are, where you live, contact details, what you do, your family, possibly your friends, your employers, your habits, your problems and diagnoses, the reasons you seek help, your appointments, if you have a carer, where you are seen and when you are seen, who by, referrals to specialists and other healthcare providers, tests carried out here and in other places, investigations and scans, treatments and outcomes of treatments, your treatment history, the observations and opinions of other healthcare workers, within and without the NHS as well as comments and aide memoires reasonably made by healthcare professionals in this practice who are appropriately involved in your health care.

When registering for NHS care, all patients who receive NHS care are registered on a national database, the database is held by NHS Digital, a national organisation which has legal responsibilities to collect NHS data.

Identifying patients who might be at risk of certain diseases

• Your medical records will be searched by a computer programme so that we can identify patients who might be at high risk from certain diseases such as heart disease or unplanned admissions to hospital.
• This means we can offer patients additional care or support as early as possible.
• This process will involve linking information from your GP record with information from other health or social care services you have used.
• Information which identifies you will only be seen by this practice.

If you would like more information, please speak with the Practice Manager.

Who we share information with

As GPs, we cannot handle all your information ourselves, so we need to delegate this responsibility to others within the practice and sometimes with other organisations.

If your care requires treatment outside the practice, we will exchange with those providing such care and treatment whatever information may be necessary to provide safe, high quality care.

Once you have seen the care provider, they will normally send us details of the care they have provided you with, so that we can understand your health better.

Your consent to this sharing of data, within the practice and with those others outside the practice is assumed and is allowed by the Law, however we will gladly discuss this with you in more detail if you would like to know more.

The Practice team (clinicians, administration and reception staff) only access the information they need to allow them to perform their function and fulfil their roles.

You have the right to object to our sharing your data in these circumstances but we have an overriding responsibility to do what is in your best interests.

For more information

If you wish to discuss these changes or have any concerns, please ask to speak with the Practice Manager in the first instance.

The law

We are required by Articles in the General Data Protection Regulations to provide you with the information in the following 9 subsections.

Data Controller: Bedford Hill Family Practice

Data Protection Officer: Dr Michael Calais

Purpose of Processing your personal information Direct Care is care delivered to the individual alone, most of which is provided in the surgery.After a patient agrees to a referral for direct care elsewhere, such as a referral to a specialist in a hospital, necessary and relevant information about the patient, their circumstances and their problem will need to be shared with the other healthcare workers, such as specialist, technicians, etc.The information that is shared is to enable the other healthcare workers to provide the most appropriate advice, investigations, treatments, therapies and or care.Your medical records will be searched by a computer programme so that we can identify patients who might be at high risk from certain diseases such as heart disease or unplanned admissions to hospital. This is called “risk stratification”. This means we can offer patients additional care or support as early as possible. This process will involve linking information from your GP record with information from other health or social care services you have used.

Lawful Basis for Processing your personal information The processing of personal data in the delivery of direct care and for providers’ administrative purposes in this surgery and in support of direct care elsewhere is supported under the following Article 6 and 9 conditions of the GDPR:Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest or in the exercise of official authority…’.Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”

Recipient or categories of recipients of your personal data The data will be shared with health and care professionals and support staff in this surgery and at hospitals, diagnostic and treatment centres who contribute to your personal care.In addition, personal data may be shared which is sent to or may be received from providers such as our 8to8 hubs (who provide some evening and weekend appointments on behalf of the practice), 111, out of hours services, local social services and care services, or other services the Wandsworth clinical commissioning group has commissioned. In all cases, we ensure the data is supplied is appropriate and within the law.

Your right to object You have the right to object to some or all the information being processed, which is detailed under Article 21. Please contact the Data Controller or the practice manager. You should be aware that this is a right to raise an objection; that is not the same as having an absolute right to have your wishes granted in every circumstance.

Your right to access and correction You have the right to access the data that is being shared and have any inaccuracies corrected. There is no right to have accurate medical records deleted except when ordered by a court of Law.

How long do we hold your personal data for? We retain your personal data in line with both national guidance and law.

Your right to complain Use of personal data is overseen by the Information Commissioners Office, often known as the ICO. You have to complain or raise concerns with the ICO and they can be contacted via their website: www.ico.org.uk or you can also call their helpline at  Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate).

Introduction

The practice has adopted a policy of zero tolerance in relation to violence and verbal abuse against staff

Everyone has a duty to behave in an acceptable and appropriate manner. Staff have a right to work, as patients have a right to be treated, free from fear of assault and abuse in an environment that properly safe and secure.

It is very difficult to provide a comprehensive description of all types of incidents that are covered under this policy, however, examples of the types of behaviour covered are summarised below:

• physical assault
• offensive language, verbal abuse and swearing which prevent staff from doing their job or makes them feel unsafe
• loud and intrusive conversation
• unwanted or abusive remarks
• negative, malicious or stereotypical comments
• invasion of personal space
• brandishing of objects or weapons
• near misses i.e. unsuccessful physical assaults
• offensive gestures
• threats or risk of serious injury to a member of staff, fellow patients or visitors
• bullying, victimisation or intimidation
• stalking
• spitting
• alcohol or drug fuelled abuse
• unreasonable behaviour and non-cooperation such as repeated disregard of surgery opening hours
• Any of the above linked to destruction of or damage to property

It is important to remember that such behaviour can be in person, by telephone, letter or e-mail or other form of communication such as graffiti on NHS property for example.

