Wigmore Medical Training is currently unable to provide wheelchair access to the premises due to being located on the 2nd floor with no lift in the building.
For visually impaired patients, we offer the opportunity to have an escorted tour of the public areas of the facility to help to familiarise them with the layout of the building.
Please contact us for assistance on this matter.
We are committed to equality and diversity in accordance with the Equality Act 2010 and the Disability Discrimination Act 2005.
Wigmore Medical Ltd (hereafter ‘Wigmore Medical’) operates a CCTV surveillance system (“the system”) in the public areas of its premises at 23 Wigmore Street, London W1U 1PL, in the basement of the premises, and in the common staircases of 21 Wigmore Street and 2D Wimpole Street, with images being monitored and recorded centrally. The system is owned and managed by Wigmore Medical. The responsible manager is the Contracts Manager.
Wigmore Medical’s registered purpose for processing personal data through use of the system is crime prevention, health and safety, and/or staff monitoring, under our legitimate interests. This is further defined as: CCTV is used for maintaining public safety, the security of property and premises and for preventing and investigating crime, it may also be used to monitor staff when carrying out work duties. For these reasons the information processed may include visual images, personal appearance and behaviours. This information may be about staff, customers and clients, offenders and suspected offenders, members of the public and those inside, entering or in the immediate vicinity of the area under surveillance. Where necessary or required this information is shared with the data subjects themselves, employees and agents, services providers, police forces, court or tribunal, security organisations and persons making an enquiry.
The operators of the system recognise the effect of such systems on the individual and the right to privacy. Full details of Wigmore Medical’s data protection registration are available on the Information Commissioner’s Office website.
The system is intended to produce images as clear as possible and appropriate for the purposes stated. The system is operated to provide when required, information and images of evidential value.
Cameras are located at strategic points throughout the public area of Wigmore Medical and the common staircases, and signage is prominently placed at strategic points on the estate to inform staff, visitors and members of the public that a CCTV installation is in use.
Images captured by the system are recorded continuously and may be monitored by Wigmore Medical. Images displayed on monitors are not visible from public areas. All staff with view of the monitors are made aware of the sensitivity of watching the live feed. The Contracts Manager is the only member of staff that is able to review the recordings and give access to the recordings to any third party. The Contracts Manager is aware of the sensitivity of such images and recordings.
The images captured by the CCTV system will be retained for a maximum of 30 days, except where the image identifies an issue and is retained specifically in the context of an investigation / prosecution of that issue. No more images and information shall be stored than is required for the stated purpose. Images will be deleted once their purpose has been discharged or in the event of a prosecution, as long as is lawfully required, which may be up to six years.
Access to recorded images (as opposed to the live feed) is restricted to those who need to have access in accordance with this policy, the SOPs and any governing legislation.
Disclosure of recorded material will only be made to third parties in accordance with the purposes of the system and in compliance with the Data Protection Act. Anyone who believes that they have been filmed by the system can request a copy of the recording, subject to any restrictions covered by the Data Protection Act (“Subject access request”). Provided always that such an image/recording exists i.e. has not been deleted and provided also that an exemption/prohibition does not apply to the release. Where the image/recording identifies another individual, those images may only be released where they can be redacted/anonymised so that the other person is not identified or identifiable. Procedures are in place to ensure all such access requests are dealt with effectively and within the law. Access requests should be addressed to Contracts Manager Wigmore Medical,23 Wigmore Street, London W1U 1PL. Wigmore Medical will respond within one month.
A person should provide all the necessary information to assist Wigmore Medical in locating the CCTV recorded data, such as the date, time and location of the recording. If the image is of such poor quality as not to clearly identify an individual, that image may not be considered to be personal data and may not be handed over by Wigmore Medical.
Members of the public should address any concerns or complaints over use of the Wigmore Medical’s CCTV system to DPO@wigmoremedical.com
This policy was approved by the management board of Wigmore Medical on 25 May 2018. It will be reviewed annually to ensure that the purpose still applies.
This policy was reviewed on 13 January 2023.
