RCGP statement on patients’ access to their GP records

The RCGP has been engaging closely with NHS England over plans to grant patients automatic access to their prospective records from 1 November 2022

The College has always supported the principle of expanded record access and the benefits that patient access to records offers in terms of self-management, health outcomes and patient satisfaction. However, we have also recognised the additional risks that automation brings and over the past year we have consistently highlighted the importance of practice preparedness, safe redaction technology and consideration of the most vulnerable patients.

Thanks to College efforts, the go live date was delayed from December 2021 and NHS England committed to provide further information and support to practices as well as to engage with the wider system and vulnerable groups. Additional guidance to practices has also been made available in the updated RCGP GP online services toolkit. In seeking to support the expansion of record access, the College considered automatic access to be on balance an acceptable risk to take.

However, it is clear as we enter the final days before the planned go-live date of 1 November that some of our members do not feel ready to implement automatic access safely for patients. This is despite their best efforts to prepare and despite the College’s work to support them in this.

The workload and workforce crisis facing general practice severely limits the ability of GPs to engage with any additional programmes of work, with priority rightly given to providing direct care for patients. In addition, while some improvements have been made to redaction functionality, NHS England has not yet delivered on all of the technical solutions the College proposed last year. Concerns have also been raised that other parts of the healthcare system are not sufficiently informed about what this means for their communications with general practice and about the implications of automation for the role of GPs as data controllers. The College has communicated these concerns to NHS England on a regular basis, and highlighted NHS England’s responsibility to fully consider the risks associated with this programme and the legal basis under which it is implemented.

It is appropriate that practices that feel ready to do so proceed with expanding record access, but the College would never encourage practices to go ahead with a course of action that they feel would jeopardise patient safety. Practices must consider the benefits of providing record access against their own level of preparedness and capacity to redact sensitive information safely, and decide whether to delay access in order to prepare further. Information is available in the RCGP GP online services toolkit on how to apply opt-out codes to prevent automatic access for patients for whom it is considered unsafe.

However, practices should not be left to address these risks alone and before confirming go-live, NHS England must carefully consider the timescale in the light of the latest information about the situation on the ground.