Policy Index (Wales)

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 the Health Board’s policy for the administration and assistance with drugs and medication, including the use of the All Wales prescription chart (further details here) and any other relevant administration charts e.g. insulin chart.

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)
• NMC: Standards for Medicines Management 2007,
• 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/patient’s 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 agreemen

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 upheld0

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 (manager@directmedics.com)

ALL MEDICATION ERRORS MUST BE REPORTED IMMEDIATELY, BEFORE DETAILS ARE 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 IN A TOILET, ‘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.

Direct Medics Ltd. aim to provide the highest quality of service to all individuals and bodies served.  We aim to enable all of our customers to make complaints quickly and simply, and we will investigate and resolve a complaint in accordance with strict timescales.

Subject to any restrictions on our customers relating to confidentiality or Data Protection Legislation, we expect to receive the necessary information surrounding any complaint, to enable us to investigate it fully.

If a customer needs to raise a formal complaint to the company, any details regarding the issue, previous attempts to resolve by informal means and contact details (email address and phone number) should be submitted. This must be made in writing and sent to our Recruitment Director at the following address:

Direct Medics Ltd.
33A Stockman’s Way,
Belfast
BT9 7ET

All written complaints will be dealt with as follows:

1. As soon as the complaint is received, it will be logged and the complainant will receive acknowledgement or receipt of the complaint in writing within two working days;
2. We will keep a full written record of the nature of the complaint and the actions taken as a result;
3. We may contact the complainant to clarify the detail of the complaint and to discuss it with them and we will follow up any conversation in writing;
4. We will use reasonable endeavours to ensure that all complaints are resolved within ten calendar days, unless the nature of the complaint requires additional investigation or action by a Professional or Regulatory Body or other Government Body. In that case, we will ensure that the complaint is resolved as soon as possible

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.

We will ensure that our Candidates are promptly and fully informed about any complaints relating to them, and we will take action to ensure no repeat of the action complained of.

At any point through this process, should a customer require it an independent advocacy services may be engaged with in an attempt to resolve outstanding issues fairly.  If required assistance will be provided to any person 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.

COMPLAINTS ABOUT CANDIDATES: REPORTING AND RECORDING PROCEDURE

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 relevant Manager (e.g. Nursing Manager) who is responsible for overseeing follow-up and close-off in collaboration with the Candidate, Direct Medics staff, Complainant and/or Professional/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 with any adjustment to the schedule in light of the complaint, in addition to any enhancement to quality monitoring at the Manager’s discretion

Where a complaint relates to evidence of malpractice, Direct Medics Ltd. reserves the right to report the Candidate to the relevant Professional/Regulatory Body.  Where this occurs, Direct Medics Ltd. will monitor such complaints until an outcome is reached, and will liaise with the relevant Client as to whether an Alert Notice is required.

Where a complaint relates to poor performance, Direct Medics Ltd. will not supply the Candidate to further Clients until the issues identified have been resolved.

Candidates will be provided with a copy of this procedure upon registration, and will sign a declaration confirming receipt and understanding.

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. NHS 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.

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, the Registered Manager advises the Nursing team as to previous roles, practice experience and competency.

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.

The email alert system 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.

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.

PRE-EMPLOYMENT CHECKS

We will ensure that the following information for each Agency Worker is obtained and verified:

