GDC GOOGLE GAFFE


BACKGROUND Ms B is a principal in a practice offering general dental treatment along with minor cosmetic procedures. She receives a letter from the GDC requesting information in regard to an anonymous complaint concerning a Google Ad for the practice with the headline “Tooth Whitening Specialists”. In the letter it is first pointed out that a


dentist is not allowed to use the term “specialist” unless qualified to appear on one of 13 GDC specialist lists – and second there is no specialist list for tooth whitening. Ms B contacts an MDDUS adviser who


helps her draft a reply. It emerges that Ms B had employed a web company to manage her online advertising campaign. The company removed the phrase “Tooth Whitening Specialists” when informed of the complaint and re-checked the “key words” agreed for the Google campaign. “Specialist” was not on the list of approved terms the practice asked to be used in the promotion of the business. The term had been inserted inadvertently via “dynamic keyword insertion” (DKI) when a user on Google typed in the phrase: “Tooth


Whitening Specialist”. Use of DKI had not been explained or okayed by the practice and a letter setting out the error is provided by the company for evidence to the GDC.


ANALYSIS/OUTCOME MDDUS replies on behalf of Ms B along with copy correspondence demonstrating her efforts to comply with relevant guidance in regard to digital marketing – including the letter from the web company. The letter also enquires why the GDC decided to take the matter forward for investigation when usual practice in such cases is in


KEY POINTS ●Be careful not to use the title “specialist” unless you are registered on one of 13 GDC specialist lists. ● Use of terms such as “special interest in” or “experienced in” are permitted for non-specialist registrants.


the first instance to simply request changes to ensure compliance. The GDC acknowledges receipt and


explains that because Ms B had been subject in the past to a fitness to practise concern it was decided to look further into the present matter. A few weeks later Ms B receives another letter confirming the matter will not be taken forward and that the case file has been closed.


ADVICE TRANSGENDER RECORDS


BACKGROUND A GP practice has been supporting a male patient transitioning to female over the past year. The patient is now demanding that personal details be changed in the medical record to reflect a new name and change of gender. The practice contacts MDDUS to ask if the patient should provide some kind of formal certificate or authorisation first?


ANALYSIS/ OUTCOME MDDUS advises that the patient should submit a signed request in writing. A Gender Recognition Certificate (GRC) or updated birth certificate is not required in order to have the record amended. The practice should then inform its CCG (Practitioner Services in Scotland) of the new name


and gender (with the patient’s consent). If the patient wishes to be issued with a new NHS number then this can be taken care of by the CCG who will ensure the records are transferred to the new identity. The practice is advised to explain that


the patient may not be contacted for current or future screening programmes associated with the sex at birth and explain the implications of this. Decisions about


screening should be made in the same way as any other health decisions (ensuring informed consent is in place).


Gender marker, pronouns and names on all the patient


information held should also be


changed. The GMC has published


guidance on trans healthcare on their website, including the process for changing name, title or NHS number across the UK. Note that it is a criminal offence to share, without the patient’s consent, information which reveals gender reassignment has occurred, where the patient has received a GRC. As such, provision of information on referrals etc. should be carefully reviewed.


KEY POINTS ● Transgender patients are not required to provide a certificate or authorisation before requesting changes related to gender status. ●A signed request from the patient is sufficient to make such changes. ●Consult GMC and other guidance on trans healthcare.


MDDUS INSIGHT / 17


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