Policy Index (Scotland)

In the event that the company’s registered manager is unavailable to discharge their duties in respect of their role for a period of greater than 28 days, the company will notify the Care Inspectorate. Details would include the following:

i.   The absence;
ii.  The expected length of absence;
iii. Proposed arrangements to provide cover for the registered manager

Any arrangements for managing the nursing division in the absence of the registered manager will be with the approval of the Care Inspectorate.

This policy aims to define for agency staff what occurrences can be regarded as an ‘accident’ or an ‘incident’. Action to be taken in terms of reporting, recording and notifying such occurrences is referenced in the the policy document ‘Reporting, recording and notifying accidents, incidents, infectious diseases and deaths incl. RIDDOR arrangements’. Agency staff are reminded also to check the corresponding policy at the client organization to ensure that any additional requirements at the location of the assignment are adhered to.

Definitions

INCIDENT: We use the word incident here to cover anything that occurs in the
workplace that could cause a situation that results in harm to people, damage to property or loss of service capacity, including accidents.

NEAR MISS: Describes an event that could have caused injury but narrowly missed doing so.

CRITICAL INCIDENT: The term ‘critical’ is used to reflect the actual or potential severity of the impact and the consequences of the event and would include the death or serious injury of a service user, visitor or staff member, serious assaults or serious medication incidents.

RIDDOR: The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) places a statutory duty upon the Agency to report and record all accidents, incidents, diseases and dangerous occurrences arising out of work activities.

DANGEROUS OCCURENCE: The term Dangerous Occurrence when applied to these guidelines, relates exclusively to the definition of Dangerous Occurrence contained in the RIDDOR Regulations 1995.

LOST TIME INCIDENT: Major or other accidents resulting in absence from duty for over three days, excluding the day of the accident. This is reportable under RIDDOR to the Health and Safety Executive (HSE).

MAJOR INJURY: Any injury included in the list under RIDDOR

CONTEMPORANEOUS: Contemporaneous records are those made during and immediately after the incident. This is essential for providing an accurate account of what happened. Failure to keep contemporaneous records could prejudice
the validity of the evidence in court proceedings

Further guidance can be found here

Incident reporting and recording procedure

When an incident is reported to the company, the following steps are completed:

i.    An incident case file is opened using NREC 11.2 ‘Incident Records’, with an entry on the Incident Log created alongside a separate file folder in which to store documents specific to the incident;
ii.   The incident is reported to the Nursing Manager who is responsible for overseeing follow-up and close-off in collaboration with the candidate, Direct Medics staff service users and/or regulatory bodies as appropriate;
iii.  All relevant documents are stored in the appropriate case file folder, and a log of contacts and close-off is stored in the Incident Log.

Direct Medics Accounting Policy overview 

Comply with generally accepted Accounting Principles (GAAP) OR International Financial Reporting Standards (IFRS) and apply accounting policies consistently within an accounting period from one financial year to another, subject to change if new accounting standards are introduced or the scale of activities change. Accounting policies refer to the framework that guides the recognition, measurement and presentation of assets, liabilities income and expenditure in financial statements.  

Aim

The aim is to enhance the comparability of financial information. This policy is a guideline for the organization and employees to follow to achieve compliance. This will assist employees and give direction and decision-making guidance.   

Purpose

The main purpose of the accounts team is to record and report on the company’s financial transactions, financial performance and cash flows. The information provided by the accounts department must be true, comparable, timely, relevant, understandable and complete, which is the basic principle of the accounting policy and will ensure that financial activity is recorded accurately and consistently across the organization. 

Scope

All aspects of the company’s finances.  

Section 1: Accounts receivable team structure

The Accounts Receivable team consists of a Finance Manager, Accounts receivable Specialists/Credit Controllers, Finance Administrators and Finance Support Officers.  

Daily Tasks

• Update Finance system to ensure bank links are operational to show daily cash inflows on both current and reserve accounts  
• Check employee outlook inbox am to establish daily task list and prioritize queries from customer accounts, director and other departments within the organization e.g. recruitment compliance and payroll. (see section 2 for additional notes)  
• Check Remittance inbox am to retrieve any remittances that need allocation.   
• Allocate all daily cash inflows on the finance system  
• Reviewing emails, dealing with any customer queries and disputes, responding to clients. (see section 2 for additional notes)  
• Maintaining and updating Credit Control spreadsheets daily. This includes recording customer communication and follow ups, monitoring outstanding balances, etc. (see section 2 for additional notes)  
• Assist with system integrations as required.  

Prioritize in order as follows:

1. Daily requests/resolving queries in order of importance and urgency from the managing director/operations general manager-Paul Mulvenna  
2. Daily requests/ resolving queries in order of importance and urgency from Finance Manager – Rose McLernon 
3. Resolving email/phone queries in order of importance and urgency:
4. External customers/auditors and accountant
5. Internal departmental requests  

Weekly Tasks

• Printing and checking invoices for the previous week   
• Sending invoices from previous week   
• Import and publish invoices on finance software   
• Reconciliation of Local trust remittance and portal remittances on finance software   
• Upload shifts worked onto portals for approval by trusts   
• Identifying anomalies with timesheets and investigating over and under payments of portal invoices   
• Correct and resubmit invoices to trusts when required  
• Correct invoices and create credits on both finance software   
• Produce and send statements to local trust once reconciliations are complete as soon as remittance has been allocated or when required for any trust/customer account   
• Follow up with portal providers for remittance and payment as required  
• Assist with ad hoc projects requested by managing director/directors as and when requested.   
• Assist Managing Director with weekly bank reconciliation   
• Assist accountant/auditors with queries and provide requested information  
• Produce reports on portals to show outstanding payments  
• Maintenance of client contact details on Eclipse CRM 

Monthly Tasks/Quarterly-Currently Manager responsibility

• Assist with statement reconciliation from BSO and resolving any queries to ensure payment of invoices-as per director instruction.  
• Assist director with correspondence detailing legal proceedings for unpaid debts-as per director instruction.  
• Assist director with interest calculations on unpaid aged debt-as per director instruction.  
• Assist Director with VAT queries -as per director instruction.  
• Assist with projects for efficiency improvements working with other departments e.g. IT. -as per director instruction.  

Agency nurses can administer any medicines or drugs that have been prescribed for the service user/patient by a qualified medical practitioner or nurse prescriber, which includes legally controlled drugs.

The role and responsibilities of a nurse who administers medication:

At the start of all assignments the agency nurse must establish local policy and procedures with regards to the administration of medication, however, within the domiciliary environment the patient’s medication plan, the Trusts policy and this policy must be followed.

The legal requirements of a nurse who administers medication:

All registered nurses should be familiar with:

NMC The Code: Professional Standards of Practice and Behaviour for Nurses and Midwives March 2015, is covered in The Code. 

NMC: Standards for Medicines Management 2020,  

Record Keeping Guidance is now covered in The Code.  

All nurses must follow the (COSHH) Control of Substances Hazardous to Health Regulations (2002).

Good practice in relation to these Regulations means nurses must:  

• Ensure hazardous substances (medication) is stored in a safe place
• Understand the actions to take if a spillage occurs
• Ensure medication is not kept and stored after its shelf life
• Have a detailed knowledge about the substances in the medication e.g. corrosive etc.
• Maintain accurate records of receipt of medication, administration and disposal
• Ensure appropriate use of PPE as required

The Misuse of Drugs Act 1971 governs controlled drugs, drugs that are liable to abuse.  The Act states all transactions must be handled by appropriately trained staff and witnessed by another trained staff member.

The Medicines Act 1968 defines ‘medical products’ as substances sold or supplied for administration to humans for medicinal purposes.

A Registered Nurse is responsible for the initial and continued assessment of patients who are self-administering and have continuing responsibility for recognising and acting on changes in a patient’s condition with regards to the safety of the patient and others. In a service user/patients home where arrangements have been made for a parent, carer or service user/patient to administer their own medicinal products, as identified in the care plan, the Nurse should ascertain the service user/patient’s participation in this agreement.

The main aims of a nurse who administers medication:

• To assist the service user to manage their medication regime as effectively as possible by ensuring medication is administered following the ‘six rights’

1. Right patient
2. Right drug
3. Right dose
4. Right route
5. Right time
6. Right to refuse

• To monitor the condition of the service user/patient before, during and after administering the medication
• To document administration, refusal or omission of medication
• To record any medication errors made and escalate as appropriate
• To record any adverse reactions and escalate as appropriate

To minimise the risk of infection:

• Hands should ALWAYS be washed before preparing medication.
• A non-touch technique should ALWAYS be used
• Gloves and an apron should be worn both for the protection of the nurse and the service user/patient if provided.
• Standard infection control procedures should be followed

Establishing consent – please refer to the company’s Consent policy

Administration checklist

Before the administration of medication nurses should check:

• The name of the service user/patient matches the name on the medication
• That consent of the service user/patient has been gained
• The date medication was dispensed
• The dose prescribed
• Time medication is due
• Route prescribed
• Directions for use
• Any precautions
• Name of medication
• Expiry date
• The service user/patients allergy status
• That medication has not already been given
• All special precautions are adhered to e.g. an empty stomach, with food etc.
• That the service user/patient has a drink of water available, if applicable
• The service user/patient is in a safe position to have their medication and their privacy and dignity is being upheld

All these details should also be checked on the Medication Administration Record (MAR) or hospital medication chart before medication is administered.  If in any doubt ask a colleague to double check with you.

Reporting & Recording

All medication administration must be recorded on a Medication Administration Record (MAR) or Hospital medication chart. Any changes, disposal, accident, error etc. must be reported immediately to the ward manager or shift leader.

Records must be legible, understandable, accurate, factual, up-to-date and signed. All records must respect the service user/patient. Remember the Data Protection Act 1998 gives service user/patients the right to access their records.

Respect a service user/patient’s decision if they decide they do not want to take their medication, but explain to them the consequences of not taking the medication. This will need to be documented and reported following the Trust’s policy.

If medication has been administered incorrectly a nurse must:

• Assess the service user’s clinical status and respond to any changes immediately
• Follow the Trusts policy in a hospital environment or for the community follow the Individual Care Plan and TNS Policy
• Inform the senior nurse or doctor immediately
• Record the mistake in detail
• Calmly and carefully inform the service user/patient, and
• Inform Direct Medics of the error ([email protected])

 ALL MEDICATION ERRORS MUST BE REPORTED IMMEDIATELY, BEFORE THE EXACT DETAILS CAN BE FORGOTTEN.

Reporting of Errors – Controlled Drugs

As per above, all medications errors must be reported to Direct Medics Ltd.  In the event that an error involves a controlled drug within Schedules 2, 3, 4 or 5 under the Misuse of Drugs Regulations 2001 (and subsequent amendments), such errors must also be reported to the Care Inspectorate.  Reportable events are as follows:

• Prescribing or dispensing error by e.g. pharmacy or doctor/dentist;
• Prescribed medication not available to be administered;
• Person given wrong medication or dose;
• Medication not recorded as given and no recorded explanation or justification;
• Medication incident/error resulting in injury, referral to the police or Procurator Fiscal;
• Medication incident/error requiring input or advice from healthcare professional, resulting in hospital admission, or considered as an adult or child protection matter;
• Medication incident/error: ‘near miss’ that could have led to injury of harm;
• Medication missing or stolen;
• Medication or controlled drug records falsified;
• Staff referred to professional registration body re: medicines management;
• Staff left during or before investigation re: missing or stolen medication;
• Staff left during or before investigation re: poor practice in management and administration of medication

Storage of Medication

In the acute sector medication should be stored in a lockable cupboard and should always be locked when not in use. It should never be left unlocked and unattended. For medication that needs to be stored in the fridge, there should be a separate lockable fridge to store these medications in.

Controlled drugs should be stored in a separate lockable cupboard.

In the community the service user is responsible for the storage of their medications. Agency workers can advise service users on safe storage, but the service user has the ultimate decision.

Storage of Controlled Drugs in the Community

In the community you should keep in mind the potential, but serious threat presented by the misuse of Controlled Drugs. Service user/patients should be encouraged to keep Controlled Drugs in as secure an environment as possible. If a locked cabinet is available this should be used. In many circumstances this is unlikely to be available; in this instance Controlled Drugs should at least be kept out of sight and reach of children, pets and visitors.

Disposal of medication

There are many reasons medication may need to be disposed of e.g. a service user/patient may pass away, medication may be changed, go out of date or be discontinued etc.  Follow the Trust policy that you are working for to dispose of unwanted medication.

NEVER DISPOSE OF MEDICATION DOWN THE TOILET, IN THE ‘SHARPS’ CONTAINER OR IN HOUSEHOLD WASTE

Always record any disposal on the correct recording sheet.  In the community all medications must be returned to the community pharmacy for disposal. A log must be kept of the medications returned.

Routes of administration of medication

Oral – this includes tablets/capsules, powders, syrups etc. Always take note of the instructions as they may state they need to be taken with food, on an empty stomach, some must be dissolved in water etc. Tablets and capsules should not be crushed, broken or opened (unless there are specific instructions to do so by the prescriber).

Inhalation – breathing in. This is usually via a nebuliser or inhaler for people with respiratory problems. However, there are also other medications available to ‘breathe in’ such as Entonox (also known as gas and air) for pain relief.

Transdermal – this method is used to describe ‘patches’ that are applied to the skin so that the medication is absorbed slowly over a number of hours.

Topical – this is medication that is applied to the skin surface, such as creams and ointments.

Intravenous – this method would only be carried out by an appropriately trained nurse or a doctor. It is direct into the vein of the patient and is designed to act quickly. This method of administration may be via an intravenous infusion pump or via a bolus injection which delivers a one-time dose of medication into the bloodstream.

Sublingual – this is when medicines are sprayed or dissolved under the tongue and not swallowed.

Rectal/Vaginal – Pessaries are inserted into the vagina and suppositories and enemas are inserted rectally. Subcutaneous – this is medication that is injected just beneath the skin e.g. insulin.

Intramuscular – this would only be done by an appropriately trained nurse or doctor. It involves an injection of medication directly into the large muscles of the buttocks, arms or legs. Intra-aural – this medication would be given in the ear.

Intraocular – this is medication that would be given via the eye and comes in the form of drops or ointments.

Naso-Gastric – medication administered through an NG tube into the service user’s stomach.

Gastrostomy – medication administered through a gastrostomy tube surgically inserted into the service user’s stomach.

Naso-Jejunostomy – medication administered through an NJ tube into the service user’s small bowel.

Jejunostomy – medication administered through a JEJ tube surgically inserted into the service user’s small bowel.

Side effects and adverse reactions

Common side effects of medication can include:

• Vomiting
• Nausea
• Diarrhoea
• Constipation
• Dry mouth
• Headache
• Breathing difficulties
• Stiffness
• Swelling
• Rash
• Shaking
• Drowsiness
• Weight gain

Please note that a mild reaction could worsen and develop into a severe reaction if medication is administered again. Severe adverse reactions could include:

• Sweating, blotches, redness of the skin or a feeling faint
• Difficulty breathing
• Swelling of hands, face and body

These symptoms are a medical emergency – expert help should be sought immediately. If your service user/patient displays any of the symptoms above it is important this is recorded and reported. Always follow the Trusts policy. The service user/patient will need to be observed and you may need to treat the symptoms. In an emergency you may need to resuscitate the service user/patient.

The purpose of this policy is to set out what actions are required of staff working through Direct Medics (Scotland) Ltd when dealing with adult protection and to ensure effective links with the relevant local authority Inter Agency Adult Support and Protection Procedures.    

This document should be read in conjunction with the relevant local Inter Agency Adult Protection Procedures. This can be sourced from the relevant local authority and should be available at your service.  

Introduction

1.1 The protection of adults at risk of harm is not an option but a responsibility across agencies. The expectation for all “at risk” adults in our communities is that they are empowered, through support from all the public services including social work services, police, health, housing and care organisations to be free from any preventable harm or exploitation. They are enabled to make their own choices about their lives and to live as independently as their personal circumstances may permit. Direct Medics (Scotland) Ltd is committed to enabling disabled people to live life to the fullest by the provision of seamless person-centred housing and support services.  

Nursing Staff will adhere to both our clients’ policies and procedures that are in parallel to Direct Medics (Scotland) Ltd, encompassing all that is required for each individual placement booking. Where the Client’s policies and procedures are more stringent than those of Direct Medics (Scotland) Ltd, it is assumed that staff will adhere to the Client policies and procedures. 

Adult Support Protection Training is deemed as mandatory at Direct Medics (Scotland) Ltd before agency staff are allowed to work. Direct Medics (Scotland) Ltd adheres to safe recruitment guidance and to a robust recruitment process. 

1.2 It is the policy of Direct Medics (Scotland) Ltd to support and protect adults at risk of harm, and the safeguarding and promoting of the interests and well-being of such adults is of paramount concern to the organisation.  

1.3 Direct Medics (Scotland) Ltd will ensure that staff will be alert to the possibility that they may become aware of adults requiring support and protection who are not persons e.g. relatives, friends, visitors etc. In all cases staff will report their concerns using the Direct Medics Ltd reporting procedures contained within this document.  

1.4 Direct Medics (Scotland) Ltd recognises that the protection of adults at risk of harm is placed above all other operating principles and supersedes the principle of confidentiality in relation to disclosure to the relevant authorities.  

1.5 Direct Medics (Scotland) Ltd undertakes to ensure that any staff working on behalf of the company to deliver a care service is aware of and has access to this policy.  

Legislation

2.1 In Scotland, there are three Acts of the Scottish Parliament which relate specifically to adult protection. These are:

• Adults with Incapacity (Scotland) Act, 2000. This Act imposes duties on, and assigns functions to, local authorities in relation to the making of enquiries in respect of adults who lack capacity, and the creation, application and supervision of proxy decision making powers in respect of such adults. Under the terms of Section 10 of the Adults with Incapacity (Scotland) Act 2000, the local authority must investigate ‘any circumstances made known to them in which the personal welfare of an adult seems to be at risk’ This means that, the local authority must investigate allegations of abuse involving an adult who lacks the capacity to make or convey decisions for him or herself, whether the adult concerned agrees to the investigation or not. It is the function of the Public Guardian to investigate situations of suspected financial abuse involving adults who lack capacity under Section 6 of the same Act.  
• Mental Health (Care & Treatment) Scotland Act, 2003. This Act imposes duties on, and assigns functions to, local authorities and health boards in respect of social and mental health well-being, the making of enquiries in respect of persons who appear to have a mental disorder, and (where necessary) the application of compulsory measures in relation to the assessment and treatment of persons having a mental disorder. 
• Adult Support and Protection (Scotland) Act 2007. This Act imposes duties on, and assigns functions to, local authorities in respect of the making of enquiries, the conduct of investigations, the application for protective powers in respect of adults defined by the legislation to be at risk of actual or suspected harm. This Act also brought about the creation of Adult Protection Committees in every local authority area.  

2.2 It is the responsibility of adult protection agencies such as Social Work Services and the Police to make enquiries (proactive and reactive) and to carry out appropriate investigations to establish:

a) whether or not an adult is at risk from harm or suspected harm; and, if so, 

b) which, if any, of the protective measures available in terms of the legislation are most appropriate to an adult at risk’s individual circumstances.

2.3 It is, however, everyone’s responsibility to report concerns regarding any adult who is, or who appears to be, at risk of harm to Social Work Services. If you are concerned that a vulnerable adult is at risk of exposure to criminal activity such as fraud, then Police must be notified as well as Social Work. However, to avoid confusion and to have clear lines of accountability, Direct Medics (Scotland) Ltd staff should report concerns directly to the Line Manager on-site in the first instance. The procedure outlined at Section B sets out the reporting guidelines.  

2.4 For the purposes of the Adult Support & Protection (Scotland) Act 2007 (“ASP Act”), an “adult” is a person aged 16 or over. However, if the adult concerned is 16 or 17 years of age, it is possible that s/he is already subject to a Supervision Order or other Order under the Children (Scotland) Act, 1995, or other social work or childcare legislation Procedures (as per your Local Authority/Council. If Direct Medics Ltd staff know that such an Order is in place in respect of that person, they should include that information in their report to the Line Manager on-site. It is the responsibility of Social Work Services to carry out any investigations about anyone who may be subject to such an Order. The procedure outlined at Section B sets out the reporting guidelines.  

2.5 Under the Adult Support and Protection (Scotland) Act 2007 ’adults at risk’ are defined as adults aged 16 or over who a) are unable to safeguard their own well-being, property, rights or other interests, b) are at risk of harm, and c) because they are affected by disability, mental disorder, illness or physical or mental infirmity, are more vulnerable to being harmed than adults who are not so affected.  

2.6 The ASP Act states harm includes all harmful conduct and includes:  

• Conduct which causes physical harm  
• Conduct which causes psychological harm (for example by causing fear, alarm or distress)  
• Unlawful conduct which appropriates or adversely affects property, rights or interests (for example: theft, fraud, embezzlement or extortion)
• Conduct which causes self-harm.  

Factors which may indicate harmful behavior towards and adult at risk

3.1 These can include one or a combination of the following actions. The following indicators must, however, be used only as a guide.  

3.2 Harm can be a single or repeated act or lack of appropriate action, occurring within any relationship where there is an expectation of trust, which causes harm or distress to an adult. It can take the form of physical, sexual, emotional, psychological or domestic abuse, acts of neglect or omission, financial and material abuse and the withholding of information. The abuse can be multiple, involving some or all the above.  

3.3 Harm can occur in any setting: when an adult lives alone or with a relative; within nursing, residential, supported living or day care settings; in hospitals, custodial situations, support services in people’s own homes and other places previously assumed safe, or in public places.  

3.4 On some occasions the perpetrator of the abuse might be at risk of abuse themselves; such as a person who regularly becomes inebriated and puts other persons or members of staff into a state of fear. All parties involved can be considered as being potentially at risk however the person behaving abusively can also be treated as an adult at risk.  

3.5 There is an expectation where the perpetrator of abuse is a member of staff that an internal investigation will not take precedence over reporting concerns to allow an investigation by Social Work Services and/or Police. The procedure outlined at Section B sets out the reporting guidelines.  

Types of Harm

4.1 Physical Abuse- involving actual or attempted injury to an adult defined as at risk. For example:  

• Physical assault by punching, pushing, slapping, tying down, giving food or medication forcibly, or denial of medication
• Use of medication other than as prescribed 
• Inappropriate restraint.  

4.2 Emotional/Psychological /Trauma Abuse- resulting in mental distress to the adult at risk. For example:  

• Excessive shouting, bullying, humiliation 
• Manipulation of, or the prevention of access to, services that would be of benefit to the adult 
• Isolation or sensory deprivation
• Denigration of culture, religion, gender, age or sexuality 

4.3 Financial or Material Abuse- involving the exploitation of resources and property belonging to the adult at risk. For example:  

• Theft or Fraud
• Misuse of money, property or resources without the informed consent of the adult at risk. 

4.4 Sexual Abuse- involving activity of a sexual nature where the adult at risk cannot or does not give consent. For example:  

• Incest
• Rape
• Acts of gross indecency
• Inappropriate touching or verbal or physical sexual harassment.  

