Wigmore Medical Ltd CCTV policy

• Ownership

  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.

• Compliance

  Images obtained from the system which include recognisable individuals constitute personal data and are covered by the Data Protection Act 2018. This Policy should therefore be read in conjunction with Wigmore Medical’s Privacy Policy. Wigmore Medical is the registered data controller under the terms of the Act. This policy has been drawn up in accordance with the advisory guidance contained within the Information Commissioner’s CCTV Code of Practice and the Home Office Surveillance Camera Code of Practice.

• Purpose

  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.

• Description

  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.

• Operation

  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.

• Information retention

  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

  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.

• Feedback

  Members of the public should address any concerns or complaints over use of the Wigmore Medical’s CCTV system to DPO@wigmoremedical.com

• Annual review

  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.

Chaperone Policy

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.

Complaints Policy

1. INTRODUCTION

   This policy outlines procedures and responsibilities within Wigmore Medical Limited ("the Organisation ") for handling any concerns, issues or complaints that may arise.

2. RELEVANT CQC FUNDAMENTAL STANDARD/H+SC ACT REGULATION (2014)

3. PURPOSE AND OBJECTIVES

   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:

   • The right to have any complaint made about our services dealt with efficiently and to have it properly investigated.
   • The right to know the outcome of any investigation into a complaint.
   • The right to take a complaint to independent review if the complainant is not satisfied with the way their complaint has been dealt with by us
   • The commitment to ensure service users are treated with courtesy and receive appropriate support throughout the handling of a complaint; and the fact that they have complained will not adversely affect their future treatment.
   • When mistakes happen they shall be acknowledged; an apology made; an explanation given of what went wrong; and the problem rectified quickly and effectively.
   • Demonstrating a commitment to ensure that the organisation learns lessons from complaints and claims and uses these to improve our services.

   This policy serves to indicate how issues concerning service user concerns or complaints should be managed within the organisation.

4. DUTIES AND RESPONSIBILITIES

   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:

   • Responsible for managing the procedures for handling and considering complaints.
   • Ensuring that replies are drafted and signed by the CQC Registered Manager or other authorised person
   • Responsible for ensuring that action is taken if necessary in the light of the outcome of a complaint or investigation.
   • Responsible for the effective management of the complaints procedure

5. POLICY STATEMENT

   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
   • We aim to provide a service that meets the needs of our service users and we strive for a high standard of care;
   • We welcome suggestions from service users and from our staff about the safety and quality of service, treatment and care we provide;
   • We are committed to an effective and fair complaints system; and
   • We support a culture of openness and willingness to learn from incidents, including complaints.

6. OUR COMPLAINTS PRINCIPLES

   • All service users are encouraged to provide suggestions, compliments, concerns and complaints and we offer a range of ways to do it.
   • All complainants are treated with respect, sensitivity and confidentiality.
   • All complaints are handled without prejudice or assumptions about how minor or serious they are. The emphasis is on resolving the problem.
   • Service users and staff can make complaints on a confidential basis or anonymously if they wish, and be assured that their identity will be protected.
   • Service users will not be discriminated against or suffer any unjust adverse consequences as a result of making a complaint about standards of care and service.
   • Formal responses sent will include a right to appeal - i.e. to the Independent Sector Complaints Adjudication
   • Service or Healthcare Advisory Services (IHAS) if the complainant remains unsatisfied.

7. MANAGING COMPLAINTS

   • All staff are expected to encourage service users to provide feedback about the service, including complaints, concerns, suggestions and compliments.
   • Staff are expected to attempt resolution of complaints and concerns at the point of service, wherever possible and within the scope of their role and responsibility.

   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.

   Unsatisfactory Resolution

   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
   Citygate
   Gallowgate,
   Newcastle upon Tyne
   Tyne and Wear
   NE1 4PA
   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
   info@iscas.org.uk
   020 7536 6091

8. RESOLUTION

   The process of resolving the problem will include:

   • an expression of regret to the user for any harm or distress suffered;
   • an explanation or information about what is known, without speculating or blaming others; considering the problem and the outcome the user is seeking and proposing a solution (i.e. staff/trainer/service review and/or refund or training discount if deemed necessary); and confirming that the service user is satisfied with the proposed solution.

