St Michael’s Clinic Ltd recognises and values the diversity of its patients and employees and is committed to equality of opportunity for all.

BACKGROUND

The Equality Act 2010 was enacted in April 2010, bringing together all the separate pieces of anti-discrimination legislation and further strengthening the law. The act covers the following protected “characteristics.”

• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race
• Religion or belief
• Sex and sexual orientation

The act’s main provisions came into effect in October 2010, the new Public  Service Equality Duty came into force in April 2011, and the ban on age discrimination in the provision of goods, services and public functions took effect in April 2012.

The Dermatology Partnership and St. Michaels Clinic Ltd have specialist support and advice on all HR matters from Effective HRM and will use this advice as required in relation to policies and to ensure that all elements of HR management are kept up to date, and all legal requirements are met.

PURPOSE

The purpose of the equality and diversity policy is to ensure that St Michael’s Clinic Ltd provides accessible, high-quality services and employment opportunities. Its aim is threefold;

1. To deliver high quality, fully accessible, respectful patient-centred services.
2. To deliver best practice in terms of recruitment and employment.
3. To promote equality and ensure that any clinic policies or procedures unlawfully disadvantages no one.

It is the policy of St Michael’s Clinic Ltd. that no employee, patient or visitor should discriminate against another individual or group, directly or indirectly, because of the listed characteristics. For employees, they abide and support this policy as a condition of their employment. Discrimination is considered to be gross misconduct and is subject to dismissal if upheld. For patient and visitors, if it is believed that they are discriminating against either a member of staff or another patient or visitor, they will be asked to leave the premises.

This policy covers all employees and those with practice privileges at St Michael’s Clinic Ltd sites, regardless of position or status and to all patients and visitors attending any of our clinic sites.

OUR AIMS

• To ensure equality, diversity and inclusion in the workplace.
  To offer fair treatment in all aspects of working life at our sites, from our written policies and procedures through to decision-making.
• To promote a culture where each employee, patient and visitor is treated with respect and dignity.
• To recognise the value that a diverse workforce can bring.

To achieve these aims, St Michael’s Clinic Ltd commits to the following;

• Ensure that the principles of this policy are used when producing all other policies and procedures used in our clinics.
• To review, monitor and adapt policies and procedures according to audits and changes in relevant legislation.
• To provide training to our employees to ensure that our commitment to diversity is known and understood. This will be achieved mainly through online training sessions and staff meetings.
• Monitor diversity during the employment process and remove any direct or indirect associative and perceptive discrimination.
• Challenge and investigate discriminatory behaviour and enforce our disciplinary policy when it is considered necessary.
• Protect our employees against discrimination from patients or visitors by making it clear to them that we will not tolerate any behaviour that is seen as discrimination towards our members of staff.

OUTCOMES

1. That patients, visitors and employees are treated with respect and dignity.
   That our services are accessible for all, culturally appropriate, and outcomes are equitable.
2. St Michael’s Clinic Ltd is acknowledged as a good employer that values its
   workforce.
3. We have a well-trained, aware and motivated workforce that reflects the
   diversity of the population it offers services to.
4. All patients, visitors and employees are protected from discrimination and abuse.

MONITORING AND REVIEW

St Michael’s Clinic Ltd will monitor the performance of this policy through an annual review of all patient and staff complaints, by analysis of patient survey returns and from feedback from individual staff appraisals. Comments, complaints and incidents are discussed and investigated at bi-monthly Clinical Governance meetings and investigations will be undertaken by the Significant Events Analysis team.

This has led us to be an award-winning clinical group and favoured by our patients. This is from a combination of our team’s world-class expertise and as a result of responding to feedback that we have received over the years. We understand sometimes situations may happen where you are unhappy with our services and your clinic experience matters to us.

If you do experience any issues or are unhappy about anything at our clinic, including correspondence before and after your visit, please let us know at the time by verbally informing a member of staff. If the event is after you have left the clinic, please telephone or email your concern.

We offer Feedback Cards that you can help yourself to in the communal waiting areas and front reception desk that include means to contact us for feedback and complaints. The team can also provide on request a patient survey from the General Medical Council that you can fill out anonymously regarding any Consultant you have seen at our clinic to help them improve their service.

Formal Complaints Policy

If you would like to write a formal complaint please email: complaints@thedermatologypartnership.com or post to:

The Practice Manager
St Michael’s Clinic
St Michael’s Street
Shrewsbury
SY1 2HE

You will receive an acknowledgement of your complaint and an offer to discuss the matter within three working days. In the unlikely event that we are not able to resolve your complaint internally please see details below of how to seek arbitration or mediation if you are dissatisfied with the outcome.