A range of measures can be taken by the surgery depending on the severity of the incident which may assist in the management of unacceptable behaviour by seeking to reduce the risks and demonstrate acceptable standards of behaviour, these may include:

• verbal warnings
• written warnings
• removal from practice list
• criminal prosecution

Reporting

All physical or non-physical assaults should be reported directly to the appropriate line manager, who will deal with the incident in the first instance. The line manager will inform the practice manager and the incident will be investigated fully. The clinical condition of the assailant will be considered as part of the decision-making process.

The following is a list of possible aggravating factors which should be considered when deciding to report an incident to the police. It is by no means exhaustive:

• the effect on the victim and / or others present
• the assailant’s behaviour is motivated by hostility towards a particular group or individual on the grounds of race, religious belief (or lack of), nationality, gender, sexual orientation, age, disability or political affiliation
• a weapon or object capable of being used as a weapon, is brandish or used to damage property
• the incident was an attempted, incomplete or unsuccessful physical assault
• the incident involves action by more than one assailant
• the incident is not the first to involve the same assailant
• there is an indication that a particular member of staff is being targeted
• there is serious concern that any threats made will be carried out
• there is concern that individual’s behaviour may deteriorate what that NHS organisations should be advised or alerted

Investigation

Following the abuse or assault on a member of staff, the incident must be reported appropriately. In appropriate cases the police must be contacted as soon as reasonably possible and full co-operation must be given to the police in any subsequent investigation

In all instances, regardless of whether or not the police decide to prosecute, the practice considers, in consultation with the relevant staff, what preventative action, if any, should be taken to reduce further or related incidents.

The details of the incident must be recorded on the incident form found on the intranet and passed to the Practice Manager.

The victim of the incident will be informed of the progress of any investigation and action taken and will be offered the full support of the surgery such as counselling or other appropriate support as necessary or desirable in the circumstances.

Thorough investigation will form the basis of any subsequent action. Investigation is essential in order to ensure that contributing factors are identified which will ensure that lessons are learned and vital information utilised for the purposes of preventative action. However, where appropriate, evidence gathered will also ensure that appropriate sanctions are sought.

It is important that each case is judged on its own merits. The sections below outline the options that can be taken in order to effectively tackle assaults, depending on the severity of the incident and aggravating factors.

Outcomes

Verbal Warnings

Verbal warnings are a method of addressing unacceptable behaviour with a view to achieving realistic and workable solutions.

They are not a method of appeasing difficult patients, relatives or visitors in an attempt to modify their behaviour or to punish them, but instead to determine the cause of the behaviour so that the problem can be addressed or the risk of it reoccurring minimised.

It is important that patients, relatives and visitors are dealt with in a demonstrable, fair and objective manner. However, whilst staff have a duty of care, this does not include accepting abusive behaviour. Every attempt should be made to de-escalate a situation that could potentially become abusive. Where de-escalation fails, the patients should be warned of the consequences of future unacceptable behaviour. The incident should also be recorded locally.

Where it is deemed appropriate to approach a patient, relative or visitor in respect of their behaviour, this should (where applicable) be done informally, privately and at a time when all parties involved are composed.

The aim of the verbal warning process is two fold:

• to ascertain the reason for the behaviour as a means of preventing further incidents in reducing the risk of reoccurring.
• to ensure that the patient, relative or visitor is aware of the consequences of further unacceptable behaviour.

A meeting should be arranged and conducted in a fair and objective manner. A formal record should be made and maintained, utilising the surgery’s incident reporting system.

Verbal warnings will not always be appropriate and should only be attempted when it is safe to do so with relevant and appropriate staff present.

Where the process has no effect and unacceptable behaviour continues, alternative action must be considered.

Patient Exclusion

Practices have the right to move from their list, with immediate effect, any patient who has been violent or threatened violence to the GP or member of staff where the incident has been reported to police.

In deciding whether or not to remove a patient from the practice list, GPs should use their clinical judgement to determine if the behaviour was a result of a clinical condition or treatment administered. GPs should exercise their judgement to ensure that the risks identified are balanced against the health care needs of the patient.

In exceptional circumstances it may be appropriate to exclude a patient where the behaviour of other members of the household is considered unacceptable. In such circumstances it may be appropriate for the GPs to terminate responsibility for the entire household.

Any decision to withhold treatment must immediately be notified to the PCT in order to ensure the continued provision of health care for that patient.

Employer’s Legal Responsibilities

Health and Safety at Work etc. Act 1974

Employers must:

• Protect the health and safety at work of their employees, and
• Protect the health and safety of others who might be affected by the practice work activities.

Management of Health and Safety at Work Regulations 1999

Employers must:

• assess all risks to the health and safety of their employees,
• implement the precautions identified in the risk assessment,
• make arrangements for the effective management of precautions,
• appoint competent people to advise them on health and safety,
• provide information and training to employees.
• co-operate and co-ordinate with other employers sharing the same place of work.

Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR)

Employers must:

• report all cases in which employees have suffered death or major injury or have been off work or incapacitated for more than three days or more following an assault which has resulted in an injury.

(Normally report completed by the Health & Safety Manager).

Safety Representatives and Safety Committees Regulations 1977, and Health and Safety (Consultation With Employees) Regulations 1996)

Employers must:

• consult with safety representatives and employees on health and safety matters.

The Employment Rights Act 1996

Provides employment protection in connection with health and safety.

Additionally, under the Management of Health and Safety at Work Regulations 1999, (Reg. 12) employees have a duty to report hazards and unsafe working conditions to their employer.