4.5 Neglect and acts of omission by others charged with the care of the adult, including ignoring medical or physical care needs. For example:  

• Failure to provide access to appropriate health, social care or educational services  
• Withholding of the necessities of life such as nutrition, appropriate heating, etc.  

4.6 Exploitation- the deliberate targeting of vulnerable adults for personal benefit.  

4.7 Discriminatory abuse- for example, treating one person less favourably than another.  

4.8 Information abuse- deliberately giving erroneous information or withholding information.  

4.9 Human rights abuse- for example deprivation of a right to family life or to a fair hearing.  

4.10 Multiple Forms of Abuse- This may occur in an ongoing relationship or service setting or to more than one person at a time. It is important therefore to look not only at a single incident, but to also consider the underlying dynamics and patterns of harm  

4.11 Random Violence- An attack by a stranger on an adult defined as at risk is an assault; this is a criminal matter and should be reported to the Police. However, where there is the possibility that the violence may be part of a pattern of victimisation in a community or neighbourhood, local authority Adult Protection procedures may also apply in respect of effective multi-agency intervention. 

4.12 Domestic Violence- Strathclyde Police define domestic violence as “any form of physical, non-physical or sexual abuse which takes place within the context of a close relationship committed either in the home or elsewhere”. In most cases this relationship will be between partners (married, cohabitating or otherwise) or ex-partners. The similarity between the above acts of harm in relation to adult protection is recognised. However, the key factor in relation to activating adult protection procedures in such situations is that the victim (or suspected victim) must be an adult at risk of harm as defined in The Act.  

Confidentiality

5.1 There is a clear requirement across agencies to co-operate in relation to the protection of adults seen to be at risk of harm.  Direct Medics (Scotland) Ltd will also ensure that appropriate mechanisms are in place in relation to any immediate or ongoing involvement and assistance by us, in consultation with the relevant statutory agencies, towards effective risk management and continuing support to the person.  

5.2 Direct Medics (Scotland) Ltd staff have a duty to report concerns about an adult thought to be at risk of harm (as defined in the ASP Act). Failure to do so may result in disciplinary action.  

5.3 Where an adult is seen to be at risk of harm, this will always override a professional or organisational requirement to keep information confidential, subject to the provisions of GDPR legislation. However, the disclosure should be limited to the relevant parties only. It is the responsibility of those employed or involved with Direct Medics (Scotland) Ltd to take appropriate action to ensure the adult deemed to be at risk is protected from harm.  

SECTION B DIRECT MEDICS (SCOTLAND) LTD, ADULT SUPPORT AND PROTECTION PROCEDURE

This procedure details the action you should take on suspecting harm or poor practice to ensure the welfare and safety of adults at risk of harm. 

Responsibilities of Direct Medics Ltd Staff

1.1 Any report that an adult may be at risk of harm, including anonymous referrals, should be taken seriously. All cases should be considered with an open mind. In all instances, the information given must be reported immediately to your Line Manager on-site.   

1.2 In the event that you become aware that an adult may be at risk of harm, or you are told directly by a person that they are being/have been abused, you should be aware that the adult may be feeling vulnerable or upset when disclosing this information. 

1.3 You should be supportive and reassure the adult by listening carefully, but do not ask unnecessary questions. It is not your role to investigate.  

1.4 You should take steps to ensure the safety of the adult at risk involved. 

Reporting

2.1 You should advise the adult that the information will have to be passed on to your Line Manager on-site and that Social Work Services may be required to investigate further.  

2.2 When you feel it is appropriate to leave the person who is disclosing the abuse, the information given by the person should be passed on immediately to your Line Manager on-site.  

2.3 Where you are concerned for the immediate safety and well-being of a person, contact emergency services i.e. ambulance and Police immediately. Do not delay. You can contact your Line Manager on-site once you are satisfied that the person is safe.  

2.4 If you suspect that abuse has taken place you should contact the Police immediately and steps should be taken to preserve evidence. You can then contact your Line Manager on-site who will contact the relevant local authority.  

2.5 If you are unhappy with the response from your Line Manager on-site, you should contact Social Work Services directly at the appropriate office and outline your concerns and the basis for them.  

2.6 If you are unhappy with the response from Social Work Services you can raise this with the Direct Medics (Scotland) Ltd Nursing Manager who inform the Care Inspectorate if necessary.  

NOTE: You should follow the above procedure for all instances of suspected abuse, for example where you become aware of 

• Abuse by another person
• Abuse by someone from within the community (family or friend)
• Abuse by a member if staff

Recording

3.1 Write down the nature of your concern and anything the person may have told you using, as far as possible, the words used by the person. Remember to sign and date the notes taken by both staff member and vulnerable adult (if appropriate). This information will form the basis of the referral and will also be required if there is an investigation. As much information as possible should be recorded, please record the facts only and no opinions or assumptions should be included.  

3.2 Any physical evidence should be preserved if possible.  

Allegations involving other site staff

4.1 If you have observed other staff acting in a way that has caused you to be concerned you should contact the Line Manager on-site outlining your concerns and the basis for them. They will take your concerns seriously, make appropriate enquires into them and thereafter decide on the appropriate course of action.  

4.2 If your concerns are about your Line Manager on-site, then you should inform their manager, or contact social work directly to pass on your concerns and seek further advice.  

4.3 In situations where the alleged abuser is a member of staff, Direct Medics (Scotland) Ltd Disciplinary Procedures should be followed, but will not supersede an adult protection referral or investigation by statutory agencies. In other words, care must be taken to ensure that implementation of any internal procedures (for example, fact finding) does not undermine or impede any investigation externally by statutory agencies.  

4.4 In such cases the Scottish Social Services Council will be contacted by the appropriate Manager on-site.  Direct Medics (Scotland) Ltd Whistleblowing policy is available as required and can be found in your policy handbook.  

Frequent Complaints without Foundation

5.1 A situation where a person makes frequent complaints alleging abuse, which after full investigation are found to be vexatious, cannot be ignored. In such cases it is good practice to always follow the above reporting procedures. The allegation must be reported to their care manager and the pattern of allegations must be reviewed regularly in case abuse is taking place.  

Next steps

6.1 Once they have received a referral, it is the duty of Social Work Services to make enquiries and to investigate matters of concern in relation to the protection of an adult deemed to be at risk of harm as defined by the legislation. Where it is alleged that a crime has been committed against the adult, investigation is likely to be progressed jointly in consultation with the Police.   

6.2 The investigating officers may need to speak to the staff member from whom the concerns originated. Managers and staff of Direct Medics Ltd will co-operate fully with any Police or Social Work Services enquiries, and managers will ensure staff are facilitated in this.  

6.3 The Care Inspectorate will be contacted by the Direct Medics (Scotland) Ltd Nursing Manager to report incidents of abuse reported by its staff.

Supporting the Adult at Risk of Harm

7.1 It is important that all employees and those involved directly with the adult seen to be at risk of harm act throughout in a facilitating and supportive manner. Staff should avoid being judgemental and should not introduce personal or third-party experiences of harm. Every effort should be made to enable the adult to express their wishes and to make decisions to the best of their ability where appropriate, but, within a duty of care, the overriding concern is the protection of the adult from harm.  

7.2 The person you are supporting is likely to continue to be involved with Direct Medics (Scotland) Ltd following the reporting of the concerns. Links should be maintained with the Social Work Services office involved in any investigation, to offer the appropriate support to the person.  

Supporting Direct Medics (Scotland) Ltd staff

The staff involved will be offered support and counselling as appropriate. 

Adult Safeguarding Champion

The company’s Adult Safeguarding Champion is the Nurse Manager 

Their key responsibilities include: 

1. To provide information, support and advice for staff and/or volunteers on adult safeguarding within the organisation; 
2. To ensure that the organisation’s adult safeguarding policy is disseminated and support implementation throughout the organisation. 
3. To advise the organisation regarding adult safeguarding training needs. 
4. To provide advice to staff or volunteers who have concerns about the signs of harm and ensure a report is made to HSC Trusts where there is a safeguarding concern. 
5. To support staff to ensure that any actions take account of what the adult wishes to achieve – this should not prevent information about risks of serious harm being passed to the relevant HSC Trust Safeguarding Team for assessment and decision making. 
6. To establish contact with the HSC Trust Designated Adult Protection Officer (DAPO), Police Scotland and other agencies as appropriate.  
7. To ensure accurate and up to date records are maintained detailing all decisions made, the reasons for those decisions and any actions taken.
8. To compile and analyse records of reported concerns to determine whether several low-level concerns are accumulating to become more significant. These records must be available on request for inspection or by way of service level agreements or contract review meetings.   
9. To inform the Care Inspectorate and NMC as appropriate. 

Introduction

Direct Medics (Scotland) Ltd is committed to the protection of children and regards the safeguarding and promoting of the interests and wellbeing of children as of paramount concern. We are also committed to the protection of vulnerable children from exploitative relationships.  Direct Medics (Scotland) Ltd consider it the duty of all those employed or involved with the organisation, to prevent the physical, sexual or emotional abuse or neglect of all children with whom they come into contact, including reporting any abuse discovered or suspected.  

Who needs protection?

Children and young people under the age of 16.  

What is child abuse?

The definition of child abuse adopted in Scottish Government guidance states: “Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting, or by failing to act to prevent, significant harm to the child. Children may be abused in a family or in an institutional setting, by those known to them or, more rarely, by a stranger. Assessments will need to consider whether abuse has occurred or is likely to occur.” 

Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by inflicting, or by failing to act to prevent, significant harm to the child. Children may be abused in a family or in an institutional setting, by those known to them or, more rarely, by a stranger. Assessments will need to consider whether abuse has occurred or is likely to occur. Any information must be seen in the context of the child or young person’s whole situation and circumstances. It is still helpful to consider and understand the different ways in which children can be abused. The National Child Protection Guidance 2014 gives additional information on dealing with specific concerns that may impact adversely on children and young people. The guidance refers to areas of risk such as  

• Child Sexual Exploitation 
• Child Trafficking  
• Non-Engaging Families  
• Children and Young People Placing Themselves At Risk  
• Children and Young People Affected By Domestic Abuse 

The following definitions show some of the ways in which abuse may be experienced by a child but are not exhaustive, as the individual circumstances of abuse will vary from child to child. Different types of abuse may overlap or co-exist. The following definitions are all taken from National Guidance for Child Protection in Scotland 2014.  

Physical Abuse

Physical abuse is the causing of physical harm to a child or young person. Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning or suffocating. Physical harm may also be caused when a parent or carer feigns the symptoms of, or deliberately causes, ill health to a child they are looking after.  

Signs of possible physical abuse:

• Unexplained injuries or burns, particularly if they are recurrent; 
• Improbable excuses given to explain injuries;  
• Refusal to discuss injuries; 
• Untreated injuries or delay in reporting them;  
• Excessive physical punishment; 
• Arms and legs kept covered even in hot weather; 
• Fear of returning home;
• Aggression towards others;  
• Running away; 
• Administration of toxic substances.  

Neglect

Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. It may involve a parent or carer failing to provide adequate food, shelter and clothing, to protect a child from physical harm or danger, or to ensure access to appropriate medical care or treatment. It may also include neglect of, or failure to respond to, a child’s basic emotional needs. Neglect may also result in the child being diagnosed as suffering from “non-organic failure to thrive‟, where they have significantly failed to reach normal weight and growth or development milestones and where physical and genetic reasons have been medically eliminated. In its extreme form children can be at serious risk from the effects of malnutrition, lack of nurturing and stimulation. This can lead to serious long-term effects such as greater susceptibility to serious childhood illnesses and reduction in potential stature. With young children in particular, the consequences may be life-threatening within a relatively short period of time  

Signs of possible physical neglect:  

• Constant hunger or inappropriate/ erratic eating patterns; 
• Poor personal hygiene; 
• Constant tiredness; 
• Lack of adequate clothing; 
• Failure to seek appropriate/necessary medical attention;  
• Unhygienic home conditions. 

Emotional Abuse

Emotional abuse is persistent emotional neglect or ill treatment that has severe and persistent adverse effects on a child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate or valued only insofar as they meet the needs of another person. It may involve the imposition of age- or developmentally inappropriate expectations on a child. It may involve causing children to feel frightened or in danger or exploiting or corrupting children. Some level of emotional abuse is present in all types of ill treatment of a child; it can also occur independently of other forms of abuse. 

Signs of possible emotional abuse:

• Low self-esteem;  
• Continual self-deprecation; 
• Sudden speech disorder/refusal to speak;
• Fear of carers;  
• Severe hostility/aggression towards other children; 
• Significant decline in concentration span;  
• Self-harm. 

Sexual Abuse

Sexual abuse is any act that involves the child in any activity for the sexual gratification of another person, whether it is claimed that the child either consented or assented. Sexual abuse involves forcing or enticing a child to take part in sexual activities, whether the child is aware of what is happening. The activities may involve physical contact, including penetrative or non-penetrative acts. They may include noncontact activities, such as involving children in looking at, or in the production of, pornographic material or in watching sexual activities, using sexual language towards a child or encouraging children to behave in sexually inappropriate ways.  

Signs of possible sexual abuse:

• Sleep disturbances or nightmares;
• Complaints of genital itching or pain; 
• Self-harm; 
• Eating disorders; 
• Unexplained pregnancy; 
• Acting in sexually explicit manner;  
• Anxiety / depression / withdrawn;  
• Fear of undressing e.g. for physical exercise;  
• Low self-esteem;
• Inappropriate sexual awareness; 
• Running away; 
• Developmental regression;  
• Lack of trust in adults or over familiarity with adults. 

Significant Harm

Significant harm can result from a specific incident, a series of incidents or an accumulation of concerns over a period. It is essential that when considering the presence or likelihood of significant harm that the impact (or potential impact) on the child takes priority and not simply the alleged abusive behaviour to understand and identify significant harm, it is necessary to consider:  

• the nature of harm, either through an act of commission or omission; 
• the impact on the child’s health and development, considering their age and stage of development; 
• the child’s development within the context of their family and wider environment; 
• the context in which a harmful incident or behaviour occurred;  
• any needs, such as a medical condition, communication impairment or disability, that may affect the child’s development, make them more vulnerable to harm or influence the level and type of care provided by the family;  
• the capacity of parents or carers to meet adequately the child’s needs; and  
• the wider and environmental family context

What to do if you think a child or young person is at risk of abuse

• Be supportive to the child or young person. Listen with care, but do not ask any unnecessary questions. Take what the child or young person is saying seriously, and advise them you will have to pass the information on;  
• Immediately report the grounds of your concern to the named person responsible for child protection within the Client organisation (if you are unsure as to who the appropriate person is, seek advice from the Nursing Manager at Direct Medics (Scotland) Ltd.).  The contact details for the named person responsible for child protection for the Client organisation (or, where appropriate for each section of the organisation) should be made available to you at induction stage and is normally displayed within the Ward or unit.  The named person will take steps to pass the information on to the relevant organisation(s) who will investigate the concerns. Do not delay in reporting your concerns. Where possible, advise the named person in the Client organisation on the same day the concern arises; and  
• Write down the nature of your concern and anything the child or young person may have told you using, so far as possible, the words used by the child or young person. Remember to sign and date the notes taken;  
• If you are unhappy with the response from the named person, you should contact the local Social Work Services Office and outline your concerns and the basis for them.  When the local office is closed, the Emergency Social Work Service should be alerted. All telephone calls should be followed up in writing within 48 hours.  If you are unhappy with the response from Social Work Services, you can contact Police Scotland or the Reporter to the Children’s Panel and outline your concerns to them.   

Confidentiality  

If a child or young person may be at risk of harm, this will always override a professional or organisational requirement to keep information confidential. Those employed or involved with Direct Medics Ltd. have a responsibility to act to make sure that a child whose safety or welfare may be at risk is protected from harm. Children, young people and their parents will always be told this.  

What happens next?  

It is the duty of Social Work Services to investigate matters of concern in relation to the protection of the child or young person. Where it is alleged, a crime has been committed against a child, the matter is likely to be investigated jointly with the Police. The investigating Social Worker / Police Officer may require speaking to the person with whom the concerns originated. You should co-operate fully with any future enquiries.  

What to do in an emergency  

If you are concerned about the immediate safety of a child, for example a child at risk of immediate harm or injury, contact Police Scotland immediately. Do not delay, as this could result in serious injury to a child.  

What if it is someone within the Client organisation that you are concerned about?  

If you have observed a member of the Client organisation acting in a way that has caused you to be concerned, and feel the matter needs to be investigated you should contact the named person responsible for child protection within the Client organisation (if you are unsure as to who the appropriate person is, seek advice from the Nursing Manager at Direct Medics (Scotland)Ltd.).  Outline your concerns and the basis for them. The named person will take your concerns seriously and decide on an appropriate course of action. This may involve the use of the organisation's disciplinary procedures and / or a referral to Social Work Services / Police.  If the concerns involve the manager / named person, this should be reported to the Director / Chief Executive of the Client organisation or to Social Work Services / Police.  

What to do if you have general welfare concerns about a child  

There are many circumstances that may cause harm to a child, and require a response, but fall short of a concern that a child is being abused. Nevertheless, a build-up of concerns over time may in time become serious enough that the child is at risk of abuse. Where you have general welfare concerns about a child you should:  

• Address the incidents as they arise with the parents/carers, within the practice guidance of the Client organisation;
• Discuss your concerns with your line manager within the Client organisation; 
• Record your actions and note your concern on the chronology of significant events or equivalent monitoring mechanism within the Client organisation.  

Training and awareness

Employees / volunteers will be made aware of the existence of the Child Protection Policy, and their responsibilities in relation to the child protection process. For example:  

• Through the provision of training  
• By issuing a copy of the policy to all new staff members.  

Direct Medics (Scotland) Ltd. understands that comprehensive, up-to-date knowledge of clinical skills procedures is a fundamental aspect of nursing care. This includes the underlying theory and evidence for procedures related to every aspect of a person′s care, aimed at enabling nurses to deliver the highest level of clinically effective, patient–focused care.  The company believes that, in maintaining practices that encourage agency staff to consistently update and maintain their knowledge in clinical nursing procedures, nurses thus gain the confidence they need to remain safe, informed and skilled practitioners. 

Standards for competence of a Registered Nurse 

Managing the Patients Journey: 

• Admission and Assessment  
• Discharge care and planning 
• Infection prevention and control

Supporting patients with human functioning: 

• Communication, psychological wellbeing and safeguarding 
• Elimination 
• Moving and positioning  
• Nutrition and fluid balance 
• Patient comfort and supporting personal hygiene 
• Pain assessment and management  
• Symptom control and care towards the end of life 
• Respiratory care, CPR and blood transfusion 

Supporting patients through the diagnostic process: 

• Diagnostic tests 
• Observation 

Supporting patients through treatment: 

• Medicines optimization: ensuring quality and safety 
• Perioperative care 
• Vascular access devices: insertion and management 
• Wound Management  

Looking after ourselves so we can support patients: 

• Self-care and wellbeing  

Addressing knowledge of procedures concerned with the above headings form the basis of annual appraisals for agency staff.  To assist staff both in terms of maintaining their knowledge and in preparing for appraisal, the Royal Marsden Hospital Manual of Clinical Nursing Procedures 10th Edition is recommended to all nurses in line with NMC 2018 'Future Nurse: Standards of Proficiency for Registered Nurses' guidance. This Manual contains the procedures and changes in practice that reflect modern acute nursing care its updated evidence underpins all procedures it is organised and structured to represent the needs of a patient along their care pathway.  This is recommended particularly to those nurses returning to clinical practice following a period of absence, by way of enhancing their induction back into their nursing practice; Nurses must maintain the ‘Standards of Competence’ throughout their career to remain on the register NMC 2015 this is measured through Revalidation. 

Although the broad topics listed above do not tend to see much variation between organisations in terms of procedures undertaken, nurses must be aware that some hospitals or institutions may have their own local policies, assessment forms and clinical guidelines in place.  Agency staff should be aware that some local variation could exist, however the company expects its client organisations to make agency staff aware of such practices.  

Direct Medics (Scotland) Ltd. requests all relevant data from its clients in advance of booking and will provide all agency staff with information received. 

Direct Medics Ltd. endeavour to provide the highest quality of service to all individuals and bodies that we work with. Information from complaints is used to improve the quality of its services. In the event that a client believes the service to be unsatisfactory, the complaint can first be initially raised informally with the company via a Nursing Recruitment Consultant.  Formal complaints to the company must detail the issue, previous attempts to resolve by informal means and contact details (email address and phone number) and should be submitted in writing to our Nursing Manager via post or email at the following address:

Suite 103-104 Baltic Chambers,
40-60 Wellington Street,
Glasgow,
Scotland,
G2 6HJ

[email protected]

All formal complaints will be dealt with as follows: 

1. The complainant will receive written acknowledgement within 5 working days; 
2. We may contact the complainant to clarify the detail of the complaint and to discuss it with them (any verbal contact will be followed up in writing); 
3. Within 20 working days after the date on which the complaint is made, or such shorter period as may be reasonable in the circumstances, we will inform the complainant of the action (if any) that is to be taken. 

Throughout the investigation we will be careful to ensure that any information about the complainant is kept confidential and steps will then be taken, where possible, to prevent a reoccurrence. 

THE ROLE OF THE CARE INSPECTORATE

Care services in Scotland must be registered with Social Care and Social Work Improvement Scotland, more commonly known as the Care Inspectorate; therefore nursing placements made by Direct Medics Ltd, within Scotland are governed by the standards of the Care Inspectorate.

Where a complaint relates to a failure by Direct Medics Ltd. to comply with the statutory regulations clients can contact the Care Inspectorate directly.   Please see address details below:

Care Inspectorate
Compass House
11 Riverside Drive
Dundee
DD1 4NY

The Care Inspectorate is a scrutiny body which supports improvement. That means the body looks at the quality of care in Scotland to ensure it meets high standards. The Care Inspectorate is required by the Regulatory Reform (Scotland) Act 2014 to follow the Scottish Regulators’ Strategic Code.

At any point through this process, a client may require that an independent advocacy services be engaged with in an attempt to resolve outstanding issues fairly.  If required assistance will be provided to any clients requiring help to access the support needed need to articulate concerns and successfully navigate the system.

The company keeps records of all complaints and including details of all communications with complainants, the results of any investigations and the action taken.  When required, a summary of all complaints, outcomes and actions taken is made available to the Care Inspectorate.

The company co-operates with any complaints investigation carried out by all relevant statutory bodies as necessary, for example:

• Scottish Social Services Council (SSSC)
• Nursing and Midwifery Council (NMC)
• Education Scotland (formerly HM Inspectorate of Education)
• Health and Safety Executive
• Healthcare Improvement Scotland (HIS)
• Local authorities
• Police Scotland
• Audit Scotland
• Scottish Housing Regulator
• Registrar of Independent Schools
• Fire and Rescue Services
• Mental Welfare Commission for Scotland
• Scottish Public Services Ombudsman (SPSO)

COMPLAINTS ABOUT A PUBLIC SERVICE

Direct Medics Ltd supplies to NHS clients in Scotland; as such, any complaints about an Client should be made by first contacting the Care Inspectorate concerned.

