FOI 2025/1477

The NHS England Violence Prevention and Reduction Programme aims to support NHS organisations and systems to embed a culture where our NHS colleagues feel supported, safe, and secure at work. The NHS violence prevention and reduction (VPR) standard complements existing health and safety legislation and supports NHS organisations to address violence against NHS staff. Within this context I would be grateful for the following information:

1. Strategy – please provide a copy or signpost to your violence prevention and reduction strategy, or any equivalent document that details your ICB’s approach to reducing violence, aggression, abuse, or anti-social behaviour against the healthcare workforce. If none exist, please indicate what governance process is in place for this purpose.
2. Information sharing – please indicate what systems or processes (if any) are in place to share information about patients or individuals with a history of violent or abusive behaviour between the various healthcare system partners and local authorities. This refers to any policies, procedures, guidance, agreements, frameworks, or memoranda of understanding that exist to enable data/information sharing between hospitals, primary care partners, ambulance trusts, community providers, social services, police, local authorities, and any other public / statutory bodies operating within the ICS.
3. IT system or digital platform – please state if there is any third party or in-house technology that is used to share data and information between system partners in respect of violence prevention or reduction. If available please specify the name of the digital system or application, and the supplier or developer.

1. NHS Greater Manchester (NHS GM) have a sexual safety in the workplace homepage on our intranet site for professionals which includes the NHS England Sexual Safety in Healthcare Charter commits to taking and enforcing a zero-tolerance approach to any unwanted, inappropriate and/or harmful sexual behaviours within the workplace launched in September 2023. NHS GM undertake weekly sexual safety panels to review any referrals that may come through with lad HR and safeguarding colleagues.

NHS England » Sexual safety in healthcare – organisational charter

Sexual safety policy. Domestic Abuse Policy and Safeguarding policy are also attached which outline the organisational process for our ICB’s approach to reducing violence, aggression, abuse, or anti-social behaviour against the healthcare workforce.

**PDF documents were sent to the requester with this response.  If you require a copy of the full response, together with the attachments, please contact NHS GM’s FOI team – nhsgm.foi@nhs.net **

Please find below a link to the Patient Services Policy

https://gmintegratedcare.org.uk/wp-content/uploads/2024/11/patient-services-policy-nhs-gm-policy-template-v5-211024.pdf

NHS GM Unreasonable Communications Policy is currently progressing through our governance process and will be available on NHS GM website once this has been verified and approved.

Therefore, currently the release of this information is exempt from disclosure by virtue of section 22 of the Freedom of Information Act 2000 as it is intended for future publication.

Section 22(1) of the Freedom of Information Act 2000 states:

(a)      the information is held by the public authority with a view to its publication, by the authority or any other person, at some future date (whether determined or not),

(b)      the information was already held with a view to such publication at the time when the request for information was made, and

(c)      it is reasonable in all the circumstances that the information should be withheld from disclosure until the date referred to in paragraph (a).

This exemption is subject to the public interest test and for the reasons outlined below, we are satisfied that the exemption applies.

Public interest test

There is an inherent public interest in ensuring that there is openness and transparency to increase confidence in procurement processes and the purchasing decisions made by NHS GM. Furthermore, disclosure of this information would also be consistent with NHS GM’s commitment to proactively publish data that is in the wider public interest.

However, this information is subject to is subject to review, validation and approval, prior to publication. Early release of the requested information could be misrepresentative, and it is in the public interest that this information is true and accurate.

After considering the arguments outlined above, we have decided that, on balance, the public interest is better served at this time in withholding the working draft version of the Unreasonable Communications Policy, on the basis that it will be published in the future once finalised, as outlined above.

2. All data sharing is subject to the NHS GM Information Governance data protection policy but there are no specific processes in place regarding sharing information on violent and abusive behaviour.

The above policies outline the information sharing routes for staff and managers where there are sexual misconduct concerns or DVA or safeguarding concerns related to these issues including what information can be shared. This also includes LADO and PIPOT. These will also link into the relevant HR policies such as disciplinary policies if required for an ICB employee.

The GM Shared Care Record is used by Health and Care Providers across Greater Manchester. If the patients GP record has been updated to indicate the patient is violent or abusive this will appear in the ‘problems’ section of the GM Care Record. However, this information is not flagged as an alert though when a clinician accesses a patients record within the GMCR.

3. There is no digital system in place to share information in relation to reducing violence, aggression, abuse, or anti-social behaviour against the healthcare workforce.

The GMCR uses Graphnet shared care record solution.