Introduction

1.1 Policy statement

This policy outlines the use of the practice telephone system and details the procedures for managing calls, telephone consultations and the practice text-messaging service.

1.2 Status

The practice aims to design and implement policies and procedures that meet the diverse needs of our service and workforce, ensuring that none are placed at a disadvantage over others, in accordance with the Equality Act 2010. Consideration has been given to the impact this policy might have in regard to the individual protected characteristics of those to whom it applies.

This document and any procedures contained within it are contractual and therefore form part of your contract of employment. Employees will be consulted on any modifications or change to the document’s status. 

1.3 Training and support

The practice will provide guidance and support to help those to whom it applies understand their rights and responsibilities under this policy. Additional support will be provided to managers and supervisors to enable them to deal more effectively with matters arising from this policy.

Use of telephones

4.1 Provision

Phones are provided to enable practice staff to communicate with patients, the patients’ carers and other service providers to ensure that the expected level of service is delivered at all times.  

4.2 Acceptable and authorised use

Practice phones are only to be used for the purpose of practice business. Personal use is strictly prohibited except in the event of an emergency. Calls to premium-rate telephone numbers are also prohibited.  

Calls to areas outside the UK are blocked; should it be necessary to call a number, practice manager authorisation will be required.

4.3 Recording incoming and outgoing calls

In accordance with the General Data Protection Regulation (GDPR), the lawful basis for processing data also applies to the recording of telephone calls. In accordance with Article 6 of the Regulation, one of the following must apply when processing any data: 

1. The data subject has given consent to the processing of his/her personal data for one or more specific purposes
2. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
3. Processing is necessary for compliance with a legal obligation to which the controller is subject
4. Processing is necessary in order to protect the vital interests of the data subject or another natural person
5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
6. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child

To align Article 6 with the recording of telephone calls, one of the following must apply:

1. The individuals involved in the call have given consent to be recorded
2. Recording of the call is necessary for the fulfilment of a contract
3. Recording of the call is necessary for the fulfilment of a legal obligation
4. Recording of the call is necessary to protect the interests of the participants or another natural person
5. Recording of the call is in the public interest or necessary for the exercise of official authority
6. Recording of the call is in the legitimate interests of the recorder, unless the interests are overridden by the interests of those involved in the call

When accepting an incoming call or dialing out, staff must endeavor to advise the caller or receiver that the call will be recorded and give the reason for the call being recorded. To justify the recording, one of the above reasons must apply.

GDPR Article 6.

In general, the purpose of call recording at TLCP is to provide a record of incoming and outgoing calls, which can:

• Identify practice staff training needs
• Protect practice staff from nuisance or abusive calls
• Establish facts relating to incoming/outgoing calls made (e.g. complaints)
• Identify any issues in practice processes with a view to improving them

TLCP will make every reasonable effort to advise callers that their call may be recorded and for what purpose the recording may be used. We have in place a pre-recorded message within the telephone system and have placed notifications regarding call recording on our website. The voice file is stored within the telephone system to which the same rules of confidentiality will apply.

If a patient objects to call recording, they can be called back/ contacted via an extension that is not subject to recording or alternatively asked to visit the surgery in person.

4.4 ACCESS TO TELEPHONE RECORDINGS 

• All TLCP staff are set up as standard users within the telephony system.
• All TLCP staff are able to listen to only their own individual recordings that they have participated in, saved on the telephony system.
• Staff are unable to delete any recordings.
• The TLCP telephony supervisor user group of which consists of the TLCP management team are able to listen to all recordings across the practice. They can download and delete call recordings.

All call recordings are kept/ stored within the telephony system for 3 years.

Access to a call recording leaves an audit trail.

From time to time monitoring of the call recordings will be undertaken by the Partners and the TLCP management team. The purpose usually being to identify any training needs, to provide feedback and allow developmental support.  Any playback of recordings will take place in a private setting and where applicable, individuals will be given the opportunity to listen to the relevant recordings to receive feedback and developmental support.  

Patient requests for copies of telephone conversations can be made under the Data Protection Act as a “Subject Access Request”. This must be done in writing and after assessing whether the information can be released, the requestor can be invited to the practice premises to hear the recording.

4.5 Answering protocol

All staff are required to answer the practice telephones in the same manner, answering as follows: 

• Use the appropriate salutation – good morning, good afternoon, good evening
• Please be advised, calls at TLCP are recorded for training and service Improvement purposes. 
• Give your name and ask, “What’s your DOB and how can I help you?”
• Action the request as appropriate
• If appropriate, place the call on hold (advising the caller that you are going to do so) until you are able to process the request
• Speak in a polite and professional manner at all times

4.6 Taking messages for staff

Should a caller wish to leave a message for a member of staff (e.g. a doctor), staff must ensure that they:

• Annotate the date and time of the call
• Record who is calling, confirming their identity by obtaining their full name and best contact telephone number
• Record the subject they wish to discuss with the member of staff
• Repeat the information to confirm accuracy

Once the call has ended, the staff member receiving the call can either:

• Send a message (using EMIS  system) 
• Email the intended recipient if they are out of the office 

For urgent messages, staff must ensure that the message is relayed in a timely manner, ideally in person to the relevant person or in their absence to their Line manager.

4.7 Abusive or aggressive patients

Unfortunately, on occasion there may be times when a patient calls the practice and speaks to a member of staff in an abusive or aggressive manner. Staff must ensure that they:

• Annotate the date and time of the call
• Ascertain who is calling
• Remain calm, offering empathy
• Determine the reason (if possible) for the aggression or abuse
• Offer solutions if practicable
• Advise the caller that if they persist with such an aggressive and/or abusive tone, the call will be ended
• End the call if appropriate
• Note down a summary in the patient’s healthcare record
• Inform the Line Manager 
• Report the incident in accordance with the practice incident reporting policy or significant event policy

In all circumstances, staff are to demonstrate confidence and compassion, remaining calm throughout the incident. Staff should refrain from being judgemental, instead opting to show the patient their clear intention to resolve the situation as opposed to attempting any form of reprimand.   