If, having followed the NHS Complaints procedure, the complainant remains unsatisfied the matter can be referred to The Scottish Public Services Ombudsman (SPSO), which is the final stage for complaints about councils, the National Health Service, housing associations, colleges and universities, prisons, most water providers, the Scottish Government and its agencies and departments and most Scottish authorities.  SPSO don’t usually look at complaints if the matter occurred more than a year ago, or has been dealt with in court.

COMPLAINTS ABOUT CANDIDATES

When a complaint is reported to the company concerning a candidate, the following steps are completed:

1. A complaints case file is opened, with an entry on the Complaint Log created alongside a separate file folder in which to store documents specific to the complaint;
2. The complaint is reported to the Nursing Manager who is responsible for overseeing follow-up and close-off in collaboration with the candidate, Direct Medics staff service users and/or regulatory bodies as appropriate;
3. All relevant documents are stored in the appropriate case file folder, and a log of contacts and close-off is stored in the Complaint Log;
4. At close-off, the candidate’s appraisal and supervision schedule is reviewed by the Nursing Manager, with any adjustment to the schedule in light of the complaint, in addition to any enhancement to quality monitoring, at the Nursing Manager’s discretion.

Good record keeping is a vital part of effective communication in nursing and integral to promoting safety and continuity of care for patients and clients.

Agency staff need to be clear about their responsibilities for record keeping in whatever format records are kept.

Key principles

• Records should be completed at the time or as soon as possible after the event.
• All records must be signed, timed and dated if handwritten. If digital, they must be traceable to the person who provided the care that is being documented.
• Ensure that you are up to date in the use of electronic systems in your place of work, including security, confidentiality and appropriate usage.
• Records must be completed accurately and without any falsification and provide information about the care given as well as arrangements for future and ongoing care.
• Jargon and speculation should be avoided.
• When possible, the person in your care should be involved in the record keeping and should be able to understand what the records say.
• Records should be readable when photocopied or scanned.
• In the rare case of needing to alter a record, the original entry must remain visible (draw a single line through the record) and the new entry must be signed, timed and dated.
• Records must be stored securely and should only be destroyed following your local policy.

Countersigning

• Nursing record keeping can be delegated to health care assistants (HCAs), assistant practitioners (APs) and nursing students so that they can document their care. 
• As with any delegated activity, the nurse needs to ensure that the HCA, AP or student is competent to undertake the activity and that it is in the patient’s best interests for record keeping being delegated. 
• Nursing - Supervision and a countersignature are required until the HCA, AP or student is deemed competent at keeping records. 
• Registered nurses should only countersign if they have witnessed the activity or can validate that it took place 
• Always follow your local policy, further guidance can be found within the document “NMC Record keeping for Nurses and Midwives”. 

The Data Protection Act 1998 defines a health record as “consisting of information about the physical or mental health or condition of an identifiable individual made by or on behalf of a health professional in connection with the care of that individual”.

The principles of good record keeping apply to all types of records, regardless of how they are held. These can include:

• handwritten clinical notes
• emails
• letters to and from other health professionals
• laboratory reports
• x-rays
• printouts from monitoring equipment
• incident reports and statements
• photographs
• videos
• tape-recordings of telephone conversations
• text messages

Failure to maintain records could potentially cause considerable difficulties in respect of any legal proceedings, e.g. an allegation of negligence. Information is essential to the delivery of high quality evidence-based health care on a day-to-day basis. Records are a valuable resource because of the information they contain. This information can facilitate clinical decision making, improved patient care through clear communication of the treatment rationale and progress, and facilitate a consistent approach to team working. However, a record is only of use if it is correctly recorded in the first place, regularly up-dated, and easily accessible when it is needed. Everyone working in healthcare that records, handles, stores, or otherwise comes across information, has a personal common law duty of confidence to comply with this.

All patient attendance, non-attendance, and refusal of treatment and advice must be noted. It is advisable to note when telephone contacts are made. It is imperative that the agency worker dealing with a particular patient on a specific day can be identified; this means the patient’s attendance is dated and signed either in the agency workers records or on a register, or both. All patient records should be kept confidential in line with the Data Protection Act 1998.

Records Management

You must treat information about patients and clients as confidential and use it only for the purpose for which it was given. You must guard against breaches of confidentially by protecting information from improper disclosure at all times. Where there is an issue of child protection you must act at all times in accordance with national and local policies.

All records relating to the provision of our service are to kept for a period of eight years. Each client has an absolutes right to confidentiality and privacy regarding the services they are receiving in accordance with Data Protection Act 1998 and Human Rights Act 1999 and your agreement with the Company. Any concerns you may have regarding confidentiality can be discussed with our Nursing Manager.

As a healthcare professional, you owe a duty of confidentiality to all those who are receiving care. This includes making sure that they are informed about their care and that information about them is shared appropriately. To achieve this, you must:  

1. respect a person’s right to privacy in all aspects of their care;
2. make sure that people are informed about how and why information is used and shared by those who will be providing care;
3. respect that a person’s right to privacy and confidentiality continues after they have died;
4. share necessary information with other healthcare professionals and agencies only when the interests of patient safety and public protection override the need for confidentiality, and;
5. share with people, their families and their carers, as far as the law allows, the information they want or need to know about their health, care and ongoing treatment sensitively and in a way they can understand.

A duty of confidence arises when one person discloses information to another in circumstances where it is reasonable to expect that the information will be held in confidence. This duty of confidence is derived from:

• common law – the decisions of the Courts
• statute law which is passed by Parliament.

The common law of confidentiality reflects that people have a right to expect that information given to a healthcare professional is only used for the purpose for which it was given and will not be disclosed without permission. This covers situations where information is disclosed directly to the healthcare professional and to information that the healthcare professional obtains from others. One aspect of privacy is that individuals have the right to control access to their own personal health information.  

It is not acceptable for healthcare professionals to:  

• discuss matters related to the people in their care outside the clinical setting
• discuss a case with colleagues in public where they may be overheard
• leave records unattended where they may be read by unauthorised persons.

All healthcare professionals need to be aware of the following pieces of legislation relating to confidentiality:  

The Data Protection Act 1998: This Act governs the processing of information that identifies living individuals. Processing includes holding, obtaining, recording, using and disclosing of information and the Act applies to all forms of media, including paper and electronic.  

The Human Fertilisation and Embryology Act 1990: Regulates the provision of new reproductive technology services and places a statutory ban upon the disclosure of information concerning gamete donors and people receiving treatment under the Act. Unauthorised disclosure of such information by healthcare professionals and others has been made a criminal offence.  

The National Health Service Venereal Disease Regulations (SI 1974 No.29): This states that health authorities should take all necessary steps to ensure that identifiable information relating to persons being treated for sexually transmitted diseases should not be disclosed.  

The Mental Capacity Act (2005): This provides a legal framework to empower and protect people who may lack capacity to make some decisions for themselves. The assessor of an “individual’s capacity to make a decision will usually be the person who is directly concerned with the individual at the time the decision needs to be made” this means that different health and social care workers will be involved in different capacity decisions at different times.  

The Freedom of Information Act 2000 and Freedom of Information (Scotland) Act 2002: These Acts grant people rights of access to information that is not covered by the Data Protection Act 1998, e.g. information which does not contain a person’s identifiable details.  

The Computer Misuse Act 1990: This Act secures computer programmes and data against unauthorised access or alteration. Authorised users have permission to use certain programmes and data. If the users go beyond what is permitted, this is a criminal offence.  

Confidentiality after death

The duty of confidentiality does continue after death of an individual to whom that duty is owed.  

Information disclosure to the police

There is no obligation placed upon any citizen to answer questions put to them by the police. However, there are some exceptional situations in which disclosure is required by statute. These include:  

• the duty to report notifiable diseases in accordance with the Public Health Act 1984
• the duty to inform the Police, when asked, of the name and address of drivers who are allegedly guilty of an offence contrary to the Road Traffic Act 1998
• the duty not to withhold information relating to the commission of acts of terrorism contrary to the Terrorism Act 2000
• the duty to report relevant infectious diseases in accordance with the Public Health (Infectious Diseases) Regulations 1998.

Police access to medical records

The police have no automatic right to demand access to a person’s medical records. Usually, before the police may examine a person’s records, they must obtain a warrant under the Police and Criminal Evidence Act 1984. Before a police constable can gain access to a hospital, for example, to search for information such as medical records or samples of human tissue, he or she must apply to a circuit judge for a warrant. The police have no duty to inform the person whose confidential information is sought but must inform the person holding that information. 

Risk or breach of confidentiality

If a healthcare professional identifies a risk or breach of confidentiality, they must raise their concerns with someone in authority if they are unable to take affirmative action to correct the problem and record that they have done so. A risk or breach of confidentiality may be due to individual behaviour or because of organisational systems or procedures. The Code states “You must act without delay if you believe that you, a colleague or anyone else may be putting someone at risk”. Healthcare professionals have a professional duty to take action to ensure the people in their care are protected and failure to take such action could amount to professional misconduct on their part. 

As appropriate registration with the NMC is a pre-requisite for nurses to secure work assignments in the United Kingdom, registration with Direct Medics is subject to verification of professional membership. This is carried out at several stages, namely: 

i.  When a nurse first applies to register with Direct Medics, as part of our initial pre-employment checks; 
ii. When a nurse is booked for a job opportunity, and 
iii. On a monthly basis for any nurses on “block” bookings
iv. Annual check when a nurse’s registration is renewed. 

Consent is defined as “permission for something to happen or agreement to do something” (Oxford English Dictionary). In relation to health care, it is a general legal and ethical principle that valid consent must be obtained before commencing an examination, starting treatment or physical investigation, or providing care. 

 This principle reflects the rights of a person to determine what happens to their own bodies or what shapes the care and support they receive. It is fundamental to good practice. The Nursing and Midwifery Council (NMC) professional practice document for Nurses and Midwives, The Code (NMC, 2015) states that registered nurses must: 

(4.1) “balance the need to act in the best interests of all people at all times with the requirement to respect a person’s right to accept or refuse treatment”, and 

(4.2) “make sure that you get properly informed consent and document it before carrying out any action”. 

Registered nurses who do not respect this principle may be liable to both legal action by the person in their care and action by the NMC. 

The requirement to gain consent has two purposes, one legal and the other clinical (Richardson V, 2013). The legal purpose is to provide those delivering treatment with a defense to a criminal charge of assault or battery or a civil claim for damages for trespass to the person.  

The clinical purpose comes from the fact that in most cases the co-operation of the person and the person’s confidence in the treatment is a major factor in their consenting to the examination, treatment or physical investigation, or the provision of care. 

What is meant by “valid consent”?

For consent to be valid, it must be given voluntarily and freely, without pressure or undue influence, by an appropriately informed person who has the capacity to consent to the intervention in question. Some people may feel pressurised, by relatives or carers for example, to accept a particular investigation or treatment. 

Registered nurses should be
aware of this, and of other situations in which people might be vulnerable, for example, those resident in a care home, or in prison. In these situations, it is essential to ensure that the person has considered the available options and has voluntarily reached their own fully informed decision. 

Emergency situations

In emergency situations, the need to initiate immediate treatment may limit the quantity of information necessary for the patient to give an informed consent.  

However, due care should be exercised to ensure that any legally binding wishes of the patient, expressed in advance of the emergency, are not overlooked. If the patient is well enough and has sufficient capacity to understand the situation, he/she has the right to refuse treatment, even if this decision may have a negative impact on health or wellbeing. 

 Such decisions should be recorded in the patient’s care plan and reflect the involvement of the patient in the decision-making process. If the patient is unconscious, or an emergency occurs when a patient is under general anesthetic, staff may act in his/her best interests without consent to protect life and future health.  

On occasions, staff may need to seek legal advice before initiating treatment or care, although this may not always be practicable in an emergency.  

Obtaining consent 

What is meant by “informed consent”?

Several recent and less recent judicial reviews and rulings by the Supreme Court have confirmed that the need for “informed consent” is a legal requirement. 

Many interventions are not a simple “yes/no” situation; it is not enough to provide adequate information to ensure consent for the examination, treatment and/or care. 

Sufficient evidence-based information must be provided to the person to enable them to make a balanced and informed decision about their care and treatment. As well as a general explanation of the procedure there is also a duty to explain the risks inherent in the procedure and the risks inherent in refusing the procedure.  

Information must also be provided regarding alternatives to the proposed intervention. This will assist the person to make the decision to consent to, or refuse consent for a particular intervention, whilst respecting their right to autonomously decide what happens to them. 

Failing to meet this legal duty can give rise to an action in negligence if the person is subsequently harmed. 

Obtaining consent is a process rather than a one-off event. When a person is told about proposed treatment and care, it is important that the information is given in a sensitive and understandable way. The person should be given enough time to consider the information and the opportunity to ask questions if they wish to. You should not assume that the person in their care has sufficient knowledge, even about basic treatment, for them to make a choice. 

The NMC Code supports involving people in the care giving processes. It clearly states: “You must uphold people’s rights to be fully involved in decisions about their care.”  It is essential that they are given sufficient information to enable them to determine whether to accept or decline treatment and care. This right is supported in the Code where it states: “You must respect and support people’s rights to accept or decline treatment and care.” 

If a person feels the information, they have received is insufficient, they could make a complaint to the NMC or take legal action. Most legal action is in the form of an allegation of negligence. It is therefore essential that nurses and midwives ensure that they: “…share with people, in a way they can understand, the information they want or need to know about their health.”  In exceptional cases, for example, where consent was obtained by deception or where not enough information was given, this could result in an allegation of battery. However, only in the most extreme cases is criminal law likely to be involved. 

Forms of consent

The validity of consent does not depend on the form in which it is given. Consent can be expressed in writing, verbally or non-verbally. 

In most cases completion of a consent form is not a legal requirement, (exceptions being prescribed forms associated with mental health legislation Act 2000, Mental Health (Northern Ireland) Order 1986, Mental Capacity on should be considered. And the Human Fertilisation and Embryology Act 1990).  

Although written forms serve as evidence of consent, the completion of any consent form or documentation must meet with the requirements that constitute valid consent, i.e. the person has the capacity to make the decision, sufficient information has been provided to ensure that consent was “informed”, and that consent has been freely given. 

 Where a person is illiterate or unable to fully complete their signature, but is able to provide valid consent, they may be able to make a mark on the form to indicate consent. It is good practice to have the mark witnessed by another clinician. If consent has been validly given, the lack of a completed form is no bar to treatment or care. 

Consent for sharing information

There is a requirement in the NMC Code (NMC, 2015) at paragraph 5, which explicitly requires nurses to respect a person’s right to privacy and confidentiality. 

When a person discloses personal health information to a health or social care professional, it is generally accepted that care cannot continue unless it is shared with other staff involved in their care. This could include both health and social care staff and administrative staff.  

Registered nurses must ensure that implied consent to sharing of information is not assumed in these circumstances and that any disclosure of information to others is essential for the provision and continuation of care, and in accordance with the requirements of the Data Protection Act (1998) and the Human Rights Act (1998). The duty of confidentiality applies to both adults and children and young people (as clarified in the Gillick principle). 

Circumstances and that any disclosure of information to others is essential for the provision and continuation of care, and in accordance with the requirements of the Data Protection Act (1998) and the Human Rights Act (1998). The duty of confidentiality applies to both adults and children and young people (as clarified in the Gillick principle). 

Should the person state that they do not want information to be shared with anyone, a registered nurse has no permission to do so. 

There is however a recognition that the duty of confidentiality is not absolute. In certain situations, a registered nurse could be required to disclose information without the consent of the individual involved.  

These circumstances may exist where there is a real and serious risk of danger to the public or an identifiable individual, or in the case of a child/young person or where a person with capacity is considered vulnerable. The onus will be on the registered nurse to provide evidence that the absence of consent and a breach of confidentiality meets these specific requirements. 

Children and young people

It is particularly important that registered nurses working with children and young people understand the laws around capacity, and child and parental consent, including giving and refusing consent for the implementation of any treatment or intervention. 

In Northern Ireland the legal age of capacity is 18. However, under section 4 of the Age of Majority Act (Northern Ireland 1969) young people aged 16 -17 are entitled to provide consent for their own medical treatment in the same way as adults this provides a legal basis for a young person under the age of 16 years to consent on his or her own behalf to any surgical, medical or dental procedure or treatment where, in the opinion of a qualified medical practitioner attending them, they are capable of understanding the nature and possible consequences of the procedure or treatment. These provisions need to be considered in conjunction with the rights of those with parental responsibility and human rights law. 

In other circumstances, current case law is based on the view that persons aged under 16 years may be competent to make decisions about their care and treatment when provided with sufficient information in a suitable format. 

This is sometimes referred to as “Gillick” competence. This principle recognises the concept of emerging capacity in children and young people. Cognitive and emotional skills are acquired differentially throughout adolescent development. Whilst decision-making is primarily dependent on information retention and processing, emotional maturity is needed. 

Consent of people who are mentally incapacitated

Relevant mental health legislation and capacity legislation includes the Mental Health (Care and Treatment) (Scotland) Act 2003) make provision for the possibility of detention/deprivation of liberty and/or treatment for a mental disorder and its complications without the consent of the adult, or a young person aged under 18 years. 

If an adult has been assessed as lacking the capacity to make a specific decision, then there are formal legislative processes that allow for a decision about care, treatment or support to be made on their behalf. 

These are commonly known as “best interests’ decisions”. Best interests are not confined to the best medical interests. Most organisations will have established protocols based on legislative requirements and recognised good practice principles.  

Professional accountability

Professional accountability means being personally answerable to the law of the land for all actions or omissions (including what is written or is not written, what advice/ information/communication is given or is not given) while fulfilling a contract as a health and social care employee. 

Registered nurses must act first and foremost to care for and safeguard those in their care. Registered nurses must display a personal commitment to the standards of practice and behavior set out in the NMC Code. NMC states that registered nurses must “show professioanalism and integrity and work within recognised professional, ethical and legal frameworks” (NMC, 2015). 

When an alert letter is received by Direct Medics Ltd. from either NHS Health Scotland or NMC and relating to a nurse on the company register, the following will apply: 

1. A presumption of innocence is made relating to the nurse under investigation during the course of the relevant enquiry; 
2. A notification is made to the Registered Manager as to the presence and nature of the alert; 
3. The Recruitment Director is responsible for checking the company register to confirm whether the nurse under investigation is registered for work; for for recording candidate's alert number, name and date of alert on the company Alerts record; for saving the alert letter in the company datastore and, for any candidates currently registered, for recording the following as an Alert on the candidate file, "Inform Recruitment Director if candidate asks to be considered for work".  In the event that the candidate asks to be considered for work, the Recruitment Director is responsible for following the directions contained in the Alert notice; 
4. Any changes to the nurse’s NMC and resulting restrictions must be carefully considered by the Registered Manager in the context of booking the nurse for assignments during the course of the investigation.  All changes to NMC registration as a result of a live investigation must be made explicit to the client organisation when putting the nurse forward for consideration for an assignment, and no nurse under suspension is permitted to be booked for an assignment; 
5. The company’s Nursing Division Compliance Officer is responsible for checking new registrations within the nursing division against the company’s Alert list.  If an alert is in existence, the Recruitment Director is informed, who in turn is responsible for recording an Alert on the candidate file as per above; 
6. When an Alert cancellation notice is received, the Recruitment Director is responsible for deleting the original Alert notice letter, removing the Alert from the candidate record (if applicable) and removing the Alert from the Alerts spreadsheet. 

The Caldicott Principles allow for the secure transfer of sensitive information across other agencies, including Social Services, Education, Police, and the Judicial System. The eight Caldicott Principles relating to the use of confidential patient information are: 

• Justify the purpose(s) of using confidential information. 
• Only use it when absolutely necessary. 
• Use the minimum necessary. 
• Access should be on a strict need-to-know basis. 
• Everyone must understand their responsibilities. 
• Understand and comply with the law.
• The duty to share information can be as important as the duty to protect patient confidentiality.
• Inform patients and service users about how their confidential information is used. 

Disclosure of Confidential Information 

Disclosure means the sharing of information. Disclosure is only lawful and ethical if the individual has given consent or if there is a legal basis for disclosure. Consent to disclose confidential information may be: 

• Explicit
• Implied
• Required by law
• Justified by public interest

Disclosure with consent: Explicit consent is obtained when the person in the care of a Healthcare Professional agrees to disclosure having been informed of the reason for that disclosure and with whom the information may or will be shared. Explicit consent can be written or spoken. Implied consent is obtained when it is assumed that the person in the care of a Healthcare Professional understands that their information may be shared within the healthcare team. Healthcare Professionals should make the people in their care aware of this routine sharing of information, and clearly record any objections.  

Disclosure without consent: The term ‘public interest’ describes the exceptional circumstances that justify overruling the right of an individual to confidentiality in order to serve a broader social concern. Under common law, staff are permitted to disclose personal information in order to prevent and support detection, investigation and punishment of serious crime and/or to prevent abuse or serious harm to others. Each case must be judged on its merits. Examples could include disclosing information in relation to crimes against the person e.g. rape, child abuse, murder, kidnapping, or as a result of injuries sustained from knife or gunshot wounds. These decisions are complex and must take account of both the public interest in ensuring confidentiality against the public interest in disclosure. Disclosures should be proportionate and limited to relevant details.  

Disclosure to third parties:  This is where information is shared with other people and/or organisations not directly involved in a person’s care. Healthcare Professionals must ensure that the people in their care are aware that information about them may be disclosed to third parties involved in their care. People in the care of a Healthcare Professional generally have a right to object to the use and disclosure of confidential information. They need to be made aware of this right and understand its implications. Information that can identify individual people in the care of a Healthcare Professional must not be used or disclosed for purposes other than healthcare without the individuals’ explicit consent, some other legal basis, or where there is a wider public interest. 

Children and young people under 18 years:If a young person is able to understand the implications of the disclosure, they are able to give their consent, regardless of age. In practical terms, consideration should be given to whether any child aged 12 and over may be competent to give consent. If a child is not competent to give consent, someone with parental responsibility may consent to disclosure on behalf of the child.  

Mothers have automatic parental responsibility, as will the father if they were married at the time of the child’s birth. For children whose births were registered after 15 April 2002 in Northern Ireland, the father has parental responsibility if he is named on the child’s birth certificate. There are also other circumstances in which fathers may gain parental responsibility – for full details see the MPS factsheet on Parental Responsibility.

Patients lacking capacity: Adults are assumed to have capacity unless they have an impairment affecting their mind (eg, dementia), which means they are unable to make a specific decision at a particular time. There is also a requirement to ensure all practical steps have been taken to help the individual make a decision. If a patient lacks capacity, you should act in their best interests when deciding whether to disclose the information. 

