Our Policies
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Version: 1.0
Effective Date: 01/07/2026
Review Date: Annually
Company Name: Imperial Medica Limited
Company Number: 160015191. INTRODUCTION
These Terms and Conditions govern the provision of services by Imperial Medica Limited (“Imperial Medica”, “the Clinic”, “we”, “our”, “us”) to any individual accessing, booking, or receiving services from the Clinic (“Patient”, “you”, “your”).
By booking an appointment, attending a consultation, using our website, requesting medical services, or making payment for services, you agree to be bound by these Terms and Conditions.
These Terms and Conditions form a legally binding agreement between Imperial Medica Limited and the Patient.
Imperial Medica is an independent private healthcare provider and does not provide NHS services unless expressly stated.
2. OUR SERVICES
Imperial Medica may provide:
· Private GP consultations
· Face-to-face consultations
· Telephone consultations
· Video consultations
· Health assessments
· Medical examinations
· Blood tests
· Diagnostic investigations
· Referrals to specialists
· Medical reports
· Occupational health assessments
· Health screening services
· Weight management services
· Minor surgical procedures
· Joint injections
· Ear microsuction services
· Travel health advice
· Private prescriptions
· Other healthcare services as introduced from time to time
The availability of services may vary depending on clinician availability and clinical suitability.
3. ELIGIBILITY
Patients must provide accurate information regarding:
· Identity
· Address
· Contact details
· Date of birth
· Medical history
· Current medications
· Allergies
We reserve the right to request photographic identification.
Patients under the age of 18 may only be seen where services are specifically offered to children and where appropriate parental responsibility or legal authority exists.
Some services may only be available to patients aged 18 years and above.
4. PRIVATE HEALTHCARE STATUS
Imperial Medica operates independently from the NHS.
Patients acknowledge that:
· Services are private and chargeable.
· Fees are payable whether or not NHS services may be available.
· NHS prescriptions cannot be guaranteed.
· NHS referrals cannot be guaranteed.
· NHS investigations cannot be guaranteed.
Any recommendation made by our clinicians remains subject to acceptance by NHS providers.
5. APPOINTMENTS
Appointments may be booked:
· Online
· By telephone
· By email
· Through approved booking systems
Appointment availability cannot be guaranteed.
Appointments are allocated based upon:
· Clinical need
· Availability
· Clinician expertise
Patients must arrive on time.
Late arrival may result in:
· Reduced consultation time
· Rebooking
· Cancellation without refund
6. TELEPHONE AND VIDEO CONSULTATIONS
Remote consultations may not be suitable for all conditions.
Patients acknowledge:
· Certain diagnoses require physical examination.
· Remote consultations have limitations.
· Technical failures may occur.
· Clinical decisions may be based upon information provided by the patient.
Clinicians may require:
· Face-to-face assessment
· Emergency assessment
· Additional investigations
before definitive advice can be given.
7. CLINICAL DECISION MAKING
Clinical decisions remain solely the responsibility of the treating clinician.
Patients cannot demand:
· Specific medications
· Specific investigations
· Specific referrals
· Specific treatments
where these are not clinically indicated.
Clinicians reserve the right to decline requests where:
· Treatment is unsafe
· Treatment is inappropriate
· Treatment falls outside professional guidance
· Treatment is contrary to GMC guidance
8. PRESCRIPTIONS
Private prescriptions may be issued where clinically appropriate.
Prescription charges are separate from consultation fees unless otherwise stated.
Imperial Medica cannot guarantee:
· Medication availability
· Pharmacy stock
· Medication pricing
Controlled drugs may not be prescribed.
Repeat prescriptions remain subject to clinical review.
The Clinic reserves the right to refuse prescription requests where:
· Monitoring requirements have not been met
· Clinical information is incomplete
· Safety concerns exist
9. REFERRALS
Where clinically appropriate, patients may be referred to:
· NHS specialists
· Private specialists
· Allied health professionals
· Diagnostic providers
Referral acceptance remains entirely at the discretion of the receiving organisation.
Imperial Medica accepts no responsibility for:
· Referral waiting times
· Specialist availability
· NHS acceptance criteria
· Specialist fees
10. INVESTIGATIONS
Investigations may include:
· Blood tests
· Urine tests
· Swabs
· ECGs
· Imaging
· Other diagnostic tests
Results may be affected by:
· Laboratory delays
· External providers
· Technical issues
Turnaround times are estimates only.
The Clinic accepts no liability for delays caused by third parties.
11. RESULTS MANAGEMENT
Patients remain responsible for ensuring they receive results.
Imperial Medica will make reasonable efforts to communicate results.
However:
· Patients must ensure contact details remain current.
· Patients should contact the Clinic if results have not been received within expected timescales.