Feedback

If you would like to email us your feedback on your experience, positive or not, please email phaycox@stmichaelsclinic.co.uk.

Raising the Matter With The Care Quality Commision

Call us on:
03000 616161

Email us at:
enquiries@cqc.org.uk

Look at our website at:
www.cqc.org.uk

Contact the Citizens Advice Service

Citizens Advice provides free, confidential and independent advice from over 3,000 locations, including in their bureaux, GP surgeries, hospitals, colleges, prisons and courts. Advice is available face-to-face and by phone.

Our Data Protection Policy is available here.

Our Confidenciality Policy is available here.

Our Privacy Policy is available here.

Our Information Governance Policy is available here.

1. Introduction

The Freedom of Information Act Policy is a statement of responsibilities of St Michael’s Clinic Ltd under the Freedom of Information Act (“the Act”), and how then company will ensure compliance with the Act, including procedures staff should follow if they receive a request for information.

2. Scope

This policy applies to all Clinic staff and relates to the procedure in place for dealing with requests under the Act. This excludes personal data, which will continue to be dealt with under the Data Protection Act (see Data Protection and Confidentiality Policies).

3. Purpose

The purpose of this policy is:

1. To ensure St Michael’s Clinic Ltd complies with the Act.
2. To ensure all Clinic staff are aware of their responsibilities under the
   Act.
3. To outline St Michael’s Clinic Ltd procedure in responding to a
   request under the Act.

4. Definitions

Data Protection Act (2018) (“the DPA”). An Act of Parliament which
defines the UK law on the processing of data of living persons. The DPA
defines eight data protection principles and is the main legislation
governing the protection of personal data in the UK.