   Our staff will consult with their manager if addressing the problem is beyond their responsibilities.

9. IF THE COMPLAINT IS NOT RESOLVED

   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.

10. STAFF TRAINING

    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.

11. PROMOTING FEEDBACK

    Information is provided about the complaints policy in a variety of ways, including some or all of the following:

    • Via email;
    • Wigmore Training Policies;
    • Wigmore Training Terms & Conditions;
    • Training Online feedback form;
    • Publicity about the service;
    • Staff inviting feedback and comments

12. RISK ASSESSMENT

    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.

13. ASSESSING RESOLUTION OPTIONS

14. 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 complaint raises complex issues that require external expertise.
    • The complaint cannot be resolved internally to the service user’s satisfaction.

15. TIMEFRAMES

16. TIMEFRAMES

    • Formal complaints are acknowledged in writing or in person within 48 hours.
    • The acknowledgment provides contact details for the person who is handling the complaint, how the complaint will be dealt with and how long it is expected to take.
    • If a complaint raises issues that require notification or consultation with an external body, the notification or consultation will occur within three days of those issues being identified.
    • Formal complaints are investigated and resolved within 28 days
    • If the complaint is not resolved within that time period, the complainant will be provided with an update.

17. RECORDS AND PRIVACY

    • The complaints manager maintains a complaints register.
    • Personal information in individual complaints is kept confidential and is only made available to those who need it to deal with the complaint.
    • Complainants are given notice about how their personal information is likely to be used during the investigation of a complaint.
    • Individual complaints files are kept in a restricted access section of the computer system’s file server.
    • Service users are provided with access to their medical records in accordance with our Subject Access policy. Others requesting access to a service users’ medical records as part of resolving a complaint are provided with access only if the service user has provided authorisation in accordance with the Subject Access policy.

18. OPEN DISCLOSURE AND FAIRNESS

    • Complainants are initially provided with an explanation of what happened, based on the known facts.
    • At the conclusion of an inquiry or investigation, the complainant and relevant staff are provided with all established facts, the causal factors contributing to the incident and any recommendations to improve the service, and the reasons for these decisions.

19. OPEN DISCLOSURE AND FAIRNESS

    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:

    • Talking to staff directly involved;
    • Listening to the complainant’s views;
    • Reviewing medical records and other records; and
    • Reviewing relevant policies, standards or guidelines.

20. COMPLAINTS ABOUT INDIVIDUALS

    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:

    • Inform the individual of the complaint made against them;
    • Ensure that if possible the individual does not have any contact with the complainant during the investigation period, or afterwards if deemed appropriate;
    • Ensure fairness and confidentiality is maintained during the investigation; and
    • Encourage the individual to seek advice from a professional body/association.

    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.

21. REPORTING AND RECORDING COMPLAINTS

    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 number and main types of complaints received, common outcomes and how complaints have resulted in changes;
    • How complaints were managed—how the complaints system was promoted, how long it took to resolve complaints (and whether this is consistent with the policy) and whether complainants and staff were satisfied with the process and outcomes;
    • The results of any service user satisfaction survey.
    • The service promotes changes it has made as a result of service user complaints and suggestions in its general publicity.

22. MONITORING AND EVALUATION

    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.

Confidentiality Policy

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:

• No personal information given or received in confidence is passed on to anyone else without the patient's prior consent. To obtain consent a patient is advised what information will be released and why and the likely consequences of the information release. The patient is given an opportunity to withhold their permission to share information, unless exceptional circumstances apply, and note is made on their consent form of whether or not they gave their permission.
• If a patient consents to sharing information about them the team member will ensure that all recipients of the information understand that it is confidential. When referring to medical colleagues we expect them to have the same high standards.
• If a patient’s information or images are used for research or marketing the team member will advise the patient how these will be used, check that the patient understands what s/he is agreeing to, obtain and record the patient’s consent to their use and only release the minimum information for the purpose. The patient will be advised that s/he can withdraw permission at any time
• If it is not necessary for a patient to be identified, they will remain anonymous in any information released
• The duty to keep information confidential also covers originals and copies of a patient's photographs, videos or audio recordings, including those made on a mobile phone. No images or recordings will be made without the patient's permission
• Patient information is kept confidential even after death