Wigmore Medical is committed to providing a safe, comfortable environment where service users, including patients (treatment models) and staff, can be confident that best practice is being followed at all times and the safety of everyone is of paramount importance.
All treatment models are entitled to have a chaperone present for any consultation, examination or procedure where they feel one is required. The chaperone may be a family member or friend. On occasions, they may prefer a formal chaperone to be present, i.e. a member of staff.
Wherever possible we would ask for this request to be made at the time of being booked in so that arrangements can be made and there are no delays on the day. Where this is not possible we will endeavour to provide a formal chaperone at the time of request. However occasionally it may be necessary to reschedule to another training session opportunity.
A doctor, nurse or other healthcare professional may also require a chaperone to be present for certain consultations.
This policy outlines procedures and responsibilities within Wigmore Medical Limited ("the Organisation ") for handling any concerns, issues or complaints that may arise.
The purpose of this policy is to ensure that any complaints or concerns by service users (trainers, delegates, training companies and treatment models) are correctly managed.
Wigmore Medical Limited, although an independent body, aspires to meet the principles set out in the NHS Constitution which are:
This policy serves to indicate how issues concerning service user concerns or complaints should be managed within the organisation.
The CQC Registered Manager holds overall responsibility for ensuring the development, implementation and operation of this policy regarding complaints. This may include appointment of a designated Complaints Manager.
The CQC Registered Manager will also lead and oversee the process of the implementation of this policy, as well as monitoring its compliance and effectiveness.
The designated Manager will be:
Everyone, from training delegates to training models and the trainers themselves, have the right to expect a positive experience and a good treatment outcome. In the event of concern or complaint, service users have a right to be listened to and to be treated with respect.
As an authorised provider, Wigmore Medical Limited will manage complaints properly so user concerns are dealt with appropriately. Good complaint handling matters because it is an important way of ensuring our users receive the service they are entitled to expect.
Complaints are also a valuable source of feedback; they provide an audit trail and can be an early warning of failures in service delivery. When handled well, complaints provide an opportunity to improve service and reputation.Our Aims & Objectives
Wigmore Training Complaints Flow Chart
Complaints regarding Wigmore’s training services 🡪 Registered Manager or other authorised person to respond 🡪 If cannot be resolved at point of service, complaint to be logged and relevant staff notified 🡪 Customer to be informed how complaint will be resolved, whether it be by improving services for future training and/or offering a refund or discounted training if deemed necessary.
Complaints regarding Wigmore’s staff 🡪 Registered Manager or other authorised person to respond 🡪 If cannot be resolved at point of service, complaint to be logged and relevant staff notified 🡪 Head of HR notified 🡪 Customer to be informed how the complaint will be resolved, whether it be by having a disciplinary investigation and/or offering a refund or discounted training if deemed necessary.
Complaints regarding the trainer 🡪 Registered Manager or other authorised person to respond 🡪 If cannot be resolved at point of service, complaint to be logged and relevant trainer notified 🡪 Customer to be informed how the complaint will be resolved, whether it be by having a review with the trainer and/or offering a refund or discounted training if deemed necessary.
Complaints regarding treatment outcomes 🡪 If complaint is medical/clinical in nature (e.g. treatment model complaining about adverse reaction or complication), Registered Manager or other authorised person to pass necessary details onto the trainer who will respond to the customer directly with medical advice.
Minor training complaints 🡪 If a complaint is minor in nature (e.g. the room is too cold or the water dispenser has run out), any staff member on hand will apologise and resolve immediately, and there will be no need to log the complaint.
If a delegate, treatment model or trainer is not satisfied with the resolution of their complaint against Wigmore Medical, they can direct their complaint to:
CQC Care Quality Commission
Newcastle upon Tyne
Tyne and Wear
0300 061 6161
If a treatment model is not satisfied with the trainer’s handling of any adverse reactions or complications, then the complaint can be escalated to an independent organisation (see below). If a claim is made, this would go on the doctor's medical indemnity insurance.
