https://club.hcqc.co.uk/c/self-audits/edit-lesson/sections/517639/lessons/2237257
🔔 This is a user-generated audit.
As part of our Inner Circle community, we welcome suggestions from members on audit topics that reflect the real-world challenges practices face. This audit was created in direct response to a request — and is just one example of how we tailor support to your priorities.
If there’s a process or topic you’d like to explore in your own setting, let us know — we’re always happy to create one just for you.
Online services have revolutionised general practice — giving patients easier access to their health information, test results, appointment booking, and medication requests. However, as digital access expands, so do the risks around confidentiality, consent, and safeguarding — especially when it comes to proxy access.
This week’s audit helps your practice assess how safe, consistent, and legally sound your approach to online and proxy access really is.
Why This Audit Is Important
1. It Protects Patient Privacy
Giving a patient access to their own record can seem straightforward. But when someone else is requesting access — like a parent, spouse, or carer — the situation becomes more complex. Practices must:
- Obtain explicit, informed consent
- Ensure both parties understand the level of access being granted
- Review proxy relationships regularly (especially when children turn 11 or 16)
- Withdraw access immediately if safeguarding concerns arise
Robust identity checks and consent documentation are critical for ensuring only the right people have access to sensitive information.
2. It’s a CQC Priority Under the New Framework
Online and proxy access directly relate to several CQC ‘We’ statements in the Single Assessment Framework, including:
- 🟩 Well-Led – Governance, Management and Sustainability
Practices must have systems in place to deliver safe, legally compliant care. - 🟩 Effective – Consent to Care and Treatment
Patients must understand and agree to access arrangements, especially when third parties are involved. - 🟩 Responsive – Person-Centred Care
People should be at the centre of decisions, with access tailored to their preferences and needs.
Practices must demonstrate they have clear processes, training, and safeguards in place for granting and reviewing access.
3. It Reduces Risk of Harm and Misuse
Without careful controls, online access can be misused. Common risks include:
- Coercive relationships (e.g. abusive partners forcing access)
- Mistaken access granted to the wrong proxy
- Parents accessing teenagers’ confidential records without review
- Inappropriate access granted in care home or support worker settings
These situations can lead to breaches of confidentiality, safeguarding issues, and even harm to patients. This audit helps you explore whether your team is spotting — and safely managing — those risks.
4. It Builds Patient Trust in Digital Services
When handled well, online access gives patients greater control and convenience in managing their care. By ensuring robust verification, clear communication, and accessible information, you help patients feel confident that their data is:
- Private
- Secure
- Shared only when they say so
Trust is crucial for encouraging take-up of digital services, particularly among older or more vulnerable patients.
What This Audit Helps You Assess
This structured audit helps your team reflect on:
- Are your ID checks and verification processes strong and consistent?
- Is proxy access only granted with clear, informed consent?
- Are safeguarding and mental capacity considerations part of the process?
- Do patients feel empowered and in control of their data?
- Are online and proxy relationships regularly reviewed and logged?
In Summary
Digital access brings huge benefits — but it must be matched with clear governance, careful consent, and safe systems.
By completing this audit, you can:
- Reduce the risk of breaches and complaints
- Safeguard vulnerable patients from misuse
- Align with CQC expectations
- Build a culture of trust and transparency in your digital services
👉 Use this audit to ensure online access is not only easy — but ethical, legal, and safe.