Legal and Regulatory Compliance 

This policy aligns with the following legislation: 

• Data Protection 2018
• UK General Data Protection Regulation (UK GDPR)
• Health and Social Care (Control of Data Processing) Act (Northern Ireland) 2016 
• Caldicott Principles (Updated 2020) 

Useful Links

• UK GDPR & Data Protection Act 2018 
• Health and Social Care (Control of Data Processing) Act (NI) 2016 
• Caldicott Principles - GOV.UK 

Effective communication is essential to provide good customer service and to fulfil the standards of service set by the company, its customers and relevant governing bodies. This policy aims to outline our commitment to effective communication by documenting the ways in which we communicate internally and with our customers, and our activities to listen to and respond to our customers through active feedback.  

We provide our customers with a range of information. Broadly speaking our communication approaches fall under the following categories:  

1. To inform: providing transparent information to our customers about our services, our policies and our procedures. 
2. To notify: providing our customers with notifications when pre-employment checks are due to expire; when new opportunities arise for locum work and when supportive opportunities are available (e.g. supervision and appraisal). 
3. To respond: responding to queries we receive from customers face-to-face, by email, telephone and via social media outlets. 

Methods of Communication

We communicate with our customers through a variety of appropriate channels and mechanisms, in ways which meet individual needs and preferences. These currently include email, Facebook, Webpages, Surveys, Telephone calls, SMS messaging, Training sessions, X (formerly Twitter), LinkedIn, Instagram, Videos. These methods will be reviewed regularly and advances in communication technology will be adapted where appropriate.  

Communication Principles  

To ensure effective communication with our customers, we aim to embody the following principles:  

1. Our communication will be clear and concise to deliver our message succinctly. 
2. We aim to use plain English and develop an acceptable glossary of terms, so our communication is easily understandable.
3. We will deliver timely communication that is relevant to the user at their point of need and ensure that agreed standards of service are met.  
4. We will reply promptly to all customer queries, ensuring that agreed standards of service are met. 
5. We will adopt a flexible communication approach, delivering our messages in a variety of ways that meet customer needs and preferences. 
6. We endeavour to standardise our communication where possible to ensure customer clarity by creating templates for letters and emails. 

Internal Communication

To deliver effective communication to our customers, we must ensure that our internal communication is effective. We will do this by: 

1. setting an Out of Office email to alert colleagues to our absence from work. 
2. recording an appropriate voicemail to allow colleagues to leave a message and to redirect colleagues to an alternative colleague/department if we are unavailable. 
3. encourage staff to offer feedback on our communication methods and information provision. 

Evaluating our Communication

To ensure the effectiveness of our communication, we will regularly evaluate our communication approach by:  

1. seeking regular customer feedback (both formal and informal) on our communication and information provision. 
2. listening to and responding to user suggestions regarding our communication and information provision. 
3. making changes to our communication methods or principles where necessary. 
4. reviewing and updating our Communication Policy accordingly. 
5. regularly review and update all information content to ensure accuracy and currency. 

(This policy is subject to change as guidance is updated from Legislation and Public Health advice) 

Infection prevention and control (IPC) is a practical evidence-based approach which prevents patients and healthcare workers from being harmed by avoidable infection. People and Colleagues have the right to live and work in an environment which is clean, pleasant, hygienic, and free from risk of infection. 

Chain of infection   

For infection to occur several things must happen.  This is often referred to as the Chain of Infection. The six links in the chain are:  

The Infectious Agent or the microorganism which can cause disease.  

The Reservoir or source of infection where the microorganism can live and thrive. This may be a person, an animal, any object in the general environment, food or water.  

The Portal of Exit from the reservoir. This describes the way the microorganism leaves the reservoir. For example, in the case of a person with flu, this would include coughing and sneezing. In the case of someone with gastro-enteritis microorganisms would be transmitted in the faeces or vomit.  

The Mode of Transmission. This describes how microorganisms are transmitted from one person or place to another. This could be via someone’s hands, on an object, through the air or bodily fluid contact.  

The Portal of Entry. This is how the infection enters another individual. This could be landing on a mucous membrane, being breathed in, entering via a wound, or a tube such as a catheter.  

The Susceptible Host. This describes the person who is vulnerable to infection.  

Infection can be prevented by breaking the Chain of Infection.

Implementation of this policy into clinical practice and will enhance resident safety and reduce the risk of residents and visitors acquiring or spreading an Infection; staff will also reduce their risk of developing infection whilst delivering care.  

 This policy will provide guidance on agency nurses carrying out a shift with Direct Medics (Scotland) and staff must also make themselves aware of the most current guidance available, including NHS Scotland own policies and procedures relating to the prevention and managements of “Infection prevention and control” and awareness if policies procedures and guidelines laid out in the National Infection Prevention and Control Manual and Public Health Scotland and in line with in line with Public Health etc (Scotland) Act 2008,  

National Infection Prevention and Control Manual: Home (scot.nhs.uk); Public Health Scotland   

Direct Medics (Scotland) ltd policy is considered in line with Standard Infection Control Precautions with Infection Control Standards, as we do not know who may be affected by infectious disease, we should therefore treat everyone the same.  

Infection control is the name given to a wide range of policies, procedures and techniques intended to prevent the spread of infectious diseases.  

Standard Infection Control Precautions (SICP’s) are designed to prevent cross transmission from recognised and unrecognised sources of infection. All resident care that involves the management of blood or bodily fluids should be performed using appropriate Personal protective equipment as laid out in the guidance within the policy of Direct Medics (Scotland). Sources of (potential) infection include blood and other body fluids secretions or excretions (excluding sweat), non-intact skin or mucous membranes and any equipment or items in the care environment which are likely to become contaminated. They are necessary to ensure the safety of residents, visitors and agency nurse who visit the environment. Bodily fluids and blood from a resident should be considered potentially hazardous.  

SICP’s must be always implemented. The application of SICP’s during delivery of care is determined by:   

The level of interaction between the Nurse and the patient  

The anticipated level of exposure to blood and or body fluids   

Training:

Training:

Direct Medics Ltd require that all agency workers should: 

• At all times, observe high standards of hygiene to protect themselves and their service users from the unnecessary spread of infection. Adhere to our clothing guidance and use disposable gloves and disposable aprons which are provided by clients for workers at risk of coming into direct contact with body fluids or who are performing personal care tasks. 
• All agency staff receive infection prevention and control (IPC) induction which includes the standard precautions for minimising infection.
• Infection Prevention and Control mandatory training is undertaken annually.  
• Attend training on infection control when organised by the agency. 

Healthier Business Group (hbcompliance.co.uk) 

Direct Medics (Scotland)Ltd Agency Nurses providing care must: 

• Show their understanding by applying the infection prevention and control principles in this policy and that of the placement. 
• Maintain competence, skills and knowledge in infection prevention and control by attending/completing training provided. 
• Communicate the infection prevention and control practices to be carried out by those being cared for, relatives and visitors, without breaching confidentiality. 
• Have up-to-date occupational immunisations, health checks and clearance requirements as appropriate 
• Report to line managers and document any deficits in knowledge, resources, equipment and facilities or incidents that may result in transmitting infection including near misses, eg PPE failures. 
• Do not take shifts or provide care while at risk of transmitting infectious agents to others and notify line manager and agency nurse manager if there is a suspected or actual HAI incident/outbreak. 

Infection prevention and control is everyone’s business, and for everyone involved in the planning and delivery of healthcare. Visitors to Client locations and patients themselves have their part to play in keeping infections at bay. 

All workers are expected to be conversant with the content of the manual and apply its principles throughout the course of their work. All workers should follow the guidance directed by the Client in their Housekeeping Policies. 

Standard Infection Control Precautions (SICP): SICPs are core measures that should be always used, in all care settings, by all staff. They are based upon the assumption that every individual could be carrying potentially harmful microorganisms and that there is the potential for transmission. 

All workers are required to be familiar with Standard Infection Prevention Standards and all updates, by referring to: 

Direct Medics (Scotland) Nurses providing care must:   

Show their understanding by applying the infection prevention and control principles in this policy and that of the placement

• Maintain competence, skills and knowledge in infection prevention and control by attending/completing training provided they must have a TURAS account and can access the Infection Prevention and Control (IPC) Zone | Turas | Learn to maintain CPD requirements  
• Communicate the infection prevention and control practices to be carried out by those being cared for, relatives and visitors, without breaching confidentiality  
• Have up-to-date occupational immunisations, health checks and clearance requirements as appropriate   
• Report to line managers and document any deficits in knowledge, resources, equipment and facilities or incidents that may result in transmitting infection including near misses, eg PPE failures.
• Do not take shifts or provide care while at risk of transmitting infectious agents to others and notify line manager, home manager and agency nurse manager if there is a suspected or actual HAI incident/outbreak.  

Infection prevention and control is everyone’s business, and for everyone involved in the planning and delivery of healthcare. Visitors to hospital and patients themselves have their part to play in keeping infections at bay.   

All workers are expected to be conversant with the content of the manual and apply its principles throughout the course of their work. All workers should follow the guidance directed by the Trust Housekeeping Policies.  

Standard Infection Control Precautions (SICP): SICPs are core measures that should be always used, in all care settings, by all staff. They are based upon the assumption that every individual could be carrying potentially harmful microorganisms and that there is the potential for transmission.  

All workers are required to be familiar with Standard Infection Prevention Standards and all updated in referring to:   

National Infection Prevention and Control Manual: Chapter 1 - Standard Infection Control Precautions (SICPs) (scot.nhs.uk)  

1.1 Patient Placement/Assessment for infection risk  

1.2 Hand Hygiene  

1.3 Respiratory and Cough Hygiene  

1.4 Personal Protective Equipment  

1.5 Safe Management of Care Equipment  

1.6 Safe Management of Care Environment  

1.7 Safe Management of Linen  

1.8 Safe Management of Blood and Body Fluid Spillages  

1.9 Safe Disposal of Waste (including sharps)  

1.10 Occupational Safety: Prevention and Exposure Management (including sharps)  

Patient Placement   

1.1 Patient Placement/Assessment for infection risk  

https://www.nipcm.scot.nhs.uk/appendices/appendix-11-best-practice-aide-memoire-for-optimal-patient-placement-and-respiratory-protective-equipment-rpe-for-infectious-agents-whilst-a-patient-is-in-hospital/ The work of agency staff involves the risk of exposure to communicable diseases.  General principles of infection control include effective handwashing:  

• Before performing hand hygiene:   
• Expose forearms (bare below the elbows)  
• Use liquid soap and water or an alcohol-based hand rub when washing hands – make sure it encounters all areas   
• Remove nail varnish, wrist and hand jewellery at the beginning of each shift where you will be regularly decontaminating your hands. A plain wedding band may be worn.
• Wear disposable gloves and aprons when attending to dressings or dealing with blood and bodily fluids (sterile gloves should only be worn when performing aseptic techniques)   
• Dispose of gloves and aprons after use ensuring you use the correct clinical waste bins.   
• Cover cuts or breaks in your skin or those of patients / clients with waterproof dressings   

1.2 Hand Hygiene  

Considered the most important practices in preventing the onward transmission of any infectious agents.  Hand hygiene should be performed in line with section 1.2 of SICPs.  

Hand hygiene is essential to reduce the transmission of infection in hospital settings.   

All staff, residents and visitors should clean their hands with soap and water or, where this is unavailable, alcohol-based hand rub (ABHR) when entering and leaving the care home and when entering and leaving areas where care is being delivered.  

Hand hygiene must be performed immediately before every episode of direct care and after any activity or contact that potentially results in hands becoming contaminated, including the removal of personal protective equipment (PPE), equipment decontamination and waste handling.  

If wearing an apron rather than a gown (bare below the elbows), and it is known or possible that forearms have been exposed to respiratory secretions (for example cough droplets) or other body fluids, hand washing should be extended to include both forearms. Wash the forearms first and then wash the hands.  

Staff should support any patients and visitors with hand hygiene regularly where required.  

1.3 Respiratory and Cough Hygiene  

The Covid-19 pandemic highlighted that the way in which respiratory transmission is currently described (droplet and airborne transmission) may not reflect what is happening in real life. The National Services for Scotland is looking at whether there is a better way to describe transmission, and whether this would lead to any improvements in infection prevention and control (IPC) practice Respiratory and cough hygiene is designed to minimise the risk of cross transmission of respiratory pathogens (The principles of respiratory and cough hygiene can be found in section 1.3 of SICPs., including any updates and Control of the Environment Policy and Procedure (windows.net) and Standard Infection Precautions Literature Review Cough etiquette Patients, staff and visitors should be encouraged to minimise potential transmission through good respiratory hygiene measures which are:  

Disposable, single-use tissues should be used to cover the nose and mouth when sneezing, coughing or wiping and blowing the nose – used tissues should be disposed of promptly in the nearest waste bin;  

Tissues, waste bins (lined and foot operated) and hand hygiene facilities should be available for residents, visitors and staff;  

Hands should be cleaned using liquid soap and water, if possible, otherwise using alcohol-based hand rub (ABHR) after coughing, sneezing, using tissues or after any contact with respiratory secretions and contaminated objects;  

Encourage patients to keep hands away from the eyes, mouth and nose.  

Some patients may need assistance with containment of respiratory secretions; those who are immobile will need a container (for example a plastic bag) readily at hand for immediate disposal of tissues.  

COVID-19 Guidance 3RD June 2024 

Following a clinical review, the Cabinet Secretary for NHS Recovery, Health and Social Care, the Minister for Social Care, Mental Wellbeing and Sport, and the Minister for Public Health and Women’s Health have agreed to end routine asymptomatic COVID-19 testing before discharge from Scottish hospitals 

Government measures may continue to change nationally and even locally depending on the prevalence of the virus. As such, access to the correct guidance and advice is paramount. The links in the document direct staff to information and guidance that is nationally agreed in partnership.  

Since the 30th of August 2023, health and social care staff with symptoms of a respiratory infection have been asked to follow NHS Inform Advice on Covid-19.  All agency staff should continue to follow this NHS Inform advice going forward. If there are any further changes to this advice, Scottish Government will engage with, and inform, health and social care employers and agencies accordingly. 

COVID-19 Infection Prevention and Control (IPC) Guidance (including PPE) 

On the 31st of March 2022 guidance was issued to all agency staff on the de-escalation of COVID-19 infection prevention and control (IPC) measures. All IPC changes are available in the National Infection Prevention and Control Manual: Home (scot.nhs.uk) 

COVID-19 - Infection Prevention and Control (IPC) outbreak 

Continued attention to safety measures in relation to a pandemic are essential for everyone. This includes hand hygiene, PPE as appropriate, ensuring good airflow (as far as reasonably comfortable), and rigorous cleaning of surfaces before and after visits. 

Everyone must be informed of and adhere to IPC measures in place, including FRSM, hand hygiene, physical distancing and not attending with COVID-19 symptoms or before a period of self-isolation has ended, whether identified as a case of COVID-19 or as a contact. 

Direct Medics (Scotland) Ltd will ensure that agency staff follow Client policies and procedures. 

Application to the agency register for staff requires the declaration of any communicable diseases. Good practice requires that staff also disclose any subsequent contraction of, or exposure to, such disease using the company’s occupational health review form. Having an infectious disease will not be grounds for refusal or termination of assignments but may make agency staff temporarily unsuitable for certain assignments through the Company or restrict the types of work to which they may be assigned, both in their own interest and that of clients/patients. 

It is the responsibility of agency staff to take adequate precautions to protect themselves from communicable diseases. If unsure of the appropriate steps to be taken, agency staff should discuss the assignment with the immediate Line Manager at the assignment location. All information regarding condition or circumstances will be treated as confidential. 

To avoid risks of cross infection, it is essential that all incidents that may result in the spreading of a disease be reported. Incidents in pa hospital site should be reported in accordance with NHS Scotland policies and procedures 

All incidents should also be reported to our Nursing Manager. 

1.4 Personal Protective Equipment  

PPE should be used correctly and is only effective when combined with:  

 cleaning your hands regularly and appropriately for at least 20 seconds  

• respiratory hygiene and avoiding touching your face with your hands  
• following standard infection prevention and control precautions  
• following the correct technique for putting on and taking off PPE  
• safe disposal of used PPE  

Public Health Scotland  

PPE exists to provide the wearer with protection against any risks associated with the care task being undertaken.   

PPE requirements as per standard infection prevention and control are detailed in section 2.4 SICPs.     

PPE requirements   

It is of paramount importance that PPE is worn only at the recommended appropriate times, selected appropriately and donned and doffed properly to prevent transmission of infection.  

PPE is the least effective control measure as per the hierarchy of controls must be implemented and adhered to wherever possible.  More details on the hierarchy of controls can be found in Appendix 17 - Hierarchy of controls.  

All patient care that involves the management of blood or bodily fluids should be performed wearing single use disposable gloves and a single use white disposable apron. This should be done regardless of infection status, and gloves and aprons must be changed between residents   

Face Masks  

PPE which should be worn when providing direct patient care.  

Type IIR facemasks should be worn for all direct care regardless of the risk category.  FRSMs should be changed if wet, damaged, soiled or uncomfortable and must be changed after having provided care for a resident isolated with a suspected or known infectious pathogen and when leaving resident areas on high-risk categories.  

 PPE - putting on (donning) and taking off (doffing)  

 All staff must be trained in how to put on and remove PPE safely. National Infection Prevention and Control Manual: Appendix 6 - Putting On and Removing PPE.  A poster describing the donning and doffing of PPE is available here: Best Practice: Appendix 6 - Putting on and removing PPE  

Before putting on PPE:  

• Check what the required PPE is for the task/visit 
• Select the correct size of PPE  
• Perform hand hygiene  
• PPE should be put on before entering the room.  

The order for putting on is apron, surgical mask, eye protection (if required) and gloves – you may require some of these items or all of them  

When putting on mask, the mask should be well fitting, position the upper straps on the crown of head and the lower strap at the nape. Mould the metal strap over the bridge of the nose using both hands.  Further link to a poster on fitting masks can be found in here: National Infection Prevention and Control Manual: Appendix 6 - Putting On and Removing PPE  

When wearing PPE:  

• Keep hands away from face and PPE being worn.  
• Change gloves when torn or heavily contaminated.  
• Limit surfaces touched in the care environment.  
• Always perform hand hygiene after removing gloves

Removal of PPE

PPE should be removed in an order that minimises the potential for cross-contamination.

Gloves

• Grasp the outside of the glove with the opposite gloved hand; peel off.  
• Hold the removed glove in gloved hand.  
• Slide the fingers of the un-gloved hand under the remaining glove at the wrist.  
• Peel the glove off and discard appropriately.  

Gown

• Unfasten or break ties.  
• Pull gown away from the neck and shoulders, touching the inside of the gown only.  
• Turn the gown inside out, fold or roll into a bundle and discard. 

Eye Protection (if worn)

To remove, handle by headband or earpieces and discard appropriately.

Fluid Resistant Surgical facemask

• Remove after leaving care area.
• Untie or break bottom ties, followed by top ties or elastic and remove by handling the ties only (as front of mask may be contaminated) and discard as clinical waste.
• For face masks with elastic, stretch both the elastic ear loops wide to remove and lean forward slightly. Discard as clinical waste.  
• To minimise cross-contamination, the order outlined above should be applied even if not all items of PPE have been used.  

Perform hand hygiene immediately after removing all PPE.  

Sessional use of PPE

During the peak of the pandemic, some PPE was used on a sessional basis and this meant that these items of PPE could be used moving between residents and for a period where a member of staff was undertaking duties in an environment where there was exposure to COVID-19.  A session ended when the healthcare worker left the clinical setting or exposure environment.    

PPE for delivery of COVID-19 vaccinations

Healthcare workers (HCWs) delivering vaccinations must adhere to the latest guidance provided by NHS Scotland and resources provided on TURAS here: COVID-19 vaccination programme | Turas | Learn (latest information correct as Winter 2024)  

• Wear a fluid resistant surgical facemask (FRSM) for all direct contact
• This will protect both the HCWs and resident from exposure to COVID-19 should either be pre-symptomatic or an asymptomatic carrier of COVID-19.
• Perform hand hygiene regularly including before and after each resident /individual contact and as per 4 moments for hand hygiene laid out in the National Infection Prevention & Control Manual (NIPCM).   
• Wear a visor where there is anticipated splashing to the face.  For example, where nasal vaccinations induce sneezing, HCWs may choose to wear a visor to prevent droplet contamination to the face following risk assessment.   

The patient on whom the nasal vaccination is being administered should be provided with disposable tissues to cover their mouth where any sneezing is likely.  They should dispose of the tissues in a suitable waste receptacle and wash hands with warm soap and water.  If there are no hand hygiene facilities available, ask the individual to use alcohol-based hand rub (ABHR) and wash their hands at the earliest opportunity.  

Other items of PPE are unlikely to be required for routine vaccination and a risk assessment should be carried out considering both IPC and COSHH guidance.  

As per SICPs; 

• Aprons should be worn where there is anticipated contamination to the healthcare workers uniform or clothing.  
• Gloves should be worn where blood and body fluid exposure is anticipated.  Tiny amounts of blood resulting from vaccination site pose little risk to a HCW where the skin of the healthcare workers hands is intact.  There is therefore no need to wear gloves when delivering a vaccination provided the skin on the HCWs hands is intact and the skin of the person receiving the vaccination is intact.  An SBAR which considered the need for HCWs to wear gloves when delivering vaccinations was produced by HPS in 2014.    

A poster detailing safe PPE practice for staff vaccinators and poster aimed at those attending vaccination clinics is available.  

Agency staff will require to adhere to the policies and procedures of NHS Scotland Trust   

Safe Management of Clothing/uniform for Agency Staff

In accordance with Direct Medics (Scotland) Ltd Nurse Manual  

• Agency Staff should not travel to work in their uniform or their work clothing. Washed separately in a load not more than half the capacity at the maximum temperature the fabric can tolerate.  
• Staff should wash their hands and change into uniform prior to entering the work area
• Staff at the end of the shift ensure hands are washed, return to the allocated changing area to take home.   

1.7 Safe Management of Linen  

Each NHS Trust will have their own set of policies and procedures, and agency staff should adhere to the policies and guidance laid out by NHS Scotland Trust providing this adheres to the  Section 1.7 of SICPs  guidance.  

1.8 Safe Management of Blood and Body Fluid Spillages   

Blood and body fluid spillages | Turas | Learn (nhs.scot)  

Each NHS Trust will have their own set of policies and procedures, and agency staff should adhere to the policies and guidance laid out by Direct Medics (Scotland) and adheres to the  Section 1.8 of SICPs  guidance.  

Each NHS Trust will have procedures in place to ensure that staff are protected from occupational exposure to micro-organisms, particularly those that may be found in blood and body fluids.   

Patients and Visitors must also be protected from any communicable diseases that staff may have.  

Skin care  

If any worker has a skin condition that may be affected by work or has the potential to affect patients or colleagues, then they must seek medical advice from their General Practitioner. If an allergic reaction to any product used in the work environment is suspected this must be investigated by the individual’s general practitioner. The agency must be updated on any advice received and a OHD form completed appropriately, and a risk assessment be carried out.  