General Medical Council
350 Euston Rd,
London NW1 3JN
0161 923 6602
Independent Healthcare Sector
Complaints Adjudication Service
70 Fleet Street
London EC4Y 1EU
020 7536 6091
The process of resolving the problem will include:
Our staff will consult with their manager if addressing the problem is beyond their responsibilities.
Complaints that are not resolved at the point of service, or that are received in writing and require follow up, are regarded as formal complaints.
If the complaint is not resolved at the point of service, staff are expected to provide the complainant with the formal complaints policy.
Our designated complaints manager coordinates resolution of formal complaints in close liaison with the staff who are directly involved.
All staff will be appropriately trained to manage complaints competently.
Regular reviews are conducted by the complaints manager to check understanding of the complaints process among our staff.
Information is provided about the complaints policy in a variety of ways, including some or all of the following:
After receiving a formal complaint, our CQC Registered Manager or designated complaints manager reviews the issues in consultation with relevant staff in order to decide what action should be taken, consistent with the risk management procedure.
Formal complaints are normally resolved by direct negotiation with the complainant, but some complaints are better resolved with the assistance of an alternative disputes resolution provider.
The complaints manager will signpost the complainant to an appropriate external body if:
The complaints manager carries out investigations of complaints to identify what happened, the underlying causes of the complaint and preventative strategies.
Information is gathered from:
Where an individual staff member, trainer, delegate or even treatment model has been mentioned specifically by a complainant, the matter will be investigated by the relevant manager or supervisor, who will:
If the complaint is directed at a staff member, this will be dealt with internally by Wigmore’s HR department and the staff member will be asked to provide a factual report of the incident, identify systems issues that may have contributed to the incident and suggest possible preventive measures.
Where the investigation of a complaint results in findings and recommendations about individual staff members, the issues are addressed through the Disciplinary or other appropriate process.
If the complaint is directed at one of the trainers, the training manager will inform the relevant trainer and request a factual report of the incident, which will be logged and recorded. A review of their training contract will be carried out if necessary, and the service user will be offered a refund or discount if deemed suitable.
If a patient is not satisfied with the trainer’s handling of any adverse reactions or complications, then the complaint can be escalated to an independent organisation. If a claim is made, this would go on the doctor's medical indemnity insurance.
The complaints manager prepares regular reports on the number and type of complaints, the outcomes of complaints, recommendations for change and any subsequent action that has been taken. The reports are provided to staff and senior management, and if appropriate, uploaded into a personal portfolio for audit and appraisal.
The complaints manager periodically prepares case studies using anonymised individual complaints to demonstrate how complaints are resolved and followed up, for the information of staff, and for use in audit and appraisal.
Information about trends in complaints and how individual complaints are resolved is routinely discussed at staff meetings and clinical review meetings as part of reflecting on the performance of the service and opportunities for improvement.
Complaints reports are considered and discussed at monthly clinical review meetings and directors’ meetings.
An annual quality improvement report is published that includes information on:
The complaints/registered manager continuously monitors the amount of time taken to resolve complaints, whether recommended changes have been acted on and whether satisfactory outcomes have been achieved.
The complaints manager annually reviews the complaints management system to evaluate if the complaints policy is being complied with and how it measures up against best practice guidelines. As part of the evaluation, users and staff will be asked to comment on their awareness of the policy and how well it works in practice.
The training facility is committed to complying with the requirements of the legislation governing patient confidentiality including: Caldicott Guidelines 1997, Confidentiality Code of Practice 1998, Data Protection Act 2018, GDPR and the current GMC Standards.
For the purpose of this policy, confidential information is defined as all the information that is learnt in a professional role including personal details, medical history, what treatment a patient is having and how much it costs. The definition of personal details includes, but is not limited by, such details as name, age, address, personal circumstances, race, health, sex and sexual orientation, etc. Note that even the fact that a patient attends the Training facility is confidential. Confidential information may be supplied or stored on any medium including images, videos, health records, and computer records or may be transmitted verbally.