1. Their full name and address
2. Their date of birth
3. Verified personal identification and a recent photograph
4. A full curriculum vitae or employment history and evidence of all previous, relevant training undertaken
5. Details of next of kin, together with an emergency contact telephone number
6. Confirmation that the Agency Worker can communicate clearly and effectively in English (i.e. they are readily able to understand and be understood)
7. A copy of the Agency Worker's driving licence that legally allows them to drive in the UK (as necessary in respect of the duties to be carried out by that Agency Worker
8. Copies of References - we will as a minimum obtain 2 references, one from each of the most recent engagements held by the Agency Worker (i.e. either the employing healthcare body if previously directly employed by a healthcare body or by the employing/engaging agency if previously working as an agency worker) and must contain details of work undertaken during these engagements. The references will be provided by the Agency Worker’s previous line managers (i.e. more senior personnel at their previous employer/agency) and obtained from the business address of the previous employer/ agency. The reference will clearly show the relationship between the referee and the Agency Worker in that appointment to establish that the reference is from the Agency Worker’s previous line manager (e.g. Line Manager, Ward Manager etc.). We will use our best endeavours to ensure that these references are relevant to each speciality in which the Agency Worker may be placed.
9. Where the Agency Worker is a qualified Operating Department Practitioner evidence of their ongoing registration with the Health Professions Council of eligibility to practice as an Operating Department Practitioner.
10. In the case of a Nurse, the personal identification number supplied by the NMC, all references to the expiry date of the Nurse's registration, written confirmation of all of the foregoing and evidence of ongoing registration with the NMC of eligibility to practice as a Nurse. (The Supplier may use a print out from the NMC’s computer system to validate and confirm the aforementioned details).
11. In the case of a Nurse registered with the NMC:
    Which part of the register the Nurse is on;
    What additional nursing certificates (if any) are held by the Nurse; and
    Details of the revalidation and the continuing professional development of the Nurse.
12. In the case of a Nurse, information as to whether the Nurse is suspended from duty with any organisation or with the NMC. At recruitment we will advise the Nurse that they must inform us if they are under investigation by the NMC or suspended from duties by another employer, or agency.
13. Where an Agency Worker claims to have obtained additional certificates or qualifications (other than NMC), copies of such certificates and proof of any other such qualifications, which shall be retained on the file of the Agency Worker concerned. We will have previously viewed the originals of such certificates or evidence of such other qualifications
14. We will ensure that Agency Workers who are not British Citizens or EC nationals and who have not been granted permanent status in the UK have the necessary Home Office permission to work. We will make available, on request from Health Boards, the relevant evidence as to Home Office status and permission to take employment including the Agency Worker's work permit number. We will view and maintain a copy of the Agency Worker's immigration status and eligibility to work from the Home Office on the personnel records of the Agency Worker.
15. Details of results of an "Enhanced Disclosure'" including POCAL and POVAL lists from the Disclosure and Barring Service performed in respect of the Agency Worker. We will maintain on the personnel records a photocopy of the top section (above confidential information) of the previous Enhanced Disclosure undertaken for the Agency Worker.
16. Where the Agency Worker has entered the UK within the previous 6 months period prior to recruitment, we will ensure that in addition to the aforementioned a police check has been undertaken within the previous 3 month period from the date of recruitment with their country of origin and is verified by us with the originator, a copy of this is also to be maintained on the personal records of the Agency Worker.
17. A current statement of good general health and a certificate of fitness to work from an occupational health service, or suitably trained and experienced Nurse or general practitioner.
18. Details of current immunisations and test results. We will check that the Agency Worker has and at all times henceforth maintains up to date immunity in respect of relevant illnesses.

MANDATORY TRAINING:

We will ensure that each new Agency Worker receives the following training prior to being sent on any assignment:

• Manual Handling (All Wales Moving & Handling Passport Scheme)
• Fire Safety,
• Lone Worker Training,
• Handling of Violence and Aggression (All Wales Violence & Aggression Passport)
• Infection Prevention and Control and Aseptic Non Touch Technique (ANTT)
• Dignity & Respect Training
• Health & safety (the requirements of the 1974 and 1999 Acts);
• Manual handling (All Wales Moving & Handling Passport Scheme)
• COSHH;
• RIDDOR;
• Basic, Intermediate or Advanced life support (adult or paediatric, as appropriate) in accordance with the relevant Job Profile and which is compliant at all times with
• Resuscitation Council UK and the Health Board’s guidelines, as appropriate, and has been delivered by means of a practical course
• Medical Devices e.g. Infusion Pumps/IV’s etc
• Dementia Care Training

In the case of an Agency Worker who may reasonably be expected in the course of their normal duties to perform assignments within Mental Health and Learning Disabilities, in addition to the above, physical restraint skills and techniques including but not limited to personal safety and control and restraint training; and

• Risk Incident Reporting,
• The Caldicott Protocols
• Any other mandatory training under current or future Health and Safety regulations
• Training in complaints and incident handling
• Mental Capacity and Protection of Vulnerable Adults and Protection of Children Acts

In addition to the above all midwives will receive annual training in:

• Resuscitation of the newborn
• Interpretation of cardiotocograph traces and annual PROMPT training compliance
• Medicines management in line with All Wales MARRS policy

Rationale

Clinical supervision, appraisal and revalidation are essential to assuring the agency that the nursing candidates being booked are suitable for the job roles originally approved by the Nursing Manager at interview stage. It allows both the Nursing Manager and the candidate to identify and discuss areas for development, and any additional skills gained that may allow the candidate to expand the scope of job roles offered by the agency. Supervision and appraisal also contribute towards the candidate’s revalidation, for which the Nurse Manager can act as Confirmer on request.

Managing Supervision and Appraisal

Identifying Candidates due supervision or appraisal:

On 1st of each month, the Compliance Manager will identify those candidates due supervision or appraisal in the following month. The relevant candidates will be sent an invitation for supervision or appraisal (template and responsibility for sending invitations are to be arranged locally).