Blood borne viruses and sharps   

Sharps injuries are one of the most common types of injury to be reported to nurse in charge of the clinical area and advice provided by the ward. In addition, the agency worker must also inform the Nurse Manager by contacting Direct Medics (Scotland). The greatest risk of a blood borne virus (BBV) being transmitted is because of a sharps injury, especially those resulting from injury with a hollow bore needle where blood may remain. Transmission of BBVs may also result from contamination of mucous membranes with splashes of blood/body fluids.   

Sharps include items such as needles, blood glucose lancets, ampoules, used razor blades and disposable razors that may be contaminated with blood or other body fluids. Sharps boxes Sharps boxes must be of a type of UN approved, correctly assembled and never be over-filled, i.e. above the manufacturer’s fill line, or ¾ full. The container must be puncturing resistant and leak proof. It must be stable and provided with a handle and an aperture which will inhibit the removal of the contents but will ensure that it is possible to dispose of items using one hand. Sharps containers must be kept off the floor, and inaccessible to unauthorised persons.   

Complete the label on the container as required when it is brought into use, and again when full, prior to disposal. When ¾ full it must be sealed, the label properly completed and sent for disposal as clinical waste.   

Use of sharps

• Wear gloves when handling sharps
• Discard all sharps into a sharp's container at the point of use  
• Never leave needles or any other sharps lying around  
• Always request assistance when using sharps with an uncooperative client
• Never walk about with unguarded sharps
• Never re-sheath needles   
• Discard syringe and needle as one unit.   
• Do not pass an exposed sharp to another person   
• Do not dispose of wrappers, cotton wool, etc in sharps boxes as this may prevent the sharps being dropped in directly, and cause an injury if someone tries to force a sharp in.   
• Never remove items from a sharp's container   
• Dispose of sealed sharps containers as clinical waste   

Sharps/Inoculation Injuries

A sharps/inoculation injury is when someone else’s blood or body fluid gains access to your blood or tissue. This may be caused by:   

• A cut or puncture of your skin by a contaminated sharp   
• Contamination of staff wounds by a resident’s blood or body fluid   
• Bites which break the skin   
• Body fluids splashed into the eye or mouth may also (rarely) transmit infection   

Remember – all sharps’ injuries are potentially preventable  

Action to take in the event of a sharps/inoculation injury:

• Bleeding from a small wound should be promoted for a few seconds by gently squeezing the surrounding skin. Do not suck or scrub   
• Wash the wound with warm running water and liquid soap   
• Cover wound with a waterproof dressing   
• If the eyes are contaminated irrigate for 2 minutes with normal saline or running water. If contact lenses are worn, irrigate both before and after removal   
• Contaminated mucus membrane (e.g., nose, mouth) should be washed with plenty of water.   
• Report the injury to the person in charge and Direct Medics (Scotland) Nurse Manager  
• Record the incident   

Unused/clean sharp – no risk of infection, (except from the microorganisms on your own skin). Record incident, but no further action.   

Used/dirty sharp – source known or unknown, also human bite/scratch/mucus membrane splash. Seek professional advice from Accident and Emergency Department at local hospital or your General Practitioner. This should be within one hour of the incident having taken place. In a hospital setting, the risk of acquiring a blood borne virus as the result of a sharps/inoculation injury from a source known to be infected has been estimated as follows: 

• Hepatitis B - around one in three
• Hepatitis C - around one on 30   
• HIV - around one in 300   

This means that the risk of acquiring an infection from a sharp/inoculation injury in a low risk population, even when the infection status of the source is unknown, is minuscule. However, this must not be used as a reason for complacency in sharps management.   

Hepatitis B immunisation

Hepatitis B immunisation is recommended for all healthcare workers who may have direct contact with individuals’ blood, blood-stained body fluids or tissues.   

When immunisation is required, the cost must be borne by Direct Medics (Scotland)  

There are no vaccines which protect against hepatitis C or HIV. 6.4 Other immunisations It is regarded as good public health practice for everyone to be fully immunised. Staff should be asked to consult Direct Medics (Scotland) and/or GP to ensure that they are up to date with all immunisations and arrange boosters if necessary.   

The Scottish Government Health Department recommends that all those involved in direct care should be immunised annually against influenza. This is the responsibility of the employer to arrange and fund. However, staff should be encouraged to be immunised, for the following reasons:   

• They personally benefit, as they reduce their chances of becoming ill   
• The organisation benefits because there is reduced absenteeism,   
• Residents benefit because they are doubly protected   

To avoid the risk of needle stick injury, nurses should not use pen injection devices to administer medication to patients.  

MANAGEMENT OF BLOOD AND OTHER BODY FLUID SPILLAGES   

Spillages of blood, body fluids and excreta may be hazardous to health and should be cleaned up promptly. A disposable plastic apron and gloves must be worn when dealing with all blood/body fluid spillages. Staff should contact the domestic staff who are trained to deal with and manager blood and body fluid spillages. Spillages should also be reported to nurse in charge and Domestic Department.   

1.9 Safe Disposal of Waste (including sharps)  

Waste should be handled in accordance with Section 1.9 of SICPs and Scottish Health Technical Note (SHTN), NHS Scotland Waste Management Guidance contains the regulatory waste management guidance for NHS Scotland including waste classification, segregation, storage, packaging, transport, treatment and disposal. Direct Medics (Scotland) agency staff will adhere to the policies and procedures laid out by the NHS Trust  

The Health and Safety (Sharp Instruments in Healthcare) Regulations 2013 outline the regulatory requirements for employers and contractors in the healthcare sector in relation to the safe disposal of sharps.   

All consumable waste items that have been in contact with the individual including tissues, should be put in a plastic rubbish bag, double bagged and ties. Waste should be put in a secure location awaiting uplift in line with the home’s policies for contaminated waste generally 72 hours holding.  

NB: Type IIR facemasks worn as part of the extended use of facemasks policy should be disposed of as clinical waste.  

All consumable waste items that have been in contact with the individual including used tissues, should be put in a plastic rubbish bag, double bagged and tied. This should be put in a secure location awaiting uplift in line with local policies for contaminated waste generally within 72 hours of holding.  

Occupational Safety  

Each trust will have their own set of policies and procedures, and agency staff should adhere to the policies and guidance laid out by Direct Medics (Scotland) 

This policy is considered current best

Agency Insurance Arrangements

The company recognises its responsibility to indemnify itself and its staff against all eventualities in the course of assignments.  As such, the company holds and maintains the following levels of insurance: 

i.    Employer’s Liability: £10million
ii.   Public & Products Liability: £10million
iii.  Professional Indemnity: £10million

Agency staff requirements

In line with EU legislation which took effect in October 2013 and subsequently adopted by the UK government, professional indemnity insurance is required for all healthcare professionals.  It is therefore a pre-requisite to registering with Direct Medics that all applicants have suitable arrangements in place to meet this requirement and are covered by the NHS. 

Direct Medics Ltd. is committed to ensuring ethical recruitment through its adherence to the UK Code of Practice (CoP) for International Recruitment. As such, Direct Medics Ltd. appears on the NHS Employers list of healthcare organisations involved in the international recruitment of healthcare professionals, indicating the company’s commitment and adherence to the UK Code of Practice, and provides a dedicated support service to NHS organisations to help them follow the guiding principles of the Code in their recruitment activities.

The guiding principles that underpin the code of practice are as follows:

1. International recruitment is a sound and legitimate contribution to the development of the healthcare workforce.
2. Extensive opportunities exist for individuals in terms of training and education and the enhancement of clinical practice.
3. Developing countries will not be targeted for recruitment, unless there is an explicit government-to-government agreement with the UK to support recruitment activities.
4. International healthcare professionals will have a level of knowledge and proficiency comparable to that expected of an individual trained in the UK.
5. International healthcare professionals will demonstrate a level of English language proficiency consistent with safe and skilled communication with patients, clients, carers and colleagues.
6. International healthcare professionals legally recruited from overseas to work in the UK are protected by relevant UK employment law in the same way as all other employees.
7. International healthcare professionals will have equitable support and access to further education and training and continuing professional development as all other employees.

Direct Medics adheres to the above by providing equality both in terms of opportunities provided to international candidates and in the probity that takes place prior to any placement by the company; procedures for pre-employment checks in line with national and regional guidelines would include but not be limited to health assessment in conjunction with Occupational Health guidelines, and confirmation with NMC that the candidate’s experience and qualifications have been validated. 

Prior to placing any international staff, Direct Medics provides comprehensive information to the new staff member, including (but not limited to): 

i. HSC and independent sector employment;
ii. minimum terms and conditions of employment;
iii. job and person specification;
iv. adaptation programmes;
v. professional associations and trade unions;
vi. NMC registration process;
vii. geographical area and the cost of living in the area to which they will be moving;
viii. all other costs that they might incur, for example, accommodation, uniform and transport costs.

The company does not charge fees to international candidates to be considered for recruitment or placement. 

As is the case for all healthcare workers placed through Direct Medics Ltd. international staff will receive regular communication from the company during their assignment(s) to ensure that they have received all the assistance necessary to settle well into their new post and area. 

Records are essential for the protection of service users and the efficient operation of the company. All records must be accurate, up-to-date, and securely maintained in compliance with the Data Protection Act 2018, UK General Data Protection Regulation (UK GDPR), and other statutory requirements. 

Access to Records 

Service users have the right to access their records and the information held about them. They should also be given opportunities to contribute to maintaining the accuracy of their records. Individual records are stored securely and used in accordance with data protection laws. 

Data Protection Compliance 

The company is registered with the Information Commissioner’s Office (ICO) and ensures that all personal data, whether held in manual records or on electronic systems, is processed in compliance with data protection regulations. Under UK GDPR, personal data must: 

1. Be processed lawfully, fairly, and transparently. 
2. Be collected for specified, explicit, and legitimate purposes. 
3. Be adequate, relevant, and limited to what is necessary. 
4. Be accurate and kept up to date. 
5. Be retained only for as long as necessary for its intended purpose. 
6. Be processed in a manner ensuring appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage. 

Data Retention and Disposal 

Records are retained for eight years in accordance with legal and regulatory requirements. The company follows a secure disposal policy, ensuring that records are destroyed in line with relevant legislation and industry best practices. Electronic data is deleted securely to prevent unauthorized recovery. 

Storage and Security of Records 

• Records are kept in secure locations with restricted access. 
• Digital records are encrypted and protected against cyber threats. 
• Access to records is limited to authorised personnel based on role-specific need-to-know principles. 

Legal and Regulatory Compliance 

This policy aligns with the following legislation and guidelines:

• UK General Data Protection Regulation (UK GDPR) 
• Data Protection Act 2018 
• ICO Data Retention Guidance 

Useful Links

• UK GDPR & Data Protection Act 2018 
• ICO Data Protection Guidance 
• NHS Records Management Code of Practice 

This policy will be reviewed annually to ensure compliance with evolving regulations and best practices. 

Nurses engaged in assignments through Direct Medics Ltd. are booked by Recruitment Consultants.  The type of assignment permitted for each nurse is dependent upon the demonstrable skills and qualifications of the individual, ascertained at interview and matching the requirements of the assignment After interview and approval by the Nurse Manager, the Registered Manager advises the Nursing team as to previous roles, practice experience, competency and suitability to future roles. 

The applicant’s information is input onto the company software which is designed to match vacancies to applicants based on grade, specialty, specific skills or a combination of all three if required.  The accurate input of the data is a quality target for the Compliance team within the company, with effective performance in this area monitored by the Compliance Manager on a monthly basis.  The data input includes mandatory training modules in line with the requirements of the NHS and relevant Framework agreements.  

Email, app notification & text alert systems for Nurses is built into the company software and is based upon specific searches, meaning that only those Nurses meeting the criteria for each vacancy is informed about the post and given the opportunity to apply.  Any applicants to a specific vacancy are subject to further document checks by a Recruitment Consultant before being put forward for consideration.   

The above ensures that, at point of registration, all Nurses wishing to book assignments through Direct Medics Ltd. are matched appropriately to vacancies according to their skills and expertise.  This system is maintained and updated as new information becomes available as to the skills and expertise of Nurses registered with the company. 

Direct Medics (Scotland) Ltd. recognises its responsibility to ensure that all reasonable precautions are taken to provide and maintain working conditions which are safe, healthy and compliant with all statutory requirements and codes of practice. 

Direct Medics (Scotland) Ltd. recognises moving and handling as the transporting and supporting of loads by hand or by bodily force without mechanical help.  This includes activities such as lifting, carrying, shoving, pushing, pulling, sliding or nudging heavy objects.  It covers the lifting or moving of service users by staff. 

Direct Medics (Scotland) Ltd. is committed to ensuring the health, safety and welfare of its staff, as far as is reasonably practicable, and of all other persons who may be affected by our activities including service users, their visitors and contractors.  As all these moving and handling activities carry a risk of injury if they are not performed carefully, it is a pre-requisite to registration with Direct Medics (Scotland) Ltd that all nursing staff are fully trained in moving and handling and attend update training as required.  

Staff duties

Staff are required to comply with the risk assessment requirements set out in the Management of Health and Safety at Work Regulations 1999 as well as the requirement in the Manual Handling Operations Regulations 1992 (as amended) (MHOR) to carry out a risk assessment on manual handling tasks. 

In addition, employees have duties to take reasonable care of their own health and safety and that of others who may be affected by their actions. They must communicate with their employers so that they too are able to meet their health and safety duties. 

Employees have general health and safety duties to: 

• follow appropriate systems of work laid down for their safety
• make proper use of equipment provided for their safety
• co-operate with their employer on health and safety matters
• inform the employer if they identify hazardous handling activities
• take care to ensure that their activities do not put others at risk

In addition, no person shall intentionally or recklessly interfere with or misuse anything provided in the interests of health, safety and welfare in pursuance of any statutory provisions.

Employer duties

The client organisation's duty is to avoid Manual Handling as far as reasonably practicable if there is a possibility of injury. If this cannot be done then they must reduce the risk of injury as far as reasonably practicable. If agency worker is complaining of discomfort, any changes to work to avoid or reduce manual handling must be monitored to check they are having a positive effect. However, if they are not working satisfactorily, alternatives must be considered.

The regulations set out a hierarchy of measures to reduce the risks of manual handling. These are as follows:

i.    avoid hazardous manual handling operations so far as reasonably practicable;
ii.   assess any hazardous manual handling operations that cannot be avoided;
iii.  reduce the risk of injury so far as reasonably practicable.

Risk assessment for manual handling by staff

i.    Staff should consider each task for risk of injury;
ii.   If a risk is identified, staff should next consider whether there is a way to eliminate the need for moving manually altogether. For instance, can equipment be used instead?
iii. If the moving and handling task cannot be eliminated altogether, the specific risks involved must next be assessed. This is done in a similar way to any other health and safety risk assessment but the assessment does not need to be recorded provided it is easy to repeat;
iv. Where a specific risk to injury is identified and moving and handling is unavoidable, then measures to reduce the risk must be introduced; e.g. the use of mechanical aids, changing the task to minimise the risk or altering the work environment to make moving and handling less awkward;
v.  Any measures taken to ensure moving and handling safety must be in proportion to the risk and cost-benefit involved.

Staff injured at work

Moving and handling accidents are covered by RIDDOR (The Reporting of Injuries, Diseases and Dangerous Occurances Regulations 1995). According to RIDDOR all moving and handling accidents and injuries should be recorded and also reported especially if they result in staff being absent from work for three days or more or involve faulty equipment.

All staff injured at work will receive appropriate support any staff injured as a result of moving and handling should see their GP as soon as possible.

The successful implementation of this policy requires total commitment from all staff. Each individual has a legal obligation to take reasonable care of their own health and safety, and of the safety of other people who may be affected by their own acts or omissions.

Service Users

Monitoring service user satisfaction is considered to be an important indicator as to whether the company is achieving its objectives in delivering a quality care service. The company will attempt to monitor this through the use of feedback reports, either verbal or written which will be requested within one month of a nurse being assigned in a particular clinical area. Feedback is retained on the staff file and provided to the company’s Nursing Manager as input into annual appraisal. In the event that the feedback provides information pertaining to a complaint or skills need, this information will be provided to the Nursing Manager for immediate attention and action under the relevant policy.

Staff

When Direct Medics staff members are confirmed for assignments it is our aim to ensure that they are completely satisfied with the assignment, that it is within the range of their skills and it is everything expected. Our contact with our staff during assignment may include:

i. Arrival calls on the first day (to confirm safe arrival and first impressions);
ii. Service calls during the assignment (to check that the assignment is proceeding as expected);
iii. Records maintenance calls (to update documents that may be due to expire during the assignment).

Whilst clients provide feedback during and after assignments to allow us to maintain a record of performance for all placements, feedback is of course a two-way process and the company encourages all staff to provide relevant information on the assignment, the setting etc to enable us to enhance our service to our staff and to their colleagues moving forward.

Furthermore, the company encourages feedback from its staff on its own performance; a feedback exercise is carried out monthly, with staff booked in the previous month asked to provide feedback via an online survey as to the performance of the company’s Recruitment and Compliance teams. Staff are encouraged to suggest improvements and all feedback is used within the company’s performance management programme for its internal staff.

Absence Notification & Certification

If a staff member is absent from their assignment due to illness or any other reason, they must comply with the company’s absence notification and certification procedure, the principles of which are as follows: 

If you are going to be absent from an assignment for any reason, you must notify your Recruitment Consultant at least one hour before the beginning of your shift time; the more notice the company receives as to your absence, the better the chance that an alternative member of staff can be provided to the client to ensure continuity of care.  It is not sufficient to leave a voicemail or to send an email or text message; in the event that your Recruitment Consultant is unavailable you must ask to speak with the Recruitment Manager or another member of the Recruitment team. Direct Medics has a 24 hour on-call service which diverts calls to the nominated on-call consultant, it is imperative you call as emails to individual Recruitment consultants are not monitored outside of core office hours. During sick absence it is vital that you, or in exceptional circumstances a member of your household, maintains regular contact with management to advise of your condition and the date when you are likely to resume work. This will enable the Employer to plan effective cover for the duration of your absence. 

For staff working in roles meeting the Agency Worker Regulations’ 12-week qualifying period, the Company reserves the right, on giving notice, to insist on evidence from your doctor for the payment of Statutory Sick Pay, for any sickness absence.  A statement of fitness for work is required for all sick absences of 8 days or more (including weekends) and, if sickness continues, at consecutive intervals thereafter.  

All staff must complete a return-to-work interview with their Recruitment Consultant, to ensure fitness to return to normal duties or, if relevant, what adjustments may be required in order to accommodate any new restrictions. 

WORK RESTRICTIONS FOR STAFF WITH INFECTIOUS CONDITIONS

All staff must have appropriate training in the control and handling of infections.  This will include an appreciation of the need to prevent an infection that an employee may contract spreading to service users and other staff.  All staff are required to report and occurrences of infection to their immediate supervisor on their assignment.  Employees returning to work after taking holidays in high-risk locations are required to complete an update health declaration.   

Each case of infection reported to Direct Medics Ltd. as per the above will be reviewed individually.  The action taken will depend upon the following factors: 

i. The nature of the disease/infection;
ii. The likely routes of transmission of the infection;
iii. The persons most likely to be infected;
iv. The staff member’s particular job role
v. The staff member involved, specifically the degree of susceptibility to infection;
vi. training records and the expected compliance of the staff member with these policies.

Depending upon the circumstances and in consideration of the above, staff members may be re-deployed to job duties which pose less of an infectious risk to hygiene, health and safety.  Such re-deployment would be considered temporary until such time that the infection has cleared.  If this is not possible, the staff member may be excluded from duties altogether until the infection has cleared.   

In cases such as the above, the period of exclusion or amended duties will be determined by the company’s independent Occupational Health provider, pending an update health declaration.  Proof must also be obtained in the form of a fit note from a GP. 

Registering with Direct Medics

The team structure of Direct Medics is designed to ensure that registering and working with the company is as straightforward and simple as possible. As a responsible recruiter we take our legislative obligations seriously and as such, there are several elements to our registration procedure designed to fulfil these obligations. We offer several options to complete pre-employment checks and our Compliance team provides any information new registrants may require.

Initial contact with Direct Medics may take several different forms; most applicants will submit an online registration via www.directmedics.com or email a copy of their latest CV. Immediate steps taken by Direct Medics upon receipt of a registration enquiry are as follows:

1. New registrants are assigned a Compliance Officer who will send an introductory email outlining the company’s pre-employment checks;
2. The Compliance Officer will add new registrant’s details to relevant contact lists to allow them to receive information on job opportunities immediately (it is however made clear that no booking can be made until all checks are completed);
3. New registrants are assigned a Recruitment Consultant who carries out an introductory interview (this can take place either in person or via videoconferencing) where any preferences for job opportunities are confirmed;
4. New registrants receive an advisory telephone call from their Compliance Officer aimed at ensuring full understanding of the registration procedure and receipt of all relevant documents. At this point, agreement will be made as to the preferred method to complete the necessary checks;
5. The compliance officer will guide through the remaining compliance checks.

Depending upon circumstances the above steps can take as little as one week to complete, pending outside factors such as processing times with outside bodies.

The NHS Employment Check Standards (2012)
The NHS Employment Check Standards are a set of six documents developed by NHS Employers in conjunction with the Department of Health, and set out the obligations of employers across the NHS pre-employment assessments that must take place for permanently-employed NHS staff. As a responsible recruiter of healthcare staff, Direct Medics adhere fully to each of the checks enshrined in the Standards for all staff employed through the company, and provide full guidance as to the actions required from new staff to meet these obligations. The checks required are as follows:

1. Verification of Identity
2. Right To Work
3. Employment History & References
4. Criminal Record and Barring Checks
5. Occupational Health
6. Professional Registration & Qualifications

In addition to the above checks, new staff members are required to commit to undertaking mandatory training modules, and maintain their validity.

Direct Medics in conjunction with Healthier Business Compliance, offer free online training modules to all registered workers in the following areas as required:

• Basic Life Support
• COSHH (Control of Substances Hazardous to Health regulation)
• Epilepsy
• Equality, Diversity & Inclusion
• Fire Safety
• Food Hygiene
• Handling Medication
• Handling Violence & Aggression and Complaint Handling
• Health and Safety
• Infection Control
• Information Governance
• Training for workers in a lone environment
• Manual Handling
• Mental Capacity Act 2005
• RIDDOR (Reporting of Injuries, Diseases & Dangerous Occurrences Regulations)
• Safeguarding Vulnerable Adults (SOVA) and Child Protection (SOCA) Level 2
• Safeguarding Vulnerable Adults (SOVA) and Child Protection (SOCA) Level 3

Additional practical training is also required in areas such as life support and moving and handling; the specific requirements are advised to staff upon registration. All staff involved in transfusion activity (i.e. sampling, collection or administration) to complete training and competency assessment in line with the Right Patient Right Blood circular.

Completion of Registration with Direct Medics

Upon completion of our pre-employment checks, files are referred to the company’s Nursing Manager, who will review all available information and contact new registrants to arrange a suitable time for a final interview. The interview may take place in person or, in exceptional circumstances via Skype and is aimed at ensuring your complete understanding of our procedures, suitability to work in chosen area(s) and the presence of specialty-specific skills. You will be booked for work through Direct Medics only with the express approval of the Nursing Manager.