All staff members must be aware of their responsibilities for safeguarding patient confidentiality and keeping information secure and must have received appropriate training on the legislation requirements and the current GMC/GDC Standards to ensure that:
In order to make a referral to the patient’s GP or third party, the patient is advised to share their information as it will be in their best interest. The details of the discussion will be fully documented in the training patient record.
A patient’s information will only be released without their prior permission in the following exceptional circumstances:
The training facility treats breaches of confidentiality very seriously. No team member shall knowingly misuse any confidential information or allow others to do so. Failure to comply with this policy may result in disciplinary action.
This policy should be read in conjunction with the Data Protection and Information Security policy and the Information Governance Procedures.
The facility follows the GMC guidelines: ‘Consent: patients and doctors making decisions together’. We treat patients politely and with respect, in recognition of their dignity and rights as individuals. We also recognise and promote our patients’ responsibility for making decisions about their bodies, their priorities and their care and make sure we do not take any steps without a patient’s consent (permission).
The clinical trainer will always obtain valid consent before starting treatment because patients have a right to choose whether or not to accept advice or treatment. All clinical trainers are adequately trained to ensure that the patient has:
Everyone aged 16 or over is presumed to have capacity to make their own decisions unless it can be shown that they lack capacity to make a particular decision at the time it needs to be made. If the treating clinician thinks that someone lacks capacity to make a treatment decision, s/he will carry out a mental capacity assessment and, if appropriate, make a decision in the person’s best interests. We have a Mental Capacity Assessment to provide a record of how a treatment decision was reached.
Training on consent is provided to staff members at team meetings. Consent procedures are reviewed and monitored annually.
The Lead for Cross Infection Control at Wigmore Training is Varag Atanosian. He is responsible for the overseeing of infection control procedures within the training facility, ensuring all staff are complying, where necessary, with national guidelines: HTM 01-01 and HTM 07-01.
Infection Control is of prime importance in this facility. It is essential for the safety of our service users, trainers, staff and visitors. We adopt a universally safe technique for all of our service users. Every member of the clinical team are trained in all aspects of infection control and the following must be adhered to at all times:
This document reflects upon the government guidance published on 17 September 2021 regarding Working Safely during Covid-19, particularly the Shop and Branches guidance, and offices, factories and labs.
Covid-19 is spread through close contact with an infected person. When someone with Covid-19 breathes, speaks, coughs or sneezes, they release particles (droplets and aerosols) containing the virus that causes Covid-19. The particles can be breathed in by another person. Surfaces and belongings can also be contaminated with Covid-19 when people who are infected cough or sneeze near them of if they touch them.
Government guidance to reduce the spread of Covid-19 is through ventilation, hand hygiene, cough hygiene (catch it, bin it, kill it), general cleaning, self-isolation if you test positive for Covid-19, have Covid-19 symptoms, have been told to isolate by NHS Test and Trace, if a member of your household/close contact has Covid-19 unless you are exempt (fully vaccinated or under 18 years and 6 months old). Symptoms of Covid-19 include a temperature of over 37.8C, persistent cough, loss of smell or taste. A large group of people are asymptomatic, so will not display any symptoms.
If you test positive for Covid-19, you must self-isolate for ten days.
We will not be able to train delegates/ work with trainers who:
Similarly, models will not be able to attend training where they are:
Models will not be allowed to bring other people with them to the training room and are discouraged from bringing children with them.
Attending a training course
Trainers and staff are tested frequently, and delegates and treatment models are required to get tested within 48 hours prior to the training session. Lateral flow tests may be available from Wigmore on arrival, but this depends on availability. If a delegate or model tests positive, they will not be allowed to continue the training and will be offered a new course date. If negative, they will be allowed to enter the training and will be directed to wash their hands.
All trainers and delegates must wear a facemask at all times during the training course. Masks can be purchased from Wigmore Medical. Exceptions will be made for those who are exempt due to health reasons. When using a facemask the following protocols should be followed:
We keep a limited record of staff, trainers, delegates and models who come into our training room for the purpose of contact tracing. By maintaining such records, we can help to identify people who may have been exposed to the coronavirus.