Exemptions. Conditions which may be applied in circumstances in which
requested data may be withheld from disclosure. There are two types of
exemption: absolute and qualified.
Absolute exemptions: exemptions that do not require a public
interest test to be undertaken.
Qualified exemptions: exemptions which require a public interest
test to be completed before they are applied.
Freedom of Information (FOI) Act (2000) (“the Act”). An Act of
Parliament which came into force in 2005. The Act gives the public the
“right to know” and allows them to request any information held by St
Michael’s Clinic Ltd relating to its work for and with the NHS only.
Information Commissioner’s Office (ICO). An independent regulatory
office reporting directly to Parliament and overseeing the DPA, the FOI
Act, and the EIRs. The Information Commissioner is appointed by the
Crown.
Public Interest Test. A public interest test must be applied when the use
of a qualified exemption is proposed. The factors for and against the
disclosure of requested information are considered. In order to apply the
exemption, the factors against disclosure must be seen to outweigh the
factors for disclosure.
Publication Scheme. A list of information the ICO expects public
authorities to regularly publish. All public authorities are required to
produce and maintain a Publication Scheme.
5. Related Clinic Policies
Data Protection Policy 2019
Confidentiality Policy 2019
Document, Record and Lifecycle Management Policy 2018
6. Roles and Responsibilities
All Clinic staff are required to comply with the Act. Staff who do not
respond in a timely manner will have the request escalated to their line
manager.
Freedom of Information Policy 2018
Shared document/Policies and Procedures/Freedom of Information Policy 2022
Review January 2024
Failure to assist may result in St Michael’s Clinic Ltd. failing to comply with
the Act, which may lead to complaints and ultimately an investigation by
the Information Commissioner.
Non-compliance with a Clinic policy, Procedure, protocol or patient
information standard may result in disciplinary action.
The Senior Information Risk Owner (SIRO) – Mr Paul Haycox – has overall
responsibility for compliance with the Act.
As well as ensuring compliance, St Michael’s Clinic Ltd SIRO is also the
responsible manager to bring any FOI issues requiring the Senior
Clinicians and Managers Group consideration to their attention.
St Michael’s Clinic Ltd Information Governance (IG) Lead, has
responsibility for the overall management of FOI policy and procedure and
the day to day routine management of FOI requests and procedures.
All staff have a responsibility to recognise and respond to requests for
information, and to forward information to the IG Lead when asked.
7. Receiving and responding to requests
St Michael’s Clinic Ltd will ensure it provides advice and assistance (as set
out in Section 16 of the Act) to persons who propose to make, or have
made, requests for information.
Under the Act, the Clinic has a duty “to confirm or deny”. In the vast
majority of cases, the Clinic must either confirm or deny whether the
information requested is held. Failure to do so may result in an
investigation by the ICO.
The Clinic may not have to comply with a request if it falls under an
exemption allowed for in the Act (See Part II of the Act, items 21 to 44)
Information provided by the Clinic in response to a request under the Act
remains under copyright and intellectual property law. If any person
wishes to re-use the public information for commercial purposes they
should make an application under the Re-use of Public Sector Information
regulations. The information should only be used for the applicant’s
personal use or for other specific uses permitted in the Copyright, Designs
and Patents Act 1988.
If an applicant wishes to use information provided by St Michael’s Clinic
Ltd for commercial purposes (including the sale of the information to a
third party) they must seek written permission from the company.
Granting permission may involve a licensing arrangement, which may
incur a fee for the applicant.
Freedom of Information Policy 2018
Shared document/Policies and Procedures/Freedom of Information Policy 2022
Review January 2024
8. Exemptions
The Act provides a small number of exemptions that may allow St
Michael’s Clinic Ltd not to disclose requested information.
The most likely exemptions to be used within St Michael’s Clinic Ltd is
Section 40 (personal information), Section 21 (information available by
other means), and Section 12 (cost of compliance is excessive, see 6.4).
Section 14 allows for a request to be exempt by classing it as “vexatious”
or “repeated”. The history of the request will be looked at in order to
establish whether a request is vexatious or repeated. Characteristically,
vexatious requests are typically obsessive and cause unjustified distress
and disruption. It is the request, not the requestor that is deemed
vexatious or repeated, so future requests will not be automatically
refused. A requestor asking for information that has already been supplied
to them can be treated as repeated.
Any decision to use a Section 14 exemption will be agreed by St Michael’s
Clinic Ltd SIRO. Requestors deemed as vexatious or repeated must be
given the right to appeal this decision by being informed of their right to
request an internal review. Once a requestor has been informed that their
request is being treated as vexatious or repeated, St Michael’s Clinic Ltd is
not obliged to provide any further response to any repeated requests for
substantially similar information until a “reasonable interval of time” has
passed.
In accordance with the Freedom of Information and Data Protection
(Appropriate Limit and Fees) Regulations 2004, St Michael’s Clinic Ltd has
the right to refuse to process any request for information where the costs
associated with that production would exceed £450. This is calculated at
the flat rate of £25 per hour and equates to 18 working hours. This is
regardless of actual salary or job role. Not all activities associated with the
production of the information will be chargeable. Where it is intended to
apply this exemption, a breakdown of the work involved in complying with
the request will be required by the SIRO, stating how the £450 limit would
be reached, and by how far it would be exceeded. The applicant may wish
to pay for the request to go ahead. St Michael’s Clinic Ltd may make
charges for multiple copies of information.
9. Refusal of Requests
St Michael’s Clinic Ltd will be obliged to disclose any information in
response to a request unless an exemption provided for in the Act applies
in relation to that particular information. If St Michael’s Clinic Ltd chooses
to refuse a request for information under any of the reasons outlined in
The Act, the applicant will be informed of the reasons for this decision
within twenty working days.
When a request is refused, the applicant will be informed of the procedure
for requesting an internal review of St Michael’s Clinic Ltd handling of the
Freedom of Information Policy 2018
Shared document/Policies and Procedures/Freedom of Information Policy 2022
Review January 2024
request, and of how to make a complaint to the ICO if they remain
dissatisfied. Appendix D contains the Clinic’s “How to request a review”
letter.
St Michael’s Clinic Ltd will follow the Appeals Procedure in Appendix B
point 12 when dealing with complaints about the discharge of the duties of
St Michael’s Clinic Ltd under the Act, including the handling of requests for
information.
Where a request is made for information that is subject to a current piece
of work and premature disclosure is not deemed in the public interest, St
Michael’s Clinic Ltd may choose to withhold the information temporarily.
Every effort will be made to indicate a date when a future request would
be honoured.
10. Consultation with Third Parties
St Michael’s Clinic Ltd recognises that in some cases the disclosure of
information may affect the legal rights of a third party, for example where
information is subject to the common law of duty of confidence or where it
constitutes “personal data” within the meaning of the DPA. Unless an
exemption provided for in the Act applies in relation to any particular
information involving third parties, St Michael’s Clinic Ltd will be obliged to
disclose that information in response to a request. St Michael’s Clinic Ltd
will always try to gain the consent of employees (see 8.0).
The fact that the third party has not responded to the consultation does
not relieve St Michael’s Clinic Ltd of its duty to disclose information under
the Act, or its duty to reply within the time specified in the Act.
In all cases, it is for St Michael’s Clinic Ltd, not the third party (or
representative of the third party) to determine whether or not information
should be disclosed under the Act. A refusal to consent to disclosure by a
third party does not, in itself, mean information should be withheld.
11. Records Management
St Michael’s Clinic Ltd is compliant with the Code of Practice on the
Management of Records under section 46 of the Act.
A request for information cannot be refused on the grounds of an inability
to locate a document or information due to poor records management. It
is a criminal offence to destroy material because it has been requested
under the Act.
St Michael’s Clinic Ltd Document, Record and Lifecycle Management Policy
contains information about the creation, management, retention period,
and disposal of Clinic records.
Freedom of Information Policy 2018
Shared document/Policies and Procedures/Freedom of Information Policy 2022
Review January 2024
12. Implementation
The policy will be available on the clinic’s internal shared network and in
hard copy.
The new policy will be highlighted to those receiving contact from the FOI
office regarding requests for information.
St Michael’s Clinic Ltd Business Manager will be available to talk to
individual staff groups about FOI awareness as and when requested.