Failure to receive results does not remove patient responsibility to seek follow-up.
12. MEDICAL REPORTS, LETTERS AND FORMS
The Clinic may provide:
· Referral letters
· Insurance reports
· Occupational health reports
· Medical certificates
· Fitness certificates
· Employer reports
Additional charges may apply.
Imperial Medica aims to complete documentation within 24 hours where reasonably practicable.
This target is not guaranteed.
Delays may occur due to:
· Clinical complexity
· Safeguarding concerns
· Information gathering requirements
· Clinician availability
· System failures
· High demand
· External dependencies
· Circumstances beyond our control
The Clinic shall not be liable for losses arising from delays in document completion where reasonable efforts have been made.
No guarantee is provided regarding acceptance of reports by third parties.
13. EMERGENCIES
Imperial Medica is not an emergency service.
Patients experiencing:
· Chest pain
· Breathing difficulties
· Stroke symptoms
· Severe bleeding
· Collapse
· Mental health crisis
· Any life-threatening condition
must contact:
· 999
· NHS 111
· Local emergency services
The Clinic accepts no responsibility where emergency services should reasonably have been sought.
14. FEES AND CHARGES
Fees are published separately.
Fees may change without notice.
Payment may be required:
· At booking
· Before consultation
· After consultation
depending on the service.
Additional fees may apply for:
· Reports
· Letters
· Forms
· Prescriptions
· Investigations
· Procedures
15. PAYMENT TERMS
Payment methods may include:
· Credit card
· Debit card
· Bank transfer
· Approved payment platforms
Outstanding fees must be settled immediately.
The Clinic reserves the right to:
· Refuse future appointments
· Withhold non-essential services
· Pursue debt recovery
for unpaid fees.
16. PATIENT RESPONSIBILITIES
Patients agree to:
· Provide accurate information.
· Disclose relevant medical history.
· Follow clinical advice.
· Attend appointments.
· Treat staff respectfully.
· Update contact details.
Failure to do so may compromise care.
17. UNACCEPTABLE BEHAVIOUR
The Clinic operates a zero-tolerance policy towards:
· Violence
· Threats
· Harassment
· Discrimination
· Abuse
· Aggressive conduct
The Clinic may immediately terminate services where such behaviour occurs.
18. CONFIDENTIALITY
Imperial Medica complies with:
· UK GDPR
· Data Protection Act 2018
· GMC Confidentiality Guidance
Patient information will remain confidential except where disclosure is:
· Required by law
· Required for safeguarding
· Necessary for direct care
· Required by court order
· In the public interest
19. DATA PROTECTION
Patient information may be processed for:
· Direct healthcare
· Administration
· Quality improvement
· Regulatory compliance
· Legal obligations
Patients should refer to our Privacy Policy for further information.
20. CONSENT
Consent will be obtained where required.
Patients may withdraw consent at any time.
Withdrawal of consent may limit the services we can provide.
21. SAFEGUARDING
The Clinic has safeguarding responsibilities.
Where concerns arise regarding:
· Children
· Vulnerable adults
· Serious risk of harm
information may be shared without consent where legally justified.
22. CHAPERONES
Patients may request a chaperone for examinations.
Clinicians may require a chaperone to be present during intimate examinations.
Further details are set out within the Chaperone Policy.
23. COMPLAINTS
Patients have the right to raise concerns or complaints.
Complaints should initially be directed to:
The Registered Manager
Imperial Medica LimitedComplaints will be handled fairly, transparently, and in accordance with the Clinic’s Complaints Policy.
24. LIMITATION OF LIABILITY
Nothing in these Terms excludes liability where exclusion would be unlawful.
Subject to this:
Imperial Medica shall not be liable for:
· Indirect losses
· Consequential losses
· Loss of earnings
· Loss of opportunity
· Delays caused by third parties
· System outages
· Force majeure events
Liability shall be limited to the amount paid for the relevant service unless otherwise required by law.
25. FORCE MAJEURE
The Clinic shall not be liable for failure to perform obligations due to:
· Power failures
· IT failures
· Industrial action
· Pandemics
· Severe weather
· Government restrictions
· Other events beyond reasonable control
26. TERMINATION OF SERVICES
The Clinic may terminate services where:
· Fees remain unpaid.
· Patients behave abusively.
· Clinical relationships break down.
· Continuing care is unsafe.
Appropriate notice will be provided where possible.
27. GOVERNING LAW
These Terms and Conditions are governed by the laws of England and Wales.
Any disputes shall be subject to the exclusive jurisdiction of the Courts of England and Wales.
28. REVIEW OF TERMS
Imperial Medica reserves the right to amend these Terms and Conditions at any time.
The latest version will be made available through the Clinic website and upon request.
Patient use of Imperial Medica services constitutes acceptance of these Terms and Conditions.