To facilitate this, attendees can ‘check-in’ by scanning the NHS QR code displayed on the door as you enter the training facility on the second floor of 21 Wigmore Street.
Throughout the training session, attendees are requested to be mindful and respectful of others and remember to:
The premises are cleaned daily.
As we have been operational from the beginning of lockdown due to running essential services, the AC systems have been in operation, as well as water usage.
Close contact training
When taking part in hands-on training, all delegates and the trainer must wear masks and gloves. Those who are watching the demonstration should aim to stand at least 6ft away from the model and trainer.
Models must also wear facemasks during a procedure unless the mask will obscure the area being treated.
The trainer / delegate should ensure that close proximity to the models should be limited to how long is necessary to finish the treatment.
2 November 2021
To be reviewed on a quarterly basis
This Training facility is committed to complying with the Data Protection Act 2018, the General Data Protection Regulation (GDPR), GMC, and other data protection requirements relating to our work. We only keep relevant information about employees for the purposes of employment and about patients to provide them with safe and appropriate health care. This policy should be read in conjunction with other related policies and procedures at the end of this policy. All data protection and information security policies, procedures and risk assessments are reviewed annually.
The Information Governance Lead for the facility is Emily Grosso.
Our lawful bases for processing personal data are listed in our Privacy Notice on the website.
The facility offers individuals real choice and control. Our consent procedures put individuals in charge to build patient trust and engagement. Our consent for marketing requires a positive opt-in, we don’t use pre-ticked boxes or any other method of default consent. We make it easy for people to withdraw consent and keep contemporaneous evidence of consent. Consent to marketing is never a precondition of a service.
Delegates booking on to courses/webinars and treatment models asking to be put on Wigmore Medical Training’s model database are considered soft opt-ins and will only be contacted regarding similar opportunities that might be of interest. Both delegates or models can request to be removed from these lists at any time.
Data protection officer (DPO)
Our DPO is Arda Eghiayan
Pseudonymisation means transforming personal data so that it cannot be attributed to an individual unless there is additional information.
Examples of pseudonymisation we use are:
We report certain types of personal data breaches to the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. If the breach results in a high risk of adversely affecting individuals’ rights and freedoms we also inform those individuals without undue delay. We keep contemporaneous records of any personal data breaches, whether or not we need to notify. For our data breach notification procedures see Information Governance Procedures.
Right to be informed
We provide ‘fair processing information’, through our Privacy Notice, which provides transparency about how we use personal data. These are available on our website and from the facility.
Your data rights
Right of Access
Individuals have the right to access their personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing. If an individual contacts the facility to access their data they will be provided with, as requested:
Right to erasure
The right to erasure is also known as ‘the right to be forgotten’. The facility will delete personal data on request of an individual where there is no compelling reason for its continued . The right to erasure applies to individuals who are not patients at the facility. If the individual is or has been a patient, the clinical records will be retained according to the retention periods in the Record Retention Policy and after the periods stated can be deleted upon request.
Right of rectification
Individuals have the right to have personal data rectified if it is inaccurate or incomplete.
Right to restriction
Individuals have a right to ‘block’ or suppress the processing of their personal data. If requested we will store their personal data, but stop processing it. We will retain just enough information about the individual to ensure that the restriction is respected in the future.
Right to object
Individuals have the right to object to direct marketing and processing for purposes of scientific research and statistics.
An individual can request the facility to transfer their data in electronic or other format.
Privacy by design
We implement technical and organisational measures to integrate data protection into our processing activities. Our data protection and information governance management systems and procedures take Privacy by design as their core attribute to promote privacy and data compliance.
We keep records of processing activities for future reference.
Information Governance Procedures includes the following information security procedures:
This policy and the data protection and information governance procedures it relates to are reviewed annually.
