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Copy of online submission made by CMF on 15 September 2009 to the General Medical Council draft for consultation on making and using visual and audio recordings of patients

Published: 16th September 2009

Draft may be viewed at online

Questions about specific sections of the guidance

Publication and use of anonymised recordings (paragraph 10)

The draft guidance aims to make clear that recordings made as part of the care or treatment of a patient can be disclosed for research, teaching or training or other purposes connected to healthcare where the doctor holding the record judges it to be anonymised so that the patient cannot be identified from it.

Question 1.

Do you think that this is a reasonable approach?


Though should patients be informed of this possibility before recording commences? This is not spelled out.

Existing collections used for teaching and training (paragraphs 19-21)

The draft guidance encourages doctors to replace images of patients in existing collections, where there is no record of the circumstances in which the images were made, including whether the patient gave consent. However, the guidance allows doctors to continue to use images relating to rare conditions, or advance stages of conditions which are not usually seen in current practice if they still have educational value.

Question 2.

Do you think that this is a reasonable approach?


Deceased patients - Recordings made when the patient was alive (paragraphs 40-41)

Paragraph 40 of the draft guidance aims to make clear that after a patient dies recordings of them for teaching and research purposes, or for broadcast in a documentary, may usually be used in accordance with consent given while they were alive.

Question 3.

Do you think that this is a reasonable approach?


General questions about the guidance

Question 4.

Do you think the draft guidance contains the right level of detail?

About right.

Question 5.

Do you think the draft guidance is clear?

Very clear.

Question 6.

Do you think the draft guidance accurately reflects the law that applies where you live or work? (For example, the law relating to confidentiality, human rights and adults who lack capacity across the UK).


Question 7.

Can you identify any changes that would be needed in order to meet the standards set out in the draft guidance? (For example, in the protocol or systems in place to make and use recordings of patients).


Question 8.

Do you think that applying the standards in this draft guidance will have an adverse impact on particular groups of patients? (For example, adults who lack capacity or children and young people).


Question 9.

We would welcome any additional comments you may have on the draft guidance. These may include, for example:
a) Any important inconsistencies between the draft guidance and the guidance published by other relevant organisations. Other organisations may include, for example, the Information Commissioner or the broadcasting regulator Ofcom.
b) Whether you think we have achieved the right balance between setting out the key standards that apply to making and using recordings of patients and referring to more detailed guidance elsewhere.
c) Any other guidance documents or information that would be useful to refer to in the draft guidance.

We thought the guidance proposed in Paragraph (16) was unnecessary. Where do we ever stop in 'covering ourselves' by informing patients of every possible thing that might happen? Being recorded while unexpectedly unconscious is surely extremely unlikely?

Question 10.

Do you have any comments on the consultation documents and/or process?


For further information:

Philippa Taylor (CMF Head of Public Policy) 020 7234 9664
Steven Fouch (CMF Head of Communications) 020 7234 9668

Media Enquiries:

Alistair Thompson on 07970 162 225

About CMF:

Christian Medical Fellowship (CMF) was founded in 1949 and is an interdenominational organisation with over 4,000 British doctor members in all branches of medicine. A registered charity, it is linked to about 65 similar bodies in other countries throughout the world.

CMF exists to unite Christian doctors to pursue the highest ethical standards in Christian and professional life and to increase faith in Christ and acceptance of his ethical teaching.

Christian Medical Fellowship:
uniting & equipping Christian doctors & nurses
Contact Phone020 7234 9660
Contact Address6 Marshalsea Road, London SE1 1HL
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