If it has been necessary to contact the local police, the practice manager is required to notify the CQC of any incident that is reported to, or investigated by, the police. 
4.8    Supporting the team

Staff who experience incidents of violence or aggression may experience subsequent after effects, which may require support from the team or external resources. Line managers and the practice management team will be required to support all staff members following any incident, no matter how minor it may seem, to ensure that the health and well-being of the staff member is not adversely affected.  

4.9 Emergencies

Calls about emergencies should be handled in accordance with the practice’s [Emergency Telephone Call Policy].  

4.10 Practice answering machine

The practice answering machine is turned on at 18:30 and switched off at 08:00 on a daily basis. The outgoing message is not to be amended unless authorized by Khaled Chowdhury (the Care Navigator Hub line manager). The current outgoing message is:

The Lewisham Care Partnership is now closed. Our routine opening hours are Monday to Friday 08:00 to 18:30. Out-of-hours patients are to call NHS Direct; this service can be accessed by dialing 111 from a landline or mobile phone. If you are calling about a medical emergency, please hang up, dial 999, and ask for the ambulance service.

Patients are unable to leave messages on the practice answering machine.

4.11 Patients’ answering machines

TLCP will not routinely leave messages on patients’ answering machines unless it is deemed urgent. This is to ensure that patient confidentiality is maintained at all times. 

If it is necessary to leave a message, the message must be brief and not breach confidentiality. The following is an appropriate example: “Please call 020 8692 1354 when you are free to discuss your appointment.” It is essential that clinical information, patient-identifiable information or other sensitive information is not disclosed during the recording of the message.

  CQC (Registration) Regulations 2009: Regulation 18: Notification of other incidents.

Telephone Consultations

6.1 Arrangements

At TLCP, clinicians are permitted to conduct telephone consultations with patients. Clinicians are allocated a number of telephone consultations slots, with each consultation being allocated 10 minutes.

6.2 Process

Prior to calling the patient, the clinician should read the patient notes on EMIS, familiarizing themselves with the notes made during the triage telephone call and any pre-existing medical conditions. The clinician is to then telephone the patient and:

• Introduce themselves clearly, stating their name and role at the practice
• Verify the ID of the patient, ensuring that they are the patient or they have the consent of the person they are calling about. This should include three forms of identity to confirm the ID, and can be a combination of name (first and last), telephone number and address
• Explain the purpose of the telephone consultation
• Offer the patient the opportunity to explain what it is they are calling about, using questions and probing as and when required
• Seek clarification to any comments the patient has made, eliciting any relevant information 
• Determine what it is the patient would like or thinks they need
• Consider a diagnosis
• Determine what treatment and/or medication is required
• Formulate an action plan, relaying the plan to the patient (or their representative)
• Ensure that the patient (or representative) understands and agrees with the plan
• End the call once assured that the patient is happy, advising the patient to call back or call 999 if their condition worsens (based on the advice given)

6.3 Recording the consultation

The clinician is to record the consultation in the individual’s healthcare record, ensuring that it is a true reflection of the consultation. Again, if the patient fails to answer the call, this is to be recorded in the healthcare record.

6.4 Prescribing by telephone

Clinicians at TLCP who are authorised to prescribe via telephone must adhere to the GMC prescribing guidance:

“Before you prescribe for a patient via telephone, video-link or online, you must satisfy yourself that you can make an adequate assessment, establish a dialogue and obtain the patient’s consent…”

Additionally, clinicians are advised that:

“…you may prescribe only when you have adequate knowledge of the patient’s health, and are satisfied that the medicines serve the patient’s needs.  You must consider:

• a. The limitations of the medium through which you are communicating with the patient
• b. The need for physical examination or other assessment
• c. Whether you have access to the patient’s medical records”

6.5 Risks

Whilst it is acknowledged that good telephone consultations can improve patient’s access to advice and treatment , clinicians at TLCP must ensure that they fully understand the risks associated with telephone consultations and take the necessary actions to mitigate such risks where possible. 

The following are common examples of risks, and action should be taken to avoid them:

• Poor information gathering due to the absence of significant questions
• Inappropriate decision-making, such as premature diagnosis 
• Confusion due to poor communication 
• Unmet expectations due to unclear instructions/advice

Communicating using text messages

8.1 GMC advice

The GMC recognises that text messaging is convenient and can be effective, but warns practices to take the necessary precautions to ensure that the communication method they use is secure. 

8.2 Consent

Patients must consent to being contacted by text; this requires a positive opt-in, ensuring compliance with the General Data Protection Regulation (GDPR). TLCP will obtain patient consent using the form at Annex A.

8.3 Services offered

TLCP will offer a text-messaging service to patients, which will include:

• Reminders for certain appointments 
• Appointment confirmation (following a booking)
• Clinic cancellation notices
• Reminders of reviews 
• Service announcements

8.4 Text-message etiquette

Staff must refrain from using ‘text speak’ and ensure that messages are written in a language that is understandable and unambiguous. 

Texts from TLCP are to be sent using the Accurx system. Under no circumstances are staff (clinicians or administrative) to use their personal mobile phones to send messages to patients.

8.5 Patient awareness

Patients are to be advised that the practice operates a text-messaging service by:

• Including information in the practice leaflet
• Advertising the service on the practice website
• Displaying posters in the practice waiting room/reception area

A poster template is available at Annex B.

MDU Text message communication in general practice.