Information Commissioner www.ico.org.uk
EU – US Privacy Shield www.privacyshield.gov
Data: means information in a form in which it can be processed (automatically)
Personal data: means data relating to a living individual who can be identified either from the data, or from the data in conjunction with other information in the possession of the data controller
Data controller: is a person who, either alone or with others, controls the contents and use of personal data
Data processor: is a person who processes personal data on behalf of a data controller, but does not include an employee of a data controller who processes such data in the course of his/her employment
Data subject: the individual person who is the subject of any relevant persona data (information)
A personal data-filing system: any structured set of personal data accessible according to specific criteria whether centralised, decentralised or dispersed on a functional or geographical basis
Third party: someone other than the data subject, controller, processor and persons with authority of the controller or processor to process the data
Recipient: is the person to whom data is disclosed. This would include employees. The data subject has to be informed of the recipients of the data.
It is the aim of the facility to comply with the duty of candour requirements from the GMC/GDC/NMC and the CQC Regulation 20. The registered manager, Varag Atanosian, is responsible for the policy. The whole training team is open and honest with people who use services when things go wrong with their care and treatment.
This facility aims to be a supportive, caring and inclusive environment for patients to receive treatment and for staff to reach their full potential. We are committed to working towards equality and to creating a culture where the diversity and dignity of patients and staff are respected and valued by all.
This facility will ensure that all patients and staff, both actual and potential, are treated fairly and respectfully and not discriminated against regardless of age, colour, disability, ethnic or national origin, gender, marital or civil partnership status, pregnancy or maternity, race, religion or belief, or sexual orientation. These are known as ‘protected characteristics’ under the Equality Act 2010.
The rights of our patients and our staff with regards to discrimination are protected by a range of legislation including:
This facility also aims to meet the current General Medical Council as well as the Nursing and Midwifery Council standards by positively promoting equality, dignity and human rights for patients and staff.
This facility and its staff aim to:
For team members
Wigmore Medical will:
Feedback and complaints
This facility welcomes and values any feedback and views feedback/complaints as potential opportunities to learn lessons and improve the service. Any service user or member of staff has the right to complain if they feel they have been:
For staff – the matter may be dealt with using the appropriate grievance procedure.
For patients – the complaint will be investigated, promptly and efficiently, in a full and fair way, and a full, constructive and prompt reply will be given.
Monitoring and review
This policy will be reviewed annually. The annual review will consider and incorporate, where appropriate:
A plan for implementing any changes will be developed in consultation with staff. The Registered Manager [Varag Atanosian ] together with the head of HR [Arda Eghiayan] has overall responsibility for the effective operation of this policy, the responsibility for communicating this policy to the team and for investigating any concerns or complaints under this policy.
We are committed to safeguarding children and adults at risk, complying with The Health and Social Care Act 2012 (and The Care Act 2014). Our team accepts and recognises our responsibilities to develop an awareness of the issues which may cause children and adults at risk harm.
We endeavour to safeguard children and adults at risk by:
This policy is underpinned by the following principles:
Other training facility policies relevant to this safeguarding policy include:
Within our training facility is our safeguarding lead, Arabella Tanyel, who is responsible for ensuring our procedures for safeguarding children and adults are kept up to date and is our point of contact for raising concerns.
We are committed to reviewing our policy and good practice standards at regular intervals.
Service Users should be kept safe from harm and danger. All members of the team should know what to do to keep patients safe and what action to take if they think that someone is being harmed.
Signs of abuse
Members of the clinical training team may observe the signs of abuse or neglect or hear something that causes them concern about a child or an adult at risk. They are not responsible for making a diagnosis of child abuse or neglect, just for sharing concerns appropriately. Each team member should be aware of the local procedures for child protection.
Abuse or neglect may present to the clinical trainers in a number of different ways:
If abuse or neglect is suspected
It is uncommon for doctors/practitioners to see patients with signs of abuse but where you have concerns about a patient who may have been abused and there is no satisfactory explanation, prompt action is important.
Where there is serious physical injury arising from suspected abuse:
Records of the incident should be maintained and be restricted to:
1 - England, Wales, Northern Ireland and Scotland have their own guidance on keeping children safe, but all agree that a child is anyone who has not yet reached their 18th birthday.
2 - Definitions of an adult at risk vary, but this definition is consistent with most definitions used by health organisations.