Please note, in the event that a Skype interview must be accommodated, new registrants will be required to meet in person with the Nursing Manager on arrival in the United
Kingdom.

Booking an Assignment

Upon completion of registration, the assigned Recruitment Consultant will make contact by SMS, email and telephone to discuss potential placements, particularly if staff regularly update their Consultant regarding availability. This is an opportunity to be informed about jobs first so it is important that regular contact is kept; this is especially important in the event of a change to location, grade or specialty.

When staff members are interested in booking an assignment, they must contact their Recruitment Consultant as soon as possible. They will be referred to their Compliance Officer in the event that registration documents have expired, otherwise their details will be put forward immediately for consideration. If selected, the company will confirm the details verbally and follow up with a written confirmation by email. The confirmation will include all relevant information about the assignment, including reporting instructions, any travel and accommodation arrangements and instructions on payment for the assignment. Any queries upon receipt of your confirmation should be addressed immediately to allow for a smooth start to assignments.

Payment

Different pay rates apply to different assignments. Before commencing an assignment staff members are informed both verbally and in writing, the rate of pay applicable to the assignment. Payment is made to staff on submission of a timesheet without exception. All information given must be accurate and timesheets must be completed in full and every shift must be authorised with an appropriate signature. The position / grade worked must also be identified. Payroll takes place weekly, with all timesheets submitted by 11am on Monday paid to arrive by the following Monday. Payment will be made by Banker’s Automated Clearing Services (BACS) directly into bank/building society accounts, with a pay slip emailed. Staff members must advise of any change to personal circumstances, e.g. change of address, email address or bank account.

The Company is required by law to deduct PAYE and Class 1 National Insurance Contributions. Therefore, staff members are required to pay income tax on earnings (if they exceed the threshold for the current financial year). The rules affecting people working through agencies are contained in Section 134 TA 1988 (formerly section 38, Finance (No.2) Act 1975). Dependent upon earnings, staff members may also be eligible for auto-enrolment onto the company’s pension scheme (which can be opted out of if they so wish).

Any queries relating to pay must be directed to the Finance team at Head Office; email queries should be directed to [email protected].

Removal from the Company’s Register

Staff may be removed from the register in the following circumstances:

i.   Where a member’s conduct or standard of work has seriously fallen below the level required by the Company or the NMC Code: Standards of Performance and Ethics for Nurses and Midwives
ii.  If it is believed that a member has acted in an unprofessional manner, the company reserves the right to remove you from your assignment and not re-assign until the matter has been investigated and resolved.
iii. If a member has a reason to be put onto the Group Clinical Alert Register;
iv. If a company has been altered by NMC, RQIA or other regulatory bodies with regard to practicing clinicians.

Examples of such conduct are as follows. This list is not exhaustive:

i.   Failure to attend a Client having accepted an engagement, or repeated lateness.
ii.  Failure to provide care in a fashion consistent with the member’s professional code of conduct or in a caring and appropriate manner, e.g. sleeping on duty, non adherence to clinical instruction etc.
iii. Failure to carry out reasonable instructions of the Client.
iv. Breach of trust involving the Company or the Client.
v.  Disclosure of confidential information to a third party relating to either a Client or the Company.
vi. Misconduct, affecting either the Client or the Company. This includes being under the Influence of alcohol or any substance that will adversely affect your performance, theft, abusive or violent behavior, harassment, criminal conviction etc.

All staff are advised to read the Staff handbook in full, to ensure full understanding of what is required.

Induction and orientation for agency staff takes two different forms; induction into Direct Medics (Scotland) Ltd, which involves instruction on the company’s operational arrangements etc. and induction into any organisation into which agency staff are placed on assignment.  All newly appointed agency staff will receive information pertaining to the full company induction checklist in the first instance.  This includes: 

i.   A copy of the staff handbook which all staff are strongly advised to read and query if necessary. Staff sign a declaration confirming receipt of the staff handbook within the company registration form;
ii. The company’s statement of purpose depicting the operational responsibilities of all members of the team at Direct Medics (Scotland) Ltd.; 
iii. Terms and conditions of engagement with the company;
iv. Access to a complete set of all relevant policies and procedures in line with the company’s registration for review, with particular attention to be drawn to absence notification and certification, Occupational Health arrangements etc. 
v. Access to the company’s HR policies and procedures including disciplinary and grievance and equal opportunities policies. 

The company relies on relevant induction information being made available by each client to its staff, relevant to the duties of the role assigned. Typically, this will include information such as meals facilities; toilets/lockers/cloakrooms; protective clothing specific to the role; fire regulations/drills/evacuations onsite; first aid arrangements and accident reporting.   

Part of the booking procedure also involves requesting that, upon arrival on assignment all staff receive an introduction to their immediate supervisor and fellow employees; an introduction to working arrangements within the setting and the opportunity to gain some familiarity with the working practices. 

To ensure that staff are aware of the induction information they may be expected to know, the company advises them at the registration meeting and their reporting instructions. 

The purpose of carrying out pre-employment health checks is for the protection of both healthcare worker and patient to:

a. ensure that prospective staff are physically and psychologically capable of doing the work proposed, taking into account any current or previous illness
b. identify anyone likely to be at excess risk of developing work-related diseases from hazardous agents present in the workplace;
c. ensure, as far as possible, that the prospective employee does not represent a risk to patients and that they will be doing work that is suitable and safe for them.

The procedures in place at Direct Medics to carry out pre-employment health checks and verify the health screening process constitute a three-step process:

1. Serology reports: New registrants must provide stamped and signed screening information appropriate to the work they are seeking; for all applicants this would involve original printed Pathology report showing correct name, date of birth and date of test. Reports will include:

• Hepatitis B surface antibody level
• Evidence of a BCG scar viewed by a suitably trained and experienced Occupational Health Nurse or Dept
• Evidence of either 2 MMR immunisations or a positive antibody for Rubella and Measles
• Proof of a positive antibody or evidence of two doses of the Varicella vaccine

In addition, anyone seeking work in an exposure-prone setting must provide identity-validated reports relating to

• Hepatitis C
• HIV
• Hepatitis B Surface Antigen status

New registrants will normally have received copies of each of these reports from the Occupational Health department at their most recent place of employment. If, for any reason, the required reports cannot be provided your Compliance Officer will put you in touch with either a local Occupational Health service or a postal pathology service to obtain the relevant screening information. Please note we can only proceed with booking assignments when health status has been verified and confirmed.

2. Health Declaration: a questionnaire detailing travel history, full screening history and general health questions provided by the Compliance Officer for completion. The health declaration must be completed no more than three months in advance of completing registration with the company;

3. Fit Slip: For anyone seeking hospital work in Northern Ireland, Scotland, Wales and England. Serology reports and health declaration are submitted to Healthier Business, our independent Consultant-led Occupational Health service. Healthier Business will verify suitability to work in either an exposure-prone or non exposure-prone setting.  The fit slip will detail any adjustments required to enable registrants to undertake the duties required.

This policy details the process for reporting, recording and notifying accidents, incidents, infectious diseases and deaths that occur when agency staff are on assignment.  Learning from incidents is a vital part of maintaining the safety of patients, staff and visitors in order that the Agency ensures safe standards of care are maintained.  Agency staff are reminded also to check the corresponding policy at the client organisation to ensure that any additional requirements at the location of the assignment are adhered to.   

RIDDOR 

The Reporting of Injuries, Diseases, and Dangerous Occurrences Regulations (Scotland) 1995 updated 2013 is the law that requires employers, and other people in control of work premises, to report and keep records of: 

i.     work-related accidents which cause death;
ii.    work-related accidents which cause certain serious injuries (reportable injuries);
iii.   diagnosed cases of certain industrial diseases; and
iv.   certain ‘dangerous occurrences’ (incidents with the potential to cause harm).

Serious accidents, building incidents and certain work-related diseases in accordance with the Reporting of Injuries, Diseases, and Dangerous Occurrences Regulations (Scotland) 1995 must be reported to the Health and Safety Executive. This includes serious injury, over 3 and 7-day injuries, specified work related illnesses and serious building related problem within 10 days The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 

Accidents 

Any injury - including minor injuries – resulting from an accident whilst on assignment should be recorded both in the 'accident book' at the employing client and in the agency’s ‘accident book’. This is mainly for the benefit of agency staff as it provides a useful record of what happened in case, they need time off work or need to claim compensation later. Recording accidents also helps the agency and employing client to see what's going wrong and take action to stop accidents in future. 

Incidents 

In the ‘Incident and Near Miss Reporting Policy and Procedure’ (September 2011) An incident is defined by the Health and Social Care Board as, ‘Any event or circumstances that could have or did lead to harm, loss or damage to people, property, environment or reputation’.  The Board goes on to list the following occurrences that would typically be regarded as ‘incidents’: 

i.      Security Incident: Patient or Service user absence; theft of HSCB property and/or staff personal property; malicious damage; removal of non-prescribed substances and alcohol; removal of offensive weapons; restraint and any other issue which poses a threat to services users, staff or visitors; 
ii.      Fire Incident: any incident no matter how small, involving fire or fire warning systems (including false alarms);
iii.     Vehicle Incident: any incident involving a vehicle e.g. Road traffic accident, excluding vandalism or theft which would be classified as a security incident;
iv.     Violence, Abuse or Harassment Incident: any incident involving verbal abuse, unsociable behaviour, racial or sexual harassment or physical assault, whether or
not injury results;
v.      Personal Accident or Injury Incident: any accident, no matter how small, which did or could have adversely affected any person;
vi.    Ill health incident: any case of known or suspected work or environment related ill health;
vii.   Clinical Incident: any incident, except medication error, directly related to patient treatment or care which did or could have resulted in adverse outcome (e.g. Treatment, medical equipment failure etc);
viii.  Medication Incident: any medication incident which did or may have caused actual or potential harm to patient(s):
ix.    Environmental Incident: Environmental incidents are those which have resulted in damage or danger to the natural environment. This may include damage to water courses or land or emissions to the air as a result of accidental pollution e.g. spillage, leakage or uncontrolled discharge of substances, emission to air of gas, dust, fumes or other pollutants, escape or improper storage or disposal of waste, etc.

All incidents listed above must be reported to the Agency.  The agency will record all notifications, and any further information or advice received in respect of such incidents.  In addition, dependent upon the circumstances surrounding the incident itself, further notifications may be necessary, including: 

Health and Safety Executive: Serious accidents, building incidents and certain work-related diseases in accordance with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 must be reported to the Health and Safety Executive UK. This includes serious injury, over 3-day injuries, specified work related illnesses and serious building related problems.  

Police: In the event of instances such as burglary, theft, fraud, assault etc. the police should be informed. 

All agency staff have a responsibility to:  

i.    Report to the agency any incident or near miss they are involved in (the agency will require full information to notify the relevant authority);  
ii.    Attend any education and training sessions available in relation to incident reporting and management;  
iii.  Co-operate with any subsequent investigation.

Infectious Diseases

Infectious diseases are caused by pathogenic microorganisms, such as bacteria, viruses, parasites or fungi; the diseases can be spread, directly or indirectly, from one person to another. Zoonotic diseases are infectious diseases of animals that can cause disease when transmitted to humans.  Under the Health Protection (Notification) Regulations 2010, there are 35 ‘notifiable’ diseases (ie those which must be treated under RIDDOR).  All agency staff should be familiar with diseases are notifiable and take necessary steps within the setting of their assignment to ensure that statutory obligations in this regard are adhered to. 

Deaths

1. Death of a service user following palliative care
   i.     The service user’s next of kin will be notified immediately. 
   ii.    If the family/next-of-kin were not present at time of death, they will be notified as soon as possible.  Upon arrival, the family will be allowed time with the deceased if they so wish, and consulted as to the type of burial required and preferred funeral director; 
   iii.   The hospital will certify death and provide the appropriate death certificate, which is then passed to the family with a cremation form if required;
   iv.    A note of the time and death must be made in the service user’s clinical notes, and the care plan is consulted to confirm any religious/ethnic/cultural considerations to be observed before handling the body.
2. Sudden death of a service user
   The hospital will notify the coroner/Procurator Fiscal;
   i.  The family/next-of-kin will be notified as soon as possible.  Upon arrival, the family will be allowed time with the deceased if they so wish, and consulted as to the type of burial required and preferred funeral director; 
   ii. The medical team will certify death and provide the appropriate death certificate, which is then passed to the family with a cremation form if required;
   iii. A note of the time and death must be made in the service user’s clinical notes, and the care plan is consulted to confirm any religious/ethnic/cultural considerations to be observed before handling the body.

All accidents, incidents, communicable diseases and deaths occurring where an agency worker has been supplied are reported to the Care Inspectorate and other relevant organisations in accordance with legislation and procedures above. 

The purpose of this policy is to outline the process for recruiting staff to vacancies.  Please refer to the company’s Operational Policy for detail relating to Pre-employment checks through which a candidate will register with Direct Medics Ltd.    

Booking an Assignment 

Upon completion of registration, the assigned Recruitment Consultant will make contact by SMS, email and telephone to discuss potential placements, particularly if staff regularly update their Consultant regarding availability. At this stage Recruitment Consultants can send a login to candidates who have satisfied all relevant compliance requirements for the Direct Medics App. This is an opportunity to be informed about jobs first so it is important that regular contact is kept; this is especially important in the event of a change to location, grade or specialty.  

When staff members are interested in booking an assignment, they must contact their Recruitment Consultant as soon as possible, via email, text, phone or via the App. They will be referred to their Compliance Officer in the event that registration documents have expired, otherwise their details will be put forward immediately for consideration.  If selected, the company will confirm the details verbally and follow up with a written confirmation by email or App notification. The confirmation will include all relevant information about the assignment, including reporting instructions, any travel and accommodation arrangements and instructions on payment for the assignment. Any queries upon receipt of your confirmation should be addressed immediately to allow for a smooth start to assignments. 

Payment 

Different pay rates apply to different assignments.  Before commencing an assignment staff members are informed both verbally and in writing, the rate of pay applicable to the assignment. Payment is made to staff on submission of a timesheet without exception.  All information given must be accurate and timesheets must be completed in full and every shift must be authorised with an appropriate signature. The position / grade worked must also be identified.  Payroll takes place weekly, with all timesheets submitted by 11.00am on Monday paid to arrive by the following Monday.  Payment will be made by Banker’s Automated Clearing Services (BACS) directly into bank/building society accounts, with a pay slip emailed. Staff members must advise of any change to personal circumstances, e.g. change of address, email address or bank account.  

The Company is required by law to deduct PAYE and Class 1 National Insurance Contributions. Therefore, staff members are required to pay income tax on earnings (if they exceed the threshold for the current financial year). The rules affecting people working through agencies are contained in Section 134 TA 1988 (formerly section 38, Finance (No.2) Act 1975).  Dependent upon earnings, staff members may also be eligible for auto-enrolment onto the company’s pension scheme (which can be opted out of if they so wish). 

Any queries relating to pay must be directed to the Finance team at Head Office; email queries should be directed to [email protected]. 

Removal from the Company’s Register 

Staff may be removed from the register in the following circumstances: 

1. Where a member’s conduct or standard of work has seriously fallen below the level required by the company.
2. If it is believed that a member has acted in an unprofessional manner, the company reserves the right to remove you from your assignment and not re-assign until the matter has been investigated and resolved. 

Examples of such conduct are as follows. This list is not exhaustive:

• Failure to attend a Client having accepted an engagement, or repeated lateness. 
• Failure to provide care in a fashion consistent with the member’s professional code of conduct or in a caring and appropriate manner, e.g. sleeping on duty, non-adherence to clinical instruction etc. 
• Failure to carry out reasonable instructions of the Client. 
• Breach of trust involving the Company or the Client. 
• Disclosure of confidential information to a third party relating to either a Client or the Company. 
• Misconduct, affecting either the Client or the Company. This includes being under the Influence of alcohol or any substance that will adversely affect your performance, theft, abusive or violent behaviour, harassment, criminal conviction etc.  

All staff should ensure full understanding of what is required. 

The Direct Medics Ltd. statement of general policy relating to health and safety is:

i.     to provide adequate control of the health and safety risks arising from our employees work activities;
ii.    to consult with our employees on matters affecting their health and safety;
iii.   to ensure that our clients provide and maintain safe plant and equipment;
iv.   to ensure safe handling and use of substances;
v.    to provide information, instruction and supervision for employees;
vi.   to ensure all employees are competent to do their tasks, and to give them adequate training;
vii.  to prevent accidents and cases of work-related ill health;
viii. to maintain safe and healthy working conditions; and
ix.   to review and revise this policy as necessary at regular intervals.

Risk Management

Risk management is recognised within the organisation as an integral part of good practice. It is the ultimate goal of this policy that the effective management of risk is an integral part of everyday practice.

Incident reporting is a fundamental tool of risk management, the aim of which is to collect information about adverse incidents, including near misses and hazards, which help to facilitate wider organisational learning. Incidents and their consequences, if not properly managed, may result in loss  of public confidence in the organisation, loss of assets and unnecessary proliferation of loss.

The following arrangements are aimed at providing a comprehensive and reporting system within Direct Medics Ltd.:

i.     A designated senior person within the organisation with responsibility for the local complaints procedure;
ii.    The arrangements for making complaints are publicised to service users;
iii.   All staff receive training and guidance on the complaints procedure to enable them to deal with complaints on the spot;
iv.   The organisation has an effective system for the recording of complaints;
v.    The organisation monitors how it, or those providing care on its behalf, deals with, and responds to, complaints;
vi.   The organisation learns from complaints and improves services as a result
vii.  All reported complaints are graded according to severity as well as potential future risk to users and/or to the organisation;
viii. Information on complaints is reported to and considered by the management team.

Examples of Verification:

i.      Complaints policy/procedure;
ii.     Compliance with the standards for complaints handling;
iii.    Evidence of dissemination of learning within the organisation and use of the Equality Good Practice Review on the handling of complaints;
iv.    Management meeting minutes;
v.     Training programmes;
vi.    Training evaluation forms;
vii.   Induction programme;
viii. Customer feedback;
ix.    Independent review reports (including those from RQIA and BSO).

The organisation must be aware of its risk profile across its entire range of activities. Specific risk assessments may be undertaken but in order to prioritise action an annual organisation-wide review is necessary to ensure that all exposures are duly considered.

Key Risks

“Key risks” (those which have significant potential to impair or affect the operational or financial ability of the organisation to deliver services and meet objectives, and may be strategic or operational in nature) themselves require a comprehensive assessment of risks, creating a continuum of risk assessments across the length and breadth of the organisation, encompassing all risks.

Examples of Verification:

i.      Risk management strategy;
ii.     Risk identification tools;
iii.    Risk assessment tools and forms;
iv.    Completed risk assessments;
v.     Risk treatment options;
vi.    Evidence of risk treatment;
vii.   Business plans;
viii. Annual report;
ix.   Risk registers;
x.    Management meeting minutes;
xi.   Monitoring and review procedure;
xii.  Incident and complaints analysis.

The above contributes to the organisation’s risk management culture, which needs to be embedded at all levels throughout the organisation. An appropriate training programme is an important means of achieving competence and helps to ensure compliance with safe working practices. All job descriptions for employees within the organisation should contain reference to their risk management responsibilities.

Independent Review

Reviews by independent bodies assist the organisation in demonstrating performance, and also in highlighting areas that need to be addressed. This gives the organisation assurance that controls are working satisfactorily and that local and national targets are being met.

The following aspects of company practice provide assurance that Direct Medics Ltd. could meet the requirements of an independent review:

i.    The role of the Audit Committee in reviewing and providing assurance on the risk management systems in place is clearly defined;
ii.   The role of the internal audit function in reviewing and providing verification on the systems in place is clearly defined;
iii.  The internal audit function carries out periodic reviews to provide assurances to the organisation that a suitable risk management system is in place and working properly taking into consideration reviews by other review bodies;
iv.  The organisation has a system in place to ensure that reviews carried out by external agencies are effectively co-ordinated and any recommendations implemented within the context of available resources;

Examples of Verification

i.    Internal Audit reports;
ii.   Audit minutes;
iii.  Minutes of the management meetings;
iv.  Reports from RQIA and other review bodies;
v.   Reports from external audit.

Smoking

This policy has been designed to protect all agency staff and service users from exposure to second-hand smoke.  Under the terms of Smoking, Health and Social Care (Scotland) Act 2005, all work premises are smoke-free (no-smoking) areas. Classed as a place of work, enclosed premises are strictly smoke-free as are any semi-enclosed premises, semi-enclosed or enclosed premises leading to an entrance or any open structure located on the premises. 

i.  The term ‘semi-enclosed’ in this context refers to any porch, veranda, balcony or stairwell that is located on work premises; 
ii. The term smoking covered under the terms of Smoking, Health and Social Care (Scotland) Act 2005 refers to “smoking tobacco or anything which contains tobacco, or smoking any other substance; and (b) smoking includes being in possession of lit tobacco or of anything lit which contains tobacco, or being in possession of any other lit substance in a form in which it could be smoked.” 

Any individual who wishes to smoke must first exit the premises and locate to the designated smoking area.  Designated disposal points must be used for the disposal of waste while smoking, whether smoking related or otherwise.  

Local and/or company disciplinary procedures will be followed if a member of staff does not comply with this policy.  Those who do not comply with the Health Act may also be liable to a fixed penalty fine and possible criminal prosecution. 

Alcohol and Substances

This policy is based on the following aims:

i.    To maintain a safe and healthy environment for all service users and staff;
ii.   To minimise drug and alcohol related injuries to persons or property;
iii.  To comply with applicable laws and legislation;

The use of drugs and/or alcohol by members of staff is strictly prohibited at all times and under all circumstances.   

The company recognises its duty as an employer to provide and monitor for employees, so far as is reasonably practicable, a working environment which is reasonably suitable for the performance of their contractual duties and this includes providing a drug and alcohol-free environment.  However, the company makes a distinction between patterns of alcohol or drug misuse which point to addiction in staff, such as drinking or drug taking to excess continually, regularly or in intense episodes and, on the other hand, random instances of drug taking or excessive drinking which effect work. 

The company regards alcohol and drug misuse of the first kind as first and foremost a health problem and its approach will be informed by this understanding.  Other forms of drink and drug consumption that affect work will be treated as conduct or performance issues and dealt with according to the disciplinary procedure.  This includes cases where employees attend work under the influence of drugs or alcohol.  In all such circumstances, where a member of staff either attends work under the influence of drugs or alcohol or uses drugs or alcohol while at work: 

i.    The member of staff will be sent home;
ii.   The disciplinary procedure will be applied;
iii. As far as is practicable, job security will be maintained for any member of staff participating in treatment and/or counselling in an attempt to deal with drug or alcohol abuse.  Where a member of staff has to be away from work to undergo treatment, their job will be held in accordance with contractual sickness procedures.  However, it must be accepted that, in the long-term, job security must depend upon work returning to an acceptable level; 
iv. Drug or alcohol abuse will not in itself constitute grounds for dismissal, unless the staff member’s actions or performance reached an unacceptable level.  Such cases will be dealt with under normal disciplinary procedures.