Completing the exercise:

The Nurse Manager is responsible for completing the supervision or appraisal exercise. The appraisal will review the nurse’s PREP requirements, their training and development needs (including CPD) with agreement as to how these are to be met and the timescales within which such training will be undertaken. These will be reviewed to ensure compliance at subsequent appraisal meetings.

We will use pro forma documents for all nurses to enable written records to be kept by us on the content and outcome of each meeting which includes PREP. Training performance and issues highlighted from previous meetings. Such records shall be placed on the file of each nurse supplied or to be supplied. At any appraisal meeting this form for the previous appraisal meeting will be reviewed, to ensure that previous agreed actions or outcomes were undertaken

All contact with the nurse is recorded on the contact log within the nurse’s candidate record (using the log type ‘appraisal’ or ‘supervision’ as appropriate)

Verification:

Once completed, the Nurse Manager will email the supervision or appraisal document to the Nurse and request that the nurse confirm by return email their agreement with its contents. Once received, the supervision or appraisal document along with the nurse agreement will be emailed to the Compliance Officer for upload to Eclipse.

Changes to supervision and appraisal schedule

Certain instances may result in changes to the schedule, for example:

i. The nurse does not respond to the invitation for several months;
ii. The nurse is overdue an appraisal when supervision is due and therefore receives an appraisal instead of supervision;
iii. There are difficulties scheduling a supervision or appraisal exercise;
iv. A complaint has been received about the nurse

In such cases, supervision and appraisal should be treated as two separate exercises, and the schedule adjusted in line with the most recent exercise completed. For example:
A nurse’s supervision is due in April, and appraisal is due in October. The nurse is contacted in March and invited to take part in supervision, but makes contact in May to arrange. Supervision eventually takes place in June. In this case, the nurse’s supervision month will be June in future, and the schedule needs to be adjusted accordingly. Appraisal is still due to take place in October.

Direct Medics Ltd. embraces diversity and aims to promote the benefits of diversity in all of our business activities. We seek to develop a business culture that reflects that belief. We will expand the media in which we recruit to in order to ensure that we have a diverse employee and candidate base. We will also strive to ensure that our clients meet their own diversity targets. 

Direct Medics Ltd. is committed to diversity and will promote diversity for all employees, workers and applicants. We will continuously review all aspects of recruitment to avoid unlawful discrimination. Direct Medics Ltd. will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act) which are age, disability, gender re-assignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We will not discriminate on the grounds of an individual's membership or non-membership of a Trade Union. All staff have an obligation to respect and comply with this policy. Direct Medics Ltd. is committed to providing training for its entire staff in equal opportunities and diversity.  Direct Medics Ltd. will avoid stipulating unnecessary requirements which will exclude a higher proportion of a particular group of people and will not prescribe discriminatory requirements for a role.

The Equal Opportunities and Diversity Policy applies to all employees regardless of length of service. 

DISCRIMINATION

Under the Act unlawful discrimination occurs in the following circumstances:  

Direct discrimination

Direct discrimination occurs when an individual is treated less favourably because of a protected characteristic. Treating someone less favourably means treating them badly in comparison to others that do not have that protected characteristic.

It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected characteristic: 

• in the terms on which the recruitment consultancy offers to provide any of its services;
• by refusing or deliberately omitting to provide any of its services;
• in the way it provides any of its services.

Direct discrimination can take place even if the individual does not have the protected characteristic but is treated less favourably because it is assumed he or she has the protected characteristic or is associated with someone that has the protected characteristic.

Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which states that certain persons are unacceptable due to a protected characteristic, unless an exception applies. The Act contains provisions that permit specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These provisions are referred to as occupational requirements.

Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment. Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement. 

Indirect discrimination 

Indirect discrimination occurs when a provision, criterion or practice (PCP) is applied but this results in people who share a protected characteristic being placed at a disadvantage in comparison to those who do not have the protected characteristic. If the PCP can be objectively justified it will not amount to discrimination.  

Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer. 

If the vacancy requires characteristics which amount to an occupational requirement or the instruction is discriminatory but there is an objective justification, Direct Medics Ltd. will not proceed with the vacancy unless the client provides written confirmation of the occupational requirement, exception or justification. 

Direct Medics Ltd. will use best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination. 

Harassment  

Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. This includes unwanted conduct of a sexual nature.

Direct Medics Ltd. is committed to providing a work environment free from unlawful harassment. Direct Medics Ltd. will ensure that the consultants do not harass any individual.

Examples of prohibited harassment are: 

1. verbal or written conduct containing derogatory jokes or comments;
2. slurs or unwanted sexual advances;
3. visual conduct such as derogatory or sexually orientated posters;
4. photographs, cartoons, drawings or gestures which some may find offensive;
5. physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected characteristic basis;
6. threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
7. retaliation for having reported or threatened to report harassment.