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:

• It is in the best interests of the public or the patient and the information released could be important in preventing or detecting a serious crime
• If a team member has information that a patient could be at risk of significant harm or may be a victim of abuse, in which case the appropriate care agencies or the police will be informed
• If a team member is required to disclose information by a court or a court order, in which case only the minimum amount of information necessary to comply will be released

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.

Consent Policy

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:

• Once the consent has been given it may be withdrawn at any time
• Giving and getting consent is a process, not a one-off event. It is an ongoing discussion between the clinician and the patient
• It is necessary to find out what the patient wants to know, as well as saying what the clinician thinks the patient needs to know. Examples of information which patients may want to know include: the risks and benefits of the proposed treatment and whether or not the treatment is considered appropriate

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.

Cross Infection Control Policy Statement

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:

• All of our clinical staff have been immunised against Hepatitis B and TB, or have completed a Non-Immunised Risk Assessment
• Our facility provides protective disposable clothing, gloves, (eyewear) and masks which must be worn by clinicians, technicians and nurses during all surgical procedures
• The team follow checklists to ensure the smooth day to day running of the facility
• Treatment models are provided with the correct PPE for procedures including drapes, surgical gowns, eye protection etc for all surgical procedures
• Before donning gloves, hands should be washed at the beginning of each session. A new pair of gloves must be worn for each patient and hands should be cleaned with an alcohol based rub between patients
• All our instruments are single use and are disposed of after each use.
• The sharps box must be out of reach of children. The containers are never filled beyond the indicator mark
• In the event of a sharps injury allow the wound to bleed and run directly under running water for a few minutes, dress the wound and contact A&E if the wounds needs attention, else if it’s a minor needle prick, then the treatment model/training delegate/staff member will be referred to a walk in clinic which will be arranged by the Doctor on site.
• Report the incident to the Registered Manager (Varag Atanosian) or Training Manager (Arabella Tanyel) and enter the incident in the accident book
• Checklists - and spot checks - are carried out by our training staff to ensure full compliance with current guidelines

Wigmore Medical Covid-19 Policy for Training

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

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.

• Before Attending Training courses (trainers, delegates, models)

We will not be able to train delegates/ work with trainers who:

• Are symptomatic of COVID-19 (or any other infectious disease)
• Have had contact with someone who is symptomatic or is a confirmed case and is not vaccinated
• Work in the NHS on COVID-19 positive wards

Similarly, models will not be able to attend training where they are:

• Are symptomatic of COVID-19 (or any other infectious disease)
• Have had contact with someone who is symptomatic or is a confirmed case and is not vaccinated

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:

• Wash your hands thoroughly with soap and water for 20 seconds or use hand sanitiser before putting a facemask on, and before and after removing it
• When wearing a facemask, avoid touching your face or facemask (you could contaminate them with germs from your hands)
• change your facemask if it becomes damp or if you’ve touched it
• continue to wash your hands regularly

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:

• Always wear a mask or face covering
• Frequently wash and sanitise hands
• Adhere to social distancing whenever possible
• Keep the windows open or air conditioning on
• Safely dispose of clinical waste and needles
• Wipe down any high touch surfaces
• Clear up any spills immediately
• Remove any tripping hazards
• Avoid blocking the exits
• Avoid touching your face
• When coughing or sneezing, it is encouraged to do so into your sleeve or elbow. If you use a tissue, discard it properly and clean/sanitise your hands immediately.