Direct Medics Ltd. believes that staff development and learning should be an integral part of the organisation’s strategic planning so that staff can perform their individual jobs effectively and, in doing so, ensure that the organisation achieves its objectives.  The central aim is therefore to provide an environment where continuous development can take place and where staff are supported and enabled to meet the changing demands and priorities of the company and its service users.  

To achieve this aim, learning and development needs will be regularly reviewed and staff will be encouraged to play an active part in identifying their own learning needs, selecting appropriate learning methods and in assessing the outcomes and effectiveness of their learning.  

Options for learning and development may include:  

i.   On the job learning / learning from others in the organisation
ii.  Internal workshops / learning for groups or teams
iii. Self-paced learning / open learning books, videos
iv. Off-job courses
v.  Mentoring

Induction

All new staff will take part in an induction programme including an introduction to all other staff, company targets, equal opportunities policy, working practices and procedures.

Coaching in immediate work processes and tasks and for inducting new staff into the organisation will be the responsibility of the appropriate member of the management team.

Performance Development Reviews

Individual staff learning needs will be identified with their Team Leader during regular supervision sessions and a six-monthly appraisal process. Collective learning needs may be identified within staff groups or teams and discussed with the appropriate Team Leader.

Each Team Leader has the lead responsibility for the development of their staff, for assessing their learning and development needs and identifying suitable learning methods.

Recording, monitoring and Evaluation

The Recruitment Manager has responsibility for ensuring that a clear procedure is in place for recording, monitoring and evaluating learning activities. Team Leaders will ensure that the procedure is followed for each learning activity.

i.   Details of each learning activity will be received on a form that will include: a description of the learning; agreed objectives; method of learning; resources needed; evaluation of outcomes;
ii.  The staff member will complete the learning form with their Team Leader who will also be responsible for ensuring that the learning is monitored and that the outcomes and effectiveness of the learning are fully discussed and recorded.

The form will be kept within the Personnel records to provide a clear record of learning for review and evaluation.

Learning Requests

All learning requests will be considered sympathetically. However, the availability of learning resources will depend on factors such as budgetary constraints, work commitments and learning priorities necessary to fulfil the organisation’s objectives. In practice, there may be occasions when a learning request is postponed or refused due to other priorities.

A further budgetary consideration will be the extent to which skills acquired through learning can be applied within the organisation, within a reasonable time period. Individual staff members may be interested in obtaining accreditation or a nationally recognised qualification. The company will be sympathetic to requests of this sort, where the learning has a demonstrable relevance to company objectives, and in co-operation with the staff member will seek to provide appropriate support and assistance.

Reimbursement of Learning Costs

Where Direct Medics Ltd. contributes towards enabling an employee to study for a qualification to meet company forward plan commitments, reimbursement of costs by the employee will be required in the following situations:

i.   All fees would be reimbursed to direct Medics Ltd. if the employee left during the period of study or did not complete the study programme;
ii.  50% of fees would be reimbursed to Direct Medics Ltd. if the employee left within a period of 12 months following completion of the period of study;
iii. Monies owed to Direct Medics Ltd. will be deducted from the employee’s salary payment or other money due to the employee.

Time off for learning, reimbursement of travel costs and payment of membership fees will be at the discretion of the Managing Director. Direct Medics Ltd. will not usually contribute to the costs of textbooks.

Aims 

• To set standards which promote a professional image and instil patient and public confidence 
• To ensure staff are familiar with current evidence available on the wearing of uniform/dress in healthcare  
• To permit identification for security and communication purposes  
• To enable mobility and comfort for the wearer 
• To comply with Health & Safety Legislation and to reduce risks of infection to staff, patients and visitors 

Uniform Rules 

• No jewellery, including wrist watches, fitness/ activity trackers (e.g. Fitbits), bracelets, rings, earrings, visible body jewellery or necklaces should be worn whilst on duty and when undertaking a clinical procedure or encountering patients. Note the following exceptions: A single plain band/ ring, Medic Alert and Fob watches. 
• Long hair must be tied back 
• Wear the provided uniform with no variance.  
• Wearing theatre scrub attire, all such staff members must change into a new set of scrubs when returning to duty in their departments. 
• Uniforms must be changed daily or when visibly soiled with blood or body fluids. 
• Uniforms should be washed without other items of clothing at 65oC or above in a domestic washing machine 
• Clinical Staff who wear a uniform should change into & out of uniform at the workplace.  Anyone permitted by the client to wear a clinical uniform to and from work should have it covered completely when travelling.  A clean uniform should be worn for each shift. 

Direct Medics (Scotland) Ltd. will provide all staff with two tunics for use during assignments.  These tunics will be replaced by the company a maximum of once per year; any additional tunics will be provided at a cost of £14.00 per tunic.  Staff are expected to supply their own trousers and shoes, which must be clean and suitable for purpose on arrival at each assignment.  

All staff are provided with an agency identification badge upon registration, which must be always displayed clearly whilst on assignment.  An induction checklist card will also be provided; this must also be stored within the lanyard supplied alongside the identification badge and used as a reference to the information required when entering a clinical setting for the first time 

Whistleblowing is defined in the Public Services Reform (Scottish Public Services Ombudsman) Healthcare Whistleblowing Order 2020 as: 

"when a person who delivers services or used to deliver services on behalf of a health service body, family health service provider or independent provider (as defined in section 23 of the Scottish Public Services Ombudsman Act 2002) raises a concern that relates to speaking up, in the public interest, about an NHS service, where an act or omission has created, or may create, a risk of harm or wrongdoing." 

This includes an issue that: 

• has happened, is happening or is likely to happen
• affects the public, other staff or the NHS provider (the organisation) itself.

People also often talk about ‘raising concerns’ or ‘speaking up’. These terms can also refer to whistleblowing. The issue just needs to meet the definition above, whatever language is being used to describe it. 

Risks can relate to wrongdoing, patient safety, or malpractice which the organisation oversees or is responsible or accountable for. In a health setting, these concerns could include, for example: 

• patient-safety issues
• patient-care issues
• poor practice
• unsafe working conditions
• fraud (theft, corruption, bribery or embezzlement)
• changing or falsifying information about performance
• breaking any legal obligation
• abusing authority
• deliberately trying to cover up any of the above.

A whistleblowing concern is different from a grievance. A grievance is typically a personal complaint about an individual’s own employment situation. 

Healthcare professionals may have a professional duty to report concerns. Managers and all staff (including students and volunteers) must be aware of this, as it can affect how and when concerns are raised. However, the processes for handling concerns should be the same for any concern raised. 

WHO CAN RAISE A CONCERN?

Anyone who provides services can raise a concern, including current (and former) employees, agency workers (and others on short or insecure contracts such as locums and bank staff), contractors (including third-sector service providers), trainees and students, volunteers, non-executive directors, and anyone working alongside NHS staff, such as those in health and social care partnerships. A person raising a concern has usually witnessed an event, but they may have no direct personal involvement in the issue they are raising. 

More than one person can raise the same concern, either individually or together. Anyone receiving a concern must make sure they understand who wants to achieve what and whether everyone wants to be kept informed and updated on the progress of any investigation. 

It is important for everyone involved in this procedure to be aware that some people may feel at greater risk than others as a result of raising a concern. For example: 

• employees whose employment may be less secure, such as agency staff or those who need a visa to work in the UK
• students and others who are due to be assessed on their work
• people from any of the recognised equalities groups.

Some people may consider themselves more likely to be treated unfairly as a result of raising a concern, particularly if they are in more than one of the above groups. It is particularly important to make sure people are aware of the support available through this procedure, and that any concerns they raise are treated seriously. 

If the person is raising a concern about a service that is not their employer, they must be able to raise concerns either directly with their employer or within the service itself, and they must have full access to the National Whistleblowing Standards. 

SUPPORT FOR THE PERSON RAISING A CONCERN 

It can be stressful and isolating to raise a concern, but when someone does raise a concern, they are trusting the organisation and giving it an opportunity to put right a wrongdoing or reduce risk. The organisation must repay this trust by protecting the person throughout the process and making sure they do not suffer any harm as a result of speaking up. 

Anyone receiving a concern will thank the person for raising the concern, listen to them carefully, take the concern seriously, and reassure them that the concern will be handled sensitively, they have done the right thing by raising the concern, and they will not be treated badly, even if no risks are identified. 

The support that is available may include: 

• access to a confidential contact who can provide information and advice on the procedure for raising concerns, as well as support during the process 
• counselling or psychological support services for people suffering from stress because they are involved in this procedure 
• occupational health services which take account of the stress involved in raising a concern 
• considering, with the person who has raised a concern, a range of actions to reduce any consequences they are facing (or think they may face) as a result of raising the concern. These actions may include making changes at work or putting in place temporary arrangements to reduce risk. 

Anyone raising a concern may want to have someone to support them at meetings or throughout the process. This could be a union representative, friend, or colleague. If it is a friend, relative, or colleague, their role is to support the person raising the concern rather than to represent them or respond on their behalf. Union representatives can be more involved in discussions, although it is best if the person raising the concern openly shares the information they have. 

EMPLOYER’S DUTY OF CARE

Employers have a duty of care to their employees and must take all reasonable steps to protect their health, safety, and well-being. They must do everything that is reasonable in the circumstances to keep their employees safe from harm. They also have a moral and ethical duty not to cause or fail to prevent physical or psychological injury. 

Under their duty of care, employers may have to ensure, so far as is reasonably practicable, a safe work environment and provide adequate training so that employees can safely carry out their designated role. 

Employees also have a responsibility to take reasonable care for their own health and safety at work. For example, they should be able to refuse to do work that would be unsafe for them, without fearing disciplinary action. An employee also has a duty to take reasonable care for the health and safety of other employees who may be affected by their acts or omissions at work. In the context of raising concerns, this means that the organisation will have systems in place to protect from detriment anyone who raises a concern. 

LEGAL PROTECTION FOR THOSE RAISING CONCERNS

The Public Interest Disclosure Act 1998 (PIDA) is often called the ‘whistleblowing law’. It is there to protect all ‘workers’ who have made a ‘protected disclosure’ from being treated unfairly as a result of raising a concern. 

A concern is considered a ‘protected disclosure’ when the person raising it reasonably believes that it is in the public interest to raise a concern and that the information available shows that the following has happened, is happening, or is likely to happen: a criminal offence, an act that creates a risk to health and safety, an act that damages the environment, a miscarriage of justice, a breach of any other legal obligation not being met, or concealment of any of the above. It is important to note that making a ‘protected disclosure’ does not mean that the concern must be raised or investigated in a certain way. It provides legal protection for workers who suffer detriment after raising concerns. 

THE INDEPENDENT NATIONAL WHISTLEBLOWING OFFICER

The Independent National Whistleblowing Officer (INWO) will approach each case on the basis that it is better for the organisation involved to identify the learning and improvements that are needed. They can accept concerns directly if they do not feel it is reasonable to expect the person to use their employer’s whistleblowing procedure. 

WHO TO RAISE A CONCERN WITH

The Direct Medics Ltd. Whistleblowing Champion (contact [email protected] confidentially for referral). 

THE NATIONAL WHISTLEBLOWING STANDARDS: TWO-STEP PROCEDURE

Direct Medics Ltd. will adhere to the requirements of The National Whistleblowing Standards (2021) Two-Step Procedure when concerns are raised.  

GENERAL PRINCIPLES

The following general principles will apply to the Disciplinary, Dismissal and Grievance Procedures for agency Nursing, and Healthcare assistant staff. 

Each step and action will be taken without unreasonable delay. Employees should be aware that timelines may vary to those set out in this policy, due to (for example) the volume or complexity of the allegations being considered, or the availability of appropriate members of staff to conduct each stage of the process 

Whenever the employee is invited by the Company to attend a meeting, the employee must take all reasonable steps to attend.  

At all stages of the procedure (except any investigation meetings) the employee will have the right to be accompanied by a trade union representative or a work colleague of your choice. If the employee’s choice of companion is unreasonable (e.g. because they are unavailable for a prolonged period of time or because of a conflict of interest) the Company may ask the employee to choose someone else. If a companion is unable to attend any such meeting the employee may suggest an alternative date, provided it is within 5 working days of the original date. 

• Timing and location of meetings must be reasonable.
• Meetings will be conducted in a manner that enables both the Company and employee to explain their case.
• For appeal hearings following a decision the Company will as far as reasonably practicable, be represented by a more senior manager than attended the first meeting (unless the most senior manager attended that meeting).
• If the employee has difficulty at any stage of the procedure because of a disability they should discuss with HR as soon as possible.

DISCIPLINARY, DISMISSAL AND GRIEVANCE PROCEDURES

PURPOSE

The Disciplinary, Dismissal and Grievance procedures are designed to help and encourage all employees to achieve and maintain appropriate standards of conduct, attendance and job performance.  The aim is to ensure consistent and fair treatment for all in the organisation.  

PRINCIPLES

• No disciplinary action will be taken against an employee until the case has been fully investigated. The amount of investigation required will depend on the nature of the allegations and will vary from case to case.  
• Direct Medics may remove agency staff without pay while an investigation takes place. Such a suspension will be reviewed as soon as possible and will aim to not normally exceed 10 working days.  Suspension of this kind is not a disciplinary penalty and does not imply any decision has been made about the allegations.  
• Misconduct will generally fall into two categories, namely “general” misconduct (in respect of which the general disciplinary action procedure described below applies) and “gross” misconduct, which is of so serious a nature that it justifies instant dismissal for a first offence.  Listed below are examples which would normally be considered to be either general misconduct or gross misconduct.  However, it should be recognised that neither list can be regarded as complete to meet every case, and also that action described as general misconduct may amount to and be treated as gross misconduct if the circumstances or the manner of the misconduct are such as to warrant serious disciplinary action.   

These lists should be regarded therefore as being illustrative rather than exhaustive.

Examples of “gross” misconduct:

Summary dismissal (i.e dismissal without notice or pay in lieu of notice) may be necessary in cases of gross misconduct.  For guidance, the following are examples of the offences which may be regarded as gross misconduct and will normally result in summary dismissal.  It is emphasised that this is not an exhaustive list: 

• Unauthorised use or disclosure of confidential information or business matters relating to the Company, its clients, temporary workers or applicants.
• Unauthorised amendments to the Company’s profile pages on any networking site or Networking Site as defined in the Company’s Email, Telephone, Computer Facilities and Social Media policy or website.
• Acts of violence, including physical assault, unlawful discrimination, drunkenness, taking of non-prescribed drugs in such a way as to impair the ability to carry out work or conduct of any kind which endangers the health and safety of others.
• Any bullying or harassment of fellow employees, clients, candidates or any other person including via the company’s facilities or any Networking Sites (as defined in the Email, Telephone, Computer Facilities and Social Media Policy).
• A criminal offence committed at work other than a minor road traffic offence committed in the course of the employment, or an offence committed outside work which is incompatible with the employee remaining in the Company’s employment.
• Falsification of information or references on appointment.
• Theft or fraudulent activity.
• Unauthorised absence or gross negligence in the performance of duties.
• Breach of the Company’s Anti-Bribery and Corruption Policy.
• Any conduct tending to bring the Company, or the employee into disrepute or which results in the loss of custom of a client, temporary or applicant or a loss of business.
• Working for or assisting a competitor of the company or seeking to establish a business which is likely to compete with the company or divulging confidential information concerning the company and its business.
• Serious insubordination or refusal to obey a lawful instruction in connection with the employment.
• Deliberate and serious damage to property or causing any loss, damage or injury through negligence.
• Serious misuse of the Company’s property or name.

Examples of “general” misconduct

The following may be regarded as reasons for disciplinary action in that they deviate from accepted standards and constitute general misconduct.  The employee’s first offence will usually result in a written warning.  Repetition of offences following a warning could lead to a final written warning as appropriate.  Thereafter any repetition will result in dismissal.  It is again emphasised that this is not an exhaustive list: 

• Poor job performance.
• Poor time-keeping.
• Failure to comply with the conditions of your employment contract.
• Unseemly or disruptive conduct.

DISCIPLINARY ACTION

The following is the disciplinary action that may be taken against an employee in cases of misconduct or unsatisfactory performance:

STAGE 1 – FORMAL WRITTEN WARNING

If an employee’s conduct or performance is unsatisfactory, they will be given a formal written warning.  This written warning will include the reason for the warning and a note that, if there is no improvement after a specified period, a final written warning will be given.  A copy of the written warning will be given to the employee and a copy will be placed on their personnel file. The warning will be disregarded after 6 months satisfactory service. 

STAGE 2 – FORMAL FINAL WRITTEN WARNING

If following a written warning, conduct or performance remains unsatisfactory, or if a serious incident occurs, a final written warning will be given making it clear that any recurrence of the offence or other serious misconduct within a specified period will result in dismissal. A copy of the written warning will be given to the employee and a copy will be placed on their personnel file. The warning will then be disregarded after 12 months satisfactory service. 

STAGE 3 – DISMISSAL OR OTHER SANCTION

If there is no satisfactory improvement in conduct or performance, or if further serious misconduct occurs within 12 months, the final step in the procedure may be dismissal, either with or without notice or payment in lieu of notice, or some other action short of dismissal such as disciplinary suspension or transfer to another department or job. Stage 3 may also apply to any gross misconduct (even if there are no active warnings on file) or any misconduct during your probationary period.  

DISCIPLINARY PROCEDURE

Informal Discussion

Minor breaches of discipline, misconduct, poor time-keeping, etc may result in an informal discussion with the employee’s contact within Direct Medics.

Although an informal warning will not be formally recorded for the purposes of any future disciplinary hearing, a note of the conversation may be kept on the employee’s personnel file.

It is expected that in most cases an informal discussion will resolve most difficulties. Where an employee commits a more serious act of misconduct or fails to improve and maintain that improvement with regard to conduct, behaviour or job performance, the formal steps detailed below may be taken.

Formal Discussion

Step 1 - Written Statement

The Company will inform the employee in writing of the alleged conduct or characteristics, or other circumstances, which lead the Company to contemplate dismissing or taking disciplinary action against the employee. This shall be done promptly after becoming aware of the circumstances, and the employee shall be invited to attend a meeting to discuss the matter, once any necessary investigations have been conducted to establish the facts of the matter. The Company will provide a copy of any relevant documents which will be used at the disciplinary meeting to the employee in advance of the meeting.  

Step 2 – Meeting

The meeting will take place before any action is taken.

The meeting will not take place unless:

• the Company has informed the employee of the ground or grounds for contemplating disciplinary action or dismissal; and
• the employee has had a reasonable opportunity to consider his response to that information.

The employee has the right to be accompanied at the meeting by a work colleague or a Trade Union representative.

After the meeting, the Company will inform the employee in writing of its decision as soon as reasonably possible (but normally within one week of the meeting) and notify him of the right to appeal against the decision if he is not satisfied with it. 

Step 3 – Appeal

If the employee does wish to appeal, s/he must inform the Company within 5 working days of receiving the decision, and on doing so the Company will invite him/her to attend a further meeting. 

The appeal meeting may not necessarily take place before the dismissal or disciplinary action takes effect but it will be arranged within a reasonable period of time. 

The appeal will be dealt with by a more senior manager than at the Step 2 meeting.  Where this is not practicable, the company will hear the appeal and decide the case as impartially as possible. 

After the appeal meeting, the Company will inform the employee of its final decision in writing, as soon as reasonably possible (but normally within one week of the meeting). The Company may uphold or revoke the original decision or substitute a different penalty.  

GRIVANCE PROCEDURE

If an employee has a problem or concern about their work, working conditions or a relationship with a colleague, they should aim to settle their grievance informally. 

If an employee’s grievance cannot be settled informally, or a formal approach is preferable, the employee should raise it formally with management by following the procedure below. 

Step 1 - Written statement

The employee must set out their grievance in writing and send this statement to their within Direct Medics unless your grievance concerns their line manager in which case the grievance should be submitted to the Recruitment Manager. Include facts, dates, a chronology and names of individuals, as appropriate. The subject heading should be marked as “Formal Grievance”.  

Step 2 – Meeting

The company will invite the employee to attend a meeting to discuss the grievance, normally within 5 days, but longer where it is necessary to undertake an investigation to establish the facts or it is otherwise impracticable. 

The meeting will not take place unless:

• the employee has informed the Company of the basis for the grievance in writing; and
• the Company has had a reasonable opportunity to consider its response to that information

After the meeting the Company will inform the employee of its decision, as soon as reasonably practicable (but normally within one week of the meeting), and the Company will notify the employee of his right to appeal if he is not satisfied with it. 

Step 3 - Appeal

If the employee does wish to appeal, he must inform Barry Shannon, Human Resources within 5 working days of receiving the decision, and on doing so the company will invite him to attend a further meeting. After the appeal meeting, the Company will inform the employee of its final decision as soon as is reasonably practicable (but normally within one week of the meeting). The Company’s decision is final. 

Section 1: Introduction, Purpose, Definition, and Scope

1. Social media platforms offer powerful new ways to express and share ideas. Their use presents Direct Medics and its staff with new and exciting opportunities; but it also introduces potential risks that must be managed. 
2. The purpose of this policy is to protect the Agencies candidates, staff, reputation, and values while supporting the effective use of social media to benefit the work of the Agency. 
3. In this policy, the term social media is used to describe a broad range of technology platforms, which allow the creation, and sharing of content across a virtual community. Examples include well known services such as Facebook, Twitter, LinkedIn, YouTube, Instagram, WhatsApp, and Snapchat; as well as smaller services such as personal blogs and discussion forums. 
4. This policy applies to all staff, including individuals who have an honorary contract with Direct Medics, temporary workers, agency staff, and individuals engaged with the agency on a self-employed contract basis 

Section 2: General principles

1. Staff must never use their personal social media to engage with patients. For example, staff should never send a “friend” request to a student on Facebook, nor accept such a request from a patient, and staff should never chat with patients over WhatsApp or via Twitter direct message (DM). 
2. Use of social media must at all times be consistent with other Direct Medics policies, such as the Data Protection policy.  
3. In order to protect the University’s students, staff, reputation, and values, care must be taken: 

• Not to breach confidentiality
• Not to do anything that could be considered discriminatory against, or bullying or harassment of any individual
• Not to breach copyright or other intellectual property laws
• Not to bring Direct Medics into disrepute

Section 3: Official Direct Medics social media accounts

When contributing to Direct medics social media activities you are representing the agency and must at all times follow the guidelines for use of official agency social media. 

Section 4: Using personal social media accounts

1. Social Media can be an effective way for candidates to connect with peers in Hospitals and in the wider world, to develop and improve their professional profile, and to support their work by providing opportunities for reflection, discovery, and collaboration. Candidates are encouraged to do this, and to state and celebrate their connection with the Direct Medics. 
2. As a member of staff your activity on social media is likely to be associated with the Agency, regardless of whether you are acting in a professional or personal capacity, and whether you are using a using an official Direct Medics social media account or a personal one. 
3. Therefore when using a personal account in a professional capacity it is important to make it clear that you are acting on behalf of yourself and not the Agency. In particular: 

• Do NOT use account names that suggest the account is an official Direct Medics Account
• Do NOT use the Direct Medics Logo without official authorisation.
• Where your personal social media account indicates your association with Direct Medics, consider using a disclaimer.
• Staff should ensure there is always a clear separation between work use and social use of their social media accounts. 