If an individual believes that they have been unlawfully harassed, they should make an immediate   report to the Recruitment Manager followed by a written complaint as soon as possible after the incident. The details of the complaint should include:  

• Details of the incident
• Name(s) of the individual(s) involved
• Name(s) of any witness(es)

Direct Medics Ltd. will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken. 

All employees and workers will be expected to comply with Direct Medics Ltd.’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action. 

Any individual who Direct Medics Ltd. finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination.  

Victimisation 

Under the Act victimisation occurs when an individual is treated unfavourably because he/she has done a ‘protected act’ which is bringing a claim for unlawful discrimination or raising a grievance about discrimination or giving evidence in respect of a complaint about discrimination. 

Direct Medics Ltd. will ensure that the consultants do not victimise any individual.

DISABLED PERSONS

Discrimination occurs when a person is treated unfavourably as a result of their disability. 

In direct discrimination occurs where a provision, criterion or practice is applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled.

In recruitment and selection there may be a requirement to make reasonable adjustments. For example, it might be necessary to have different application procedures for partially sighted or blind applicants that enable them to use Braille. With testing and assessment methods and procedures, tests can only be justified if they are directly related to the skills and competencies required for the job. Even then, it might be appropriate to have different levels of acceptable test results, depending on the disability. For example, an applicant with a learning disability might need more time to complete a test, or not be expected to reach the same standard as other non-disabled applicants. 

Reasonable adjustments in recruiting could include: 

• modifying testing and assessment procedures; 
• meeting the candidate at alternative premises which are more easily accessible; 
• having flexibility in the timing of interviews; 
• modifying application procedures and application forms; 
• providing a reader or interpreter. 

Wherever possible Direct Medics Ltd. will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances. 

Direct Medics Ltd. will not discriminate against a disabled person:  

• in the arrangements i.e. application form, interview or arrangements for selection for determining whom a job should be offered; or
• in the terms on which employment or engagement of temporary workers is offered; or
• by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or
• in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or
• by subjecting the individual to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).

Direct Medics Ltd. will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.  

AGE DISCRIMINATION 

Under the Act, it is unlawful to directly or indirectly discriminate against or to harass or victimise a person because of age.  Age discrimination does not just provide protection for people who are older or younger. People of all ages are protected.

A reference to age is a reference to a person’s age group. People who share the protected characteristic of age are people who are in the same age group.

Age group can have various references: e.g. Under 21s; people in their 40s; Adults. 

Direct Medics Ltd. will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to encourage clients to recruit on the basis of competence and skills and not age. 

Direct Medics Ltd. is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company. 

If Direct Medics Ltd. requests age as part of its recruitment process such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process. In addition if under age 22 to adhere to Conduct of Employment Agencies and Employment Business Regulations 2003 and other relevant legislation applicable to children or young candidates.

Where a client requests age or date of birth, this will have to be under an occupational requirement or with an objective justification which should be confirmed in writing.

PART-TIME WORKERS

This policy also covers the treatment of those employees and workers who work on a part-time basis, Direct Medics Ltd.  recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full-time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. Direct Medics Ltd. also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations. 

GENDER REASSIGNMENT POLICY 

Direct Medics Ltd. recognises that any employee or worker may wish to change their gender during the course of their employment with the Company. 

Direct Medics Ltd. will support any employee or worker through the reassignment.   

Direct Medics Ltd. will make every effort to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace.  

Where an employee is engaged in work where the gender change imposes genuine problems Direct Medics Ltd. will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee. 

Any employee or worker suffering discrimination on the grounds of gender reassignment should have recourse to the Company’s grievance procedure.  

RECRUITMENT OF EX-OFFENDERS

Where Direct Medics Ltd. has registered with the Disclosure and Barring Service (DBS) and has the authority to apply for criminal records checks on individual because they are working with children or vulnerable adults or both, we will comply with the DBS’s Code of Practice which includes having a policy on the recruitment of ex-offenders.

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 and is retained on the staff file. 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); and
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.

Section 1: Introduction, Purpose, Definition, and Scope

1.1          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.

1.2          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.

1.3          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.

1.4          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

2.1          Staff must never use their personal social media to engage with patients. For example, staff should never send a “friend” request to a patient 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).

2.2          Use of social media must at all times be consistent with other Direct Medics policies, such as the Data Protection policy.

2.3          In order to protect the Company’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

4.1          Staff must ensure there is always a clear separation between work use and social use within their social media accounts.            

4.2          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.

4.2          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.

Section 5: Online Safety

5.1          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

6.1          Any illegal or unlawful acts that can be committed using words or images can equally be committed using social media.

6.2          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.