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Version: 1.0
Effective Date: 01/07/2027
Review Date: Annually
Policy Owner: Operations Manager / Registered Manager
Approved By: Directors of Imperial Medica Limited1. POLICY STATEMENT
Imperial Medica Limited is committed to providing accessible, high-quality private healthcare services whilst ensuring that clinical appointments, procedures and clinician time are used efficiently.
Missed appointments, late cancellations and non-attendance prevent other patients from accessing care and result in lost clinical capacity.
This policy explains:
· Appointment booking requirements
· Cancellation procedures
· Refund arrangements
· Non-attendance charges
· Rescheduling arrangements
· Exceptional circumstances
· Procedures and package cancellations
This policy forms part of the contractual Terms and Conditions of Imperial Medica Limited.
2. PURPOSE
The purpose of this policy is to:
· Ensure fair and transparent charging arrangements.
· Reduce missed appointments.
· Protect clinical resources.
· Support business sustainability.
· Ensure compliance with UK consumer legislation.
· Maintain consistency across all services.
3. SCOPE
This policy applies to all services provided by Imperial Medica Limited including:
· GP consultations
· Telephone consultations
· Video consultations
· Health assessments
· Weight management services
· Ear microsuction services
· Joint injection clinics
· Minor surgery procedures
· Blood tests
· Medical examinations
· Occupational health assessments
· Medical reports
· Administrative services
· Specialist clinics
· Any future services introduced by Imperial Medica
4. APPOINTMENT BOOKINGS
Appointments may be booked through:
· Website booking systems
· Telephone
· Email
· Administrative staff
· Approved third-party booking platforms
Payment may be required at the time of booking.
Appointments are not confirmed until payment has been successfully received where applicable.
5. PATIENT CANCELLATION POLICY
Patients may cancel appointments by:
· Telephone
· Email
· Online booking system (where available)
The cancellation date and time will be determined by the time the cancellation request is received by Imperial Medica.
6. CANCELLATIONS MORE THAN 24 HOURS BEFORE APPOINTMENT
Where cancellation occurs more than 24 hours before the scheduled appointment time:
Patients may choose:
Option 1
Full refund.
Option 2
Transfer of payment to another appointment.
Option 3
Credit held on account for future services.
Refunds will normally be processed within 7–14 working days.
7. CANCELLATIONS LESS THAN 24 HOURS BEFORE APPOINTMENT
Where cancellation occurs less than 24 hours before the appointment:
No refund will normally be provided.
This is because:
· Clinical time has been reserved.
· It is often not possible to reallocate appointments at short notice.
· Costs have already been incurred.
Management may exercise discretion in exceptional circumstances.
8. NON-ATTENDANCE (DNA)
A patient is considered a non-attender where:
· They fail to attend.
· They fail to answer telephone consultations.
· They fail to join video consultations.
· They arrive too late for the appointment to proceed safely.
Non-attendance will normally result in:
· Loss of appointment.
· No refund.
· Full fee remaining payable.
The clinician will not usually be obliged to extend the appointment beyond the allocated slot.
9. LATE ARRIVAL
Patients are encouraged to arrive at least:
· 10 minutes before face-to-face appointments.
Where a patient arrives late:
The clinician may:
· Proceed with a shortened consultation.
· Rearrange the appointment.
· Treat the appointment as a non-attendance.
This decision will depend upon:
· Clinical safety.
· Appointment availability.
· Impact on other patients.
No refund will normally be provided.
10. CLINIC CANCELLATION
Imperial Medica reserves the right to cancel appointments where:
· Clinician illness occurs.
· Unexpected emergencies arise.
· Equipment failures occur.
· Premises become unavailable.
· Circumstances arise beyond our reasonable control.
Where the clinic cancels:
Patients will be offered:
Option 1
Alternative appointment.
Option 2
Full refund.
Imperial Medica shall not be responsible for:
· Travel costs.
· Accommodation costs.
· Loss of earnings.
· Consequential losses.
11. TELEPHONE AND VIDEO CONSULTATIONS
Failure to answer calls or join video consultations within:
10 minutes of the scheduled appointment time
may be treated as non-attendance.
Reasonable attempts may be made to contact the patient.
The clinician’s decision shall be final.
12. PROCEDURES AND SPECIALIST APPOINTMENTS
Certain appointments require:
· Equipment preparation
· Medication preparation
· Room allocation
· Additional staffing
These may include:
· Joint injections
· Minor surgery
· Microsuction
· Health assessments
Additional cancellation restrictions may apply.
Patients will be informed at booking.
13. BLOOD TESTS AND LABORATORY SERVICES
Once laboratory processing has commenced:
No refund will be available.
This includes:
· Blood tests
· Swabs
· Urine testing
· Pathology services
Third-party laboratory charges may remain payable regardless of attendance.