Section 5: Online Safety

1. To protect yourself online, follow these key guidelines: 

• Limit the personal information you post on social media. 
• Publish as little personal information as you can.
• Remember that it is often possible to link your individual social media accounts and so build up a wider picture of your social media footprint. So as well as considering how much personal information you publish on any single site, consider how much personal information you have published across all sites
• Never publish your address or financial details on social media.
• Be aware of location services accidentally giving away personal information. Some social media platforms include your location with every new post. Posting from a mobile phone, in particular may include a precise GPS location. Smartphones and many cameras may also embed location data in digital photographs.
• Avoid allowing social media apps access to your contacts list or address book – in general, don’t give them information they don’t need.
• Watch out for Fraud
• Use the same caution when clicking links or opening documents from social media that you would for emails - social media is increasingly being targeted by phishers and other fraudsters.

Section 6: Social Media and the Law

1. Any illegal or unlawful acts that can be committed using words or images can equally be committed using social media. 
2. Posts on social media that violate the general principles listed in section 3 of this document could potentially be in breach of legislation such as: 

• The Communications Act 2003
• The Contempt of Court Act 1981
• The Data Protection Act 2018
• The Defamation Act 2013
• The Malicious Communications Act 1988
• The Offences Against the Person Act 1861
• The Protection From Harassment Act 1997
• The Sexual Offences Act 2003

Section 7: Disciplinary action over Social Media use

All employees are required to adhere to this policy. Any breaches may lead to disciplinary action. Serious breaches of this policy, for example incidents of bullying of colleagues or social media activity causing serious damage to the organisation, may constitute gross misconduct and lead to summary dismissal. 

Direct Medics(Scotland) is committed to providing a quality service in the provision of locum and permanent staff and the ancillary services needed to support our customers. The company assesses the quality of our service through a series of management procedures and continual improvement measures which are directly in line with the requirements of the Care Inspectorate 

• Document audits: the Registered Manager reviews a selection of candidate files weekly, based on those placed to work on a date selected by the Manager.  The results of this audit are disclosed on the monthly monitoring; 
• Quality monitoring: the Recruitment team obtains verbal or written feedback for each candidate, at each clinical setting in which they are placed.  This information is checked monthly to ensure all clinical settings have been covered, with the results disclosed on the monthly monitoring; 
• Supervision and Appraisal: all supervision and appraisal records are securely and centrally located.  A review of supervision and appraisal activities is disclosed on the monthly monitoring; 
• Complaints and incidents: all complaints and incidents are securely and centrally located.  A statement as to the current status of active complaints and incidents is disclosed on the monthly monitoring 

In addition, the nursing division takes part in company-wide quality monitoring activities which form part of our Quality Management System in maintenance of ISO 9001:2008 certification.  Activities include: 

• Quality targets for each team and core process grouping; 
• Monthly management meetings which monitor the improvements being made and operational duties 
• Quarterly reviews which review the targets for the previous quarter and planned improvements for the following quarter 
• Bi-annual management reviews which take the findings for the preceding two quarterly reviews and ensure that we are continually improving our quality of service 
• Annual internal audit of each company department against ISO 9001:2008 

In addition to the above in line with the company’s ISO 9001:2008 certification, the company adheres fully to the minimum standards set out by the Department of Health, Social Services and Public Safety including co-operation with and inspection by the Regulation and quality Improvement Authority. 

Management Structure & Responsibilities for Direct Medics Nursing:

REGISTERED PERSON:

• Ensures registered nurse oversees recruitment of staff
• Deals with alert letter and issues around competence of staff
• Ensures appropriate levels of insurance in place

REGISTERED MANAGER

• Reports issues to Registered Person
• Reviews complete file for each applicant to the register and confirms suitability for placement
• Reviews the ongoing suitability of nurses being placed in assignments annually

RECRUITMENT DIRECTOR:

• Prepares monthly monitoring figures and audits service delivery in adherence with procedures

DIVISION HEAD & RECRUITMENT CONSULTANTS:

• Liaises with Registered Manager to confirm suitability of applicants for roles
• Confirms assignment for candidates in line with recommendation of Registered Manager.

COMPLIANCE OFFICERS:

• Complete and maintain all checks required by NHS Employment Check Standards and RQIA

The service contracts held by Direct Medic Ltd. are instigated via procurement exercises and as such, the expected performance level for any resulting service contracts is explicitly defined.  The company manages service contracts using the following methods: 

1. Effective bid management: At the point of tender issue, the assigned Bid Manager examines the specification of the requirement and carries out a ‘Bid/No Bid’ exercise based on the company’s ability to fulfil the requirements of the resulting service contract.  The final decision as to whether to bid would be dependent upon factors such as human resource planning, marketing activities, management information requirements and the current business objectives;
2. Tender Management: In the course of completing a tender bid, the team also identifies what resources not already in place are required in order to perform effectively under the resulting service contract;
3. Contract Instigation Plan: Upon notification of a contract award, the resources and reporting required in order to service the contract are notified to the Board for approval;
4. Performance Monitoring: During the course of the service contract, close monitoring of the team’s performance takes place for several reasons:

i. To ascertain the company’s performance relative to any Key Performance Indicators on the service contract;
ii. To identify issues relevant to contract performance and take remedial action aimed at service improvement;
iii. To safeguard against any detriment to the company in the event that the service contract is renewed.

The Quality Management System (QMS) for Direct Medics applies a succinct method of monitoring and controlling the quality of the company’s processes by means of the procedures outlined in this manual as per the requirements of the ISO 9001:2008 standard for Quality Management Systems.  

Quality Procedures

The Quality Management System is implemented using the following procedures:

• Monitoring reports - one per month, undertaken by an appointed Monitoring Officer not directly involved in the day-to-day running of the service.  The monitoring report will include reference to: 

i.  Service users /patients surveyed and summary of their views on the quality of care and support provided by the agency via its candidates; 
ii. Staff surveyed and summary of their comments on the standard of care provided; 
iii. Accidents/incidents or other untoward events, including restrictive interventions, restraint as defined the DHSS 2005 guidance on restraint; 
iv. Key findings from looking at the records of complaints during this month including updates on ongoing complaints;  
v. Recruitment files checked; 
vi. CNO Alerts during the monitoring period; 
vii. Staff NMC Checks; 
viii. A review of the Supervision and appraisal log for the preceding month;
vi. A review of the Supervision and appraisal log for the preceding month;
vi. A review of the Supervision and appraisal log for the preceding month;

• Management review meetings - one approximately every 6 months. The main objective of the meetings include Improving on the current processes; Annual targets progression, and resource planning;
• Annual review: The quality of services provided is evaluated on an annual basis by collating the content of monthly monitoring meetings and involving the comments of key stakeholders including service users and nurses;
• Annual internal audit - conducted against the ISO9001:2008 QMS standard requirements, aimed at ensuring that the quality management system is effective, against the requirements of the standard and planned procedures of the QMS. Areas for improvement are identified using non-conformities as triggers for corrective action and subsequent preventive action;
• Departmental Quality Targets - financial targets set by the Managing Director annually, and the Recruitment Director in conjunction with the Division Head will create quality objectives that will be based on the pursuit of those financial targets.

All policies and procedures are viewed by Direct Medics Ltd. as ‘live’ documents. As such, updates and amendments take place on an ongoing basis in line with factors such as: 

i.    Legislative changes;
ii.   Procedural amendments as instructed by procurement bodies;
iii.  Advances in best practice knowledge; and
iv.  Requirements laid down in inspection reports from Care Inspectorate. 

As a minimum, all company policies and procedures are reviewed annually. 

Information is a corporate asset and the records of Direct Medics are important sources of administrative, evidential and historical information. They are vital to the organisation in its current and future operations, for the purposes of accountability, and for an awareness and understanding of its history and procedures.   

Scope of the Policy

Records are defined as all those documents, regardless of format, which facilitate the business carried out by Direct Medics and which are thereafter retained to provide evidence of its Recruitment Placements or activities. These records may be created, received or maintained in hard copy or electronically.  

Policy Statement

Direct Medics is committed to creating, keeping and managing its records in a manner that accurately documents its activities and that meet its statutory obligations.   

The aim of the Policy is to define and provide a framework for managing the Agency’s records and to establish accountabilities to ensure the Company:   

• Creates and captures authentic and reliable records to demonstrate evidence, accountability and information about its decisions and activities. 
• Maintains securely and preserves access to those records as long as they are required to support College operations. 
• Confidentially destroys those records as soon as they are no longer required. 
• Meets legal record-keeping requirements, including the Data Protection Act 1998 and the Freedom of Information Act 2000. 
• Identifies and preserves securely those records deemed worthy of permanent preservation. 
• Conforms with GDPR Legislation. 

Implementation

The Policy will be realised by the development of the following:  

• A retention schedule to regulate how long records are retained by the Agency. 
• An archive to house those administrative records that need to be retained beyond the immediate operational needs, in a cost-effective manner but from which records can still be retrieved when necessary. 
• A MDR Quality Management Database that outlines changes made to internal records. 
• a disposal policy to show the procedures for destroying records so they are disposed of in a consistent manner, by confidential shredding, with documented authorisation. 

Staff Guidance

The Quality Team will provide guide notes for Good Practice on the company DataStore. In particular, guidelines will be supplied in the form of:   

• A retention schedule to show staff how long to keep certain types of records in their care so they are not retained longer than is necessary or destroyed before they should be. 
• Step by step guidelines to show staff how to archive e-mails.  

Responsibilities

All employees will be responsible for creating and maintaining records in relation to their work that are authentic and reliable.   

The team structure at Direct Medics (Scotland) Ltd. is designed to make roles, responsibilities and lines of communication explicit.  As such, communication between staff members relevant to the supply of nursing staff is frequent and comprehensive.  The role of Registered Manager has been designed and agreed to ensure involvement in each placement as far as is practicable (and the Registered Manager has responsibility for ongoing supervision and review of each member of the nursing staff); the Responsible Person, however, is less involved in the day-to-day running of the agency function.   

The company’s monthly monitoring meeting is therefore designed to provide a platform to close out the company’s monthly monitoring of nursing recruitment, involving any members of staff directly or indirectly involved in the supply of nursing staff.  This could include (but is not limited to): 

i.    Responsible Person;
ii.   Registered Manager;
iii.  Recruitment Director;
iv.  Nursing Recruitment Consultants;
v.   Nursing Compliance Officers
v.    Quality Assurance Controller 

The general aims of staff meetings are:

i.    To keep the Responsible Person & Registered Manager apprised of developments in the division; 
ii.   To discuss concerns arising from new registrants; 
iii.   To receive any relevant information from the Registered manager relating to queries or concerns around agency staff; 
iv.  To agree plans for the development of the division;
v.   To plan for scheduled inspections and/or audits.

Registering with Direct Medics

The team structure of Direct Medics is designed to ensure that registering with the company is as straightforward and simple as possible, thus providing service users with a constant supply of additional nurses where possible.  As a responsible recruiter the company takes its legislative obligations seriously and as such, there are several elements to our registration procedure designed to fulfil these obligations and provide assurances to service users. We offer several options to complete pre-employment checks in partnership with the company’s Compliance team.  The following sequence of events must be followed before a nurse is considered ready to supply to a service user:   

1. New nurses are assigned a Compliance Officer who will send an introductory email outlining our pre-employment checks and add their details to relevant contact lists;
2. New nurses are assigned a Recruitment Consultant who carries out an introductory call where any preferences for job opportunities are confirmed and ensuring full understanding of the registration procedure and receipt of all relevant documents;
3. The compliance officer guides the new nurse through the remaining compliance checks in line with NHS Employment Check Standards and any other relevant requirements such as mandatory training and evidence of PI insurance, Access NI etc. 

The NHS Employment Check Standards (2012)
The NHS Employment Check Standards are a set of six documents developed by NHS Employers in conjunction with the Department of Health, and set out the obligations of employers across the NHS pre-employment assessments that must take place for permanently-employed NHS staff. As a responsible recruiter of healthcare staff, Direct Medics adhere fully to each of the checks enshrined in the Standards for all staff employed through the company, and provide full guidance as to the actions required from new agency staff to meet these obligations.

The requirements of the NHS Employment Check Standards are as follows:

1. Verification of Identity Checks
2. Right To Work
3. Employment History & References
4. Criminal Record and Barring Checks
5. Occupational Health
6. Professional Registration & Qualifications

Upon completion of our pre-employment checks, files are referred to our Registered Manager, who will review all available information and conduct a final interview aimed at ensuring complete understanding of our procedures and suitability to work in the chosen area. You will be booked for work through Direct Medics only with the express approval of the Registered Manager.

Booking an Assignment

Upon completion of your registration, agency staff are made aware of all job opportunities fitting their profile as and when they arise. Candidates are put forward for consideration by the agency following instruction from the candidate and pending confirmation that their documents remain valid. If selected, the company provides a booking form to the client organisation and a conformation with the agency staff both verbally and by email. The confirmation will include all relevant information about the assignment, including reporting instructions, any travel and accommodation arrangements and instructions on payment for the assignment. Agency staff are advised to raise any queries they may have upon receipt of the confirmation immediately to allow for a smooth start to the assignment.

Contact During the Assignment

It is aim of the company to ensure complete satisfaction with assignments, that it is within the skill set of the agency staff and it is everything expected. Our contact with agency staff during assignments may include:

i.   Arrival calls on the first day (to confirm your safe arrival and first impressions);
ii.  Service calls during the assignment (to check that the assignment is proceeding as expected);
iii. Records maintenance calls (to update documents that may be due to expire during the assignment).

Clients are asked to provide feedback during assignments and complete a company assessment form at the end to allow us to maintain a record of performance for all placements as far as reasonably practicable. Feedback is of course a two-way process and we encourage agency staff to provide us with relevant information on the assignment, the setting etc to enable us to enhance our service to them.

At point of registration, all nurses wishing to book assignments through Direct Medics (Scotland) are matched appropriately to vacancies according to their skills and expertise (see “Matching Skills and Expertise of Nurses to the Requirements of Placements”).  The aim of reviewing and reassessing nurses on an ongoing basis is to maintain and update the company’s records as new information becomes available as to the skills and expertise of nurses registered with the company, thus amending records as to the suitability of individual nurses for specific vacancies and providing assurances as to the ongoing suitability of individual nurses for roles originally deemed suitable for them at the point of registration. 

The following reviews and reassessments typically take place:

1. Prior to booking an assignment: Each time a nurse requests that an assignment be booked for them, their Recruitment Consultant performs a check with the Nursing and Midwifery Council’s Online Confirmation Service, which is an enhanced checking service designed to provide up to date information as to registration status.  This check identifies any stipulations or restrictions on the nurse’s registration which may affect a booking;

2. During/after assignments: Each nurse will receive a call from their Recruitment Consultant to confirm verbally that the assignment is within the scope of their skills and that they are comfortable with the duties expected of them.  On a monthly basis, the agency checks company software for any candidates working in a clinical setting for the first time and contact the Client for feedback which may be given verbally or in writing.  Feedback is recorded on the company software.  Any areas of concern raised are reported to the Registered Manager and feedback is subsequently delivered to the nurse, with a development plan put in place if required aimed at improving upon the areas of concern.  The plan would include required actions with agreed timescales for completion and are closed off in a timely and realistic manner;

3. On an ongoing basis: The company software is designed to issue reminders to Compliance staff as to the expiry dates of all relevant documentation for nurses, including items such as RTW, disclosures, mandatory training modules, professional indemnity, NMC registration.  The Compliance team works with nurses to update and maintain their files thus ensuring ongoing suitability and update of knowledge particularly regarding training modules.  Likewise, if a nurse obtains additional qualifications or can develop skills, these are reported to the Registered Manager who advises the team as to any amendments to be made to the company software to impact upon the roles suitable for that nurse;

4. Six months after the first booking, and annually thereafter: The Registered Manager invites all candidates to take part in clinical supervision, provided they have carried out at least sixty shifts in the previous six months.  Supervisions are based on the NHS national frameworks for the nursing and midwifery workforce in NHS Scotland (NES, 2023; NES, 2024) and support a 'Once for Scotland' approach to implementation, practice and governance of clinical supervision. Supervisions should focus on practice, professional and restorative practice. The supervision exercise is an opportunity for candidates to raise any concerns and provide feedback on clinical settings. Actions required to improve outcomes will be identified and reported to relevant staff at the company.  Any specific support required will be identified and documented.  Progress against these actions will be reviewed and documented at follow up supervision sessions.

5. Twelve months after the first booking, and annually thereafter: The Registered Manager invites each nurse to an annual appraisal.  Preparation for the appraisal meeting would include a review of all work undertaken through Direct Medics Ltd. in the preceding year and corresponding exit reports; any recommendations made to the nurse throughout the year and subsequent actions and reviews (including a record of any conclusion drawn by the Registered Manager throughout the year as to the nurse’s ongoing fitness for work specified).  The appraisal meeting itself is aimed at reconfirming the conclusions of the Registered Manager following the initial interview at registration stage, updating the information available to reflect the nurse’s current preferences and suitability for work and to identify any desired areas for development.  The outcome of the appraisal meeting is a Personal Development Plan for each nurse identifying their learning and development objectives for the coming year in agreement with the Registered Manager.

In line with the terms of registration with the Care Inspectorate (CI) and relevant framework agreements, Direct Medics (Scotland) Ltd. operates under an ethos of openness and transparency.  To that end, the company will facilitate any requirement to audit or inspect the company’s operation and will make available all resources required by the relevant authority to facilitate such audits or inspections.  This includes (but is not limited to): 

i.   A complete copy of the company’s policies and procedures;
ii.  A copy of relevant staff records (e.g. pre-employment checks);
iii. Access to a qualified member of staff to answer any queries

The overarching quality standard to be met by Direct Medics (Scotland) is the specification of its contracts with various NHS organisations. The company holds ISO 9001:2015 certification alongside REC and NRF memberships and its service is maintained in adherence with this, and inspection reports generated by the Care Inspectorate.  An ongoing series of management procedures and continual improvement measures take place at a senior level within the company including:  

i.  Quality targets for each team: for example, targets for Compliance staff are monitored on their handling of new registrants and other staff available for locum work.  Targets for each team are reviewed quarterly with results contributing to performance management. 
ii.  Monthly management meetings at which a summary is provided by each member of the management team as to quality targets and progress on business improvements are discussed alongside operational matters. 
iii. Quarterly reviews against company Quality Objectives which review the targets for the previous quarter, areas for development and planned improvements for the following quarter. 
iv. Quarterly management reviews which take the findings for the preceding quarter reviews. 
v.  Annual internal audit of each of the company’s departments against ISO 9001:2015 by the company’s BSI-qualified Internal Auditor, supported by an Assistant Auditor. 
vi. Annual external audit of the company by BSI for ISO 9001:2015 re-certification. 
vii. Monitoring Report – one per month, undertaken by a nominated Monitoring Officer and shared with stakeholders including the Nurse Manager, Registered Owner, Recruitment Manager and Compliance Manager.  The monitoring meeting includes a review of the previous month’s performance using indicators including: 

Staff surveyed and a summary of views 
Service users surveyed and a summary of their views 
Key findings from records of complaints 
Recruitment files checked 
Audit of Staff NMC Checks 
Training records audited 
Requirements and recommendations specified in the Care Inspectorate’s Quality Improvement 
Plans, and commentary on progress made on planned improvements 

The quality control systems of Direct Medics (Scotland) are in accordance with ISO accreditation with systems aimed at assuring that risk is minimised for the company’s clients.   

Ongoing improvement is achieved via review of company documents, processes and training materials in line with service specifications, and refresher training provided as an ongoing programme overseen by team leaders.  The company’s quality control systems focus on both legal compliance and excellent customer service for healthcare workers; processes in place include the following: 

i.  All healthcare workers are assigned a Compliance Officer to advise on documents and a Recruitment Consultant to advise on opportunities according to skills. 
ii.  Regular communication takes place to ensure compliance and to meet client needs. 
iii. System alerts to Compliance staff about outstanding documentation and reference reports or items due for renewal are embedded in the company’s bespoke software. 
iv. Post-booking checks by senior management with failure to adhere to protocols treated under the company’s disciplinary procedure. 
v.  Regular document checks during assignment and advice to current workers on same. 
vi. Monthly audits: results are examined to identify any training needs and to commend those who meet the requirements 

1. The Code of Practice (“the Code”) is published by Scottish Ministers under section 122 of Part V of The Police Act 1997 (“the 1997 Act”). The Code identifies obligations which registered bodies, countersignatories and other recipients of disclosure information issued under the 1997 Act and the Protection of Vulnerable Groups (Scotland) Act 2007 (“the 2007 Act”). 
2. We comply with the Code, the 1997 and 2007 Acts regarding the treatment of individuals who are subject to Disclosure Scotland checks. We undertake not to discriminate unfairly against the subject of a disclosure on the basis of conviction or other information revealed.
3. We will provide a copy of this policy and the Code to anyone who asks to see it. 
4. We are committed to equality of opportunity, to following practices, and to providing a service which is free from unfair and unlawful discrimination. We ensure that no applicant or member of staff is subject to less favourable treatment on the grounds of offending background. We actively promote the right mix of talent, skills and potential and welcome applications from a wide range of candidates, including those with criminal records. The selection of candidates for interview will be based on skills, qualifications and experience.  
5. We will use a Disclosure Scotland check only where this is considered proportionate and relevant to the particular position or type of regulated work. This will be based on a thorough risk assessment of the position or work and having considered the relevant legislation which determines whether or not a Standard or Enhanced Disclosure under the 1997 Act or a Scheme Record under the 2007 Act is applicable. 
6. Where a disclosure application or request is deemed necessary, individuals will be made aware that the position or work will be subject to a Disclosure Scotland check and that the nature of the position or work entitles us to ask about spent and unspent convictions. 
7. We will ask individuals to complete a criminal record self-declaration form. We will stress to individuals that they should be honest in their response. We will ask that this form be returned under separate, confidential cover, to a designated person within our organisation and we guarantee that this form will only be seen by those who need to see it as part of the decision-making process. 
8. At interview, or under separate discussion, we undertake to ensure an open and measured discussion on the subject of any offences or other matters that might be considered relevant for the position or work concerned. 
9. We undertake to discuss any matter revealed in a certificate1 issued under the 1997 Act or a Scheme Record issued under the 2007 Act with the subject of that disclosure before a decision is made. 
10. We ensure that all those who are involved in the decision making process have been suitably trained to identify and assess the relevance and circumstances of disclosure information. We also ensure that they have received appropriate guidance and training about providing work for ex-offenders. 

HAVING A CRIMINAL RECORD WILL NOT NECESSARILY DEBAR YOU FROM WORKING WITH US.