Introduction

The Dermatology Partnership is a leading dermatology group, defined by its clinical excellence and focus on leading dermatological care. We are committed to providing our patients with
the best service and support.

We have a zero-tolerance approach to modern slavery or human trafficking in our business operations or supply chains.

We are committed to acting ethically and with integrity in all our business dealings and
relationships. Modern slavery is a crime and a violation of fundamental human rights. We recognise this takes various forms, such as slavery, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains. We expect the same standards and commitment from all our suppliers, contractors and other third parties.

Our Business

We operate in the medical sector and all our dermatologists are well-known authorities in their
field. Prior to employment careful checks are carried out to ensure that our team have the right to work, DBS clearance, qualifications and licence to practice.

We recognise that due to the level of checks within our sector the risk of modern slavery is lower, but we take our responsibility seriously in ensuring that our business operations and supply chains are compliant. Our HR providers are aware of the signs of exploitation and can take the necessary steps should that be identified.

Responsibility for this policy
It is the boards job to make this policy and how we behave complies with our legal and ethical responsibilities, and that works under our control follows this policy.

Our compliance manager has day to day responsibility for putting this policy into practice, making sure it works and answering questions about it.

We have thought about the areas of our business where there might be risks of modern slavery and put in place steps to reduce the risks as far as we can. We provide training for our people
where they can help with those steps.

It is the job of every manager to make sure the people that report to them understand and follow this policy and are given enough regular training on it.

Our Supply Chains
We do not use third parties to provide our services. Given the industry we operate in we do not have an extensive supply chain network. However, we do engage with suppliers for essentials to support business operations, such as IT, accountancy and legal services. We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally compliant and professional manner.

Due Diligence
We identify and assess the risk of potential slavery and human trafficking in our supply chains
and our diligence measures include:

• Requiring all staff to comply with the applicable legislation relating to Modern Slavery
  and to avoid any activity that might lead to, or suggest, a breach of this legislation.
• Requiring new suppliers to agree to contractual obligations to avoid slavery and human
  trafficking and all existing contracts to include these contractual obligations at the next
  renewal or extension.
• Encouraging all staff and third parties to raise any concerns about any issue or
  suspicion of modern slavery in any parts of the business or supply chains of any
  supplier tier at the earliest possible stage and to notify the Board.
• Protecting staff from victimisation or retaliation if they raise concerns about slavery and
  human trafficking, even if raised in error.
• Taking any allegation of potential slavery and human trafficking seriously and
  investigating any allegation diligently.

Our People

We are committed to operating our business with integrity and in an environment where all
employees feel like they can report any concerns they may have.

We ensure that all our employees are eligible or have the necessary visas to work in the United Kingdom.

We treat all employees in a fair and equal manner and with dignity and respect. We ensure that employees’ salaries are always paid at market rates and above minimum wage.

We ensure that all employment is freely chosen and employees can leave with reasonable notice. Additionally, all employees must be provided with a clear contract of employment, which complies with local legislation.

Our employee must raise any concerns that involve modern slavery immediately, even if they are not certain as we would rather be informed of any genuine concerns.

Our Training

To raise awareness of the potential risks of slavery and human trafficking, we provide guidance and training to support our employees’ understanding of expected behaviours during induction and beyond where required.

Breaches of Our Policy

Employees who breach this policy will face disciplinary action, which could result in being termination of the employment contract for gross misconduct. We may also immediately end our relationship with other individuals and organisations working with us if they breach this policy.

Approval

This policy / statement refers to the financial year ended 31st March 2024 and has been approved by the Directors.