Social distancing

• Signage reminding delegates to distance.
• Reduced number of delegates and models.
• Frequent hand washing and surface cleaning. All Trainers / Room Hosts have to sign that they have cleaned key points such as taps, switches, and door handles. There is updated signage throughout the building reminding attendees to wash their hands, and sanitisers and cleaning wipes are available to all.
• Our cleaner has been given specific sterilisers and cleaning products to use.
• PPE is available for attendees.
• The large balcony window is to be opened and the AC used to ensure good ventilation in the Training room. Additionally, windows in the waiting area should also be opened.

Cleaning
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
Arda Eghiayan
To be reviewed on a quarterly basis

Data Protection and Information Security Policy

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.

Consent
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
Pseudonymisation means transforming personal data so that it cannot be attributed to an individual unless there is additional information.

• Pseudonymisation – the data can be traced back to the original data subject
• Anonymisation – that data cannot be tracked back to the original data subject

Examples of pseudonymisation we use are:

• We never identify patients in research, patient feedback reports or other publicly available information
• When we store and transmit electronic data it is encrypted and the encryption key is kept separate from the data

Data breaches
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:

• Confirmation that their data is being processed
• Access to their personal data
• Any other supplementary information about your rights as found below and in our Privacy Notices

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.

Data portability
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.

Records
We keep records of processing activities for future reference.

Information security
Information Governance Procedures includes the following information security procedures:

• Team members are aware of their legal duty to maintain confidentiality, to protect personal information and provides guidance on how and when personal or special category data can be disclosed
• How to manage a data breach, including reporting
• A comprehensive set of procedures, risk assessments and activities to prevent the data we hold being accidentally or deliberately compromised and to respond to a breach in a timely manner
• The requirements and responsibilities if team members use personal equipment such as computer, laptop, tablet or mobile phone for business

Regular review
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
GDPR Regulation

Glossary

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.

Duty of Candour Policy

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.

We will: 

• Notify the relevant person (who is usually the service user) that an incident has occurred as soon as is reasonably practical
• Give an apology in an appropriate manner, or by an appropriate representative, to the relevant person
• Provide the relevant person with all reasonable practical and emotional support necessary to help overcome the physical, psychological and emotional impact of the incident 
• Provide a jargon free step-by-step account of all relevant facts known about the incident with as much or as little information as the relevant person wants to hear
• Give information in a way that the relevant person understands, with advocates or interpreters if necessary
• Advise the relevant person on what further enquiries are appropriate and give them reasonable opportunities to be involved as much as they wish to be in any enquiries 
• Explain to the relevant person that new information may come out during the course of any enquiries into the incident, and keep them informed of new information 
• Provide a single point of contact for any questions or to discuss the case on an ongoing basis until they are satisfied that all relevant information has been disclosed 
• Provide the outcomes or results of any enquiries and investigations in writing to the relevant persons, should they wish to receive them 
• Respond to any correspondence from relevant person relating to the incident in an appropriate and timely manner
• Keep a record of all communications

Equality, Dignity and Human Rights Policy

Our commitment
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.

Legal responsibilities
The rights of our patients and our staff with regards to discrimination are protected by a range of legislation including:

• Human Rights Act 1998
• Equality Act 2010
• Part-time Workers (Prevention of Less Favourable Treatment) Regulations 2000
• Fixed Term Workers (Prevention of Less Favourable Treatment) Regulations 2001
• Data Protection Act 1998 & GDPR 2018
• Public Interest Disclosure Act 1998
• Anti-discrimination Acts and Orders in NI

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.

For patients
This facility and its staff aim to:

• Treat service users with dignity, respect and fairly, without discrimination, at all times
• Give all patients the information they need, in a way they can understand, so they can make informed decisions about their care
• Be clear on the procedures for providing additional support for service users with disabilities e.g. access for wheelchair users
• Provide services that are accessible to service users with disabilities and make reasonable adjustments in order to provide care which meets their needs
• Support patients by providing information in other languages and translators, where appropriate Keep patient information confidential
• Tackle health inequalities through positive promotion and care
• Involve individual patients and patient groups in decisions about the design and delivery of the service

For team members
Wigmore Medical will:

• Promote equality in the workplace as good management practice
• Create an environment in which individual differences and the contributions of staff are recognised, respected and valued
• Actively demonstrate its commitment to supporting and managing disability issues, for patients and staff in an effective, sensitive and respectful manner
• Ensure that every staff member has a working environment that promotes dignity and respect and is not discriminatory
• Ensure that no form of bullying, harassment or unlawful discrimination by staff or patients is tolerated
• Ensure reasonable adjustments are made, as appropriate, for staff with a disability
• Encourage, support and facilitate the continuing professional development of all staff through a range of training, development and progression opportunities
• Ensure all staff receive relevant equality, and human rights training and updates
• Provide regular, effective and appropriate supervision to all staff
• Provide regular and appropriate opportunities for all staff to give feedback and, where necessary, raise concerns
• Regularly review all employment practices and procedures to ensure fairness
• Regard breaches of the equality and diversity policy as misconduct, which could lead to disciplinary proceedings

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:

• Treated unfairly, or without dignity or respect
• Discriminated against
• Unhappy with any care or treatment they have received

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:

• Changes in legislation
• Good practice models
• Feedback from patients and staff
• Concerns and complaints raised by patients and staff

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.

Safeguarding 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:

• Having an awareness of and adopting safeguarding guidelines through our training service procedures and policies.
• Having a code of conduct for the team of trainers.
• Making staff and patients aware that we take the protection of children and adults at risk seriously and respond to all concerns.
• Sharing information about concerns with agencies who need to know and involving parents and children appropriately.
• Following carefully the practice procedures for staff recruitment and selection and, where appropriate, requesting enhanced criminal records checks.
• Providing effective management for staff by ensuring access to supervision, support and training.

This policy is underpinned by the following principles:

• Patients have access to information and knowledge to ensure that they can make an informed choice.
• Patients are supported to make their own decisions and to give or withhold consent to treatment. Unless provided for otherwise by law, no-one can give or withhold consent on behalf of another adult
• Information about patients held by the facility is managed appropriately and all members of the team understand the need for confidentiality.
• The individual needs of each patient are respected.
• The background and culture of all service users are respected.
• Training service procedures ensure the safety of patients at all times.
• Recruitment and selection procedures at the training facility are followed routinely and ensure that all required checks are carried out

Other training facility policies relevant to this safeguarding policy include:

• Confidentiality policy
• Consent policy
• Equality and diversity policy
• Recruitment and Selection policy

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.

Supporting guidance
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.

Definitions

• A child is anyone who has not yet reached their 18th birthday ¹
• An adult at risk is a person aged 18 years or over who is, or may be, in need of community care services or is resident in a continuing care facility by reason of mental or other disability, age or illness or who is, or may be, unable to take care of him or herself or unable to protect him or herself against significant harm or exploitation²

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:

• through a direct allegation (sometimes termed a ‘disclosure’) made by the child, adult at risk, a parent or some other person
• through signs and symptoms which are suggestive of physical abuse or neglect
• or through observations of child behaviour or parent-child interaction; or observation of the adult at risk and the relationship they have with their carer.

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.

• Discuss your concerns with a colleague or Arabella Tanyel.
• If you remain concerned, seek informal advice from the local social services department without disclosing the child’s name to help you decide whether a formal referral is needed. (see Safeguarding Contacts & Safeguarding Flowchart)
• Seek permission from the patient to refer – unless doing so would put the patient at greater risk, the parents or carers are being abusive or violent and discussion would put others at risk, or sexual abuse by a family member is suspected.

Where there is serious physical injury arising from suspected abuse:

• Refer the individual to the nearest hospital A&E department, with the consent of the person having parental responsibility or care of the child.
• Advise the A&E department in advance that the patient is being sent.
• If consent is not obtained, contact the duty social worker at the local Social Services Department or the police, so that action can be taken to safeguard the welfare of the individual

Records
Records of the incident should be maintained and be restricted to:

• The nature of the injury (see Body Map of Injuries document in the Treatment Models folder on Google Drive)
• Facts to support the possibility that the injuries are suspicious.

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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.