14. PRESCRIPTION FEES
Private prescription charges are non-refundable once:
· A prescription has been issued.
· Clinical review has been completed.
· Administrative processing has commenced.
Medication costs paid directly to pharmacies remain subject to pharmacy policies.
15. REFERRAL LETTERS AND REPORTS
Charges relating to:
· Referral letters
· Occupational health reports
· Insurance reports
· Medical certificates
· Administrative forms
are non-refundable once work has commenced.
Work is deemed to commence once:
· Clinical review begins.
· Documentation drafting begins.
· Information gathering begins.
16. WEIGHT MANAGEMENT PROGRAMMES
Where patients enrol in structured programmes:
· Consultation fees already delivered are non-refundable.
· Medication costs are non-refundable once ordered.
· Laboratory costs are non-refundable once incurred.
Future unused appointments may be refunded at the discretion of management and subject to package terms.
17. PACKAGE SERVICES
Where discounted packages are purchased:
Refund calculations may take account of:
· Services already provided.
· Discounts applied.
· Administrative costs incurred.
Imperial Medica reserves the right to recalculate charges based on standard individual service prices where packages are cancelled early.
18. EXCEPTIONAL CIRCUMSTANCES
Imperial Medica recognises that genuine emergencies occur.
Examples may include:
· Hospital admission
· Serious illness
· Bereavement
· Road traffic collision
· Significant family emergency
Evidence may be requested.
Management may:
· Waive cancellation fees.
· Offer rebooking.
· Provide partial refunds.
· Provide full refunds.
These decisions remain entirely discretionary.
19. REFUND PROCESS
Approved refunds will normally be returned:
· To the original payment method.
· Within 7–14 working days.
Processing times may vary depending on banking providers.
20. REFUNDS NOT AVAILABLE
Refunds will generally not be available where:
· The appointment has been completed.
· The patient chooses not to follow medical advice.
· A referral is not accepted.
· Medication is unavailable elsewhere.
· Desired outcomes are not achieved.
· Investigations are normal.
· Administrative work has commenced.
· The patient fails to attend.
21. PATIENT DISSATISFACTION
A request for a refund does not automatically indicate clinical negligence or service failure.
Where concerns exist:
Patients may use the clinic complaints process.
Refund requests and complaints will be considered separately.
22. FORCE MAJEURE
Imperial Medica shall not be liable for delays, cancellations or service interruptions arising from:
· Severe weather
· Industrial action
· National emergencies
· Utility failures
· IT failures
· Cyber incidents
· Government restrictions
· Pandemics
· Circumstances beyond our reasonable control
Refunds in such circumstances will be considered on a case-by-case basis.
23. LIMITATION OF LIABILITY
To the maximum extent permitted by law:
Imperial Medica shall not be liable for:
· Travel expenses
· Accommodation costs
· Childcare costs
· Loss of earnings
· Business interruption
· Consequential losses
arising from cancelled, delayed or rearranged appointments.
Nothing in this policy excludes liability where such exclusion would be unlawful.
24. REPEAT NON-ATTENDANCE
Where repeated non-attendance occurs, Imperial Medica reserves the right to:
· Require advance payment.
· Refuse future bookings.
· Remove patients from certain services.
· Restrict online booking access.
This decision will be documented and proportionate.
25. EQUALITY AND REASONABLE ADJUSTMENTS
Imperial Medica will make reasonable adjustments for patients who:
· Have disabilities.
· Have communication difficulties.
· Require additional support.
Requests should be made in advance wherever possible.
26. DISPUTES
Any dispute regarding fees, cancellations or refunds should initially be submitted in writing to:
The Registered Manager Imperial Medica Limited
The matter will be reviewed fairly and objectively.
27. GOVERNING LAW
This policy shall be governed by the laws of England and Wales.
Any disputes shall be subject to the jurisdiction of the Courts of England and Wales.
28. POLICY REVIEW
This policy will be reviewed:
· Annually
· Following legal changes
· Following significant complaints
· Following service changes
29. APPROVAL
Approved by:
Imperial Medica Limited Directors
Date: 01/07/2026
Review Date: 1/07/2027
APPENDIX 1 – STANDARD PATIENT NOTICE
Cancellation Notice
Appointments cancelled more than 24 hours before the appointment time are eligible for a full refund or rebooking.
Appointments cancelled less than 24 hours before the appointment time are normally non-refundable.
Failure to attend an appointment without notice will result in the loss of the appointment fee.
Certain services, prescriptions, reports, investigations and laboratory fees may be non-refundable once work has commenced.
Imperial Medica reserves the right to exercise discretion in exceptional circumstances.
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Version: 1.0
Effective Date: 01/07/2026
Review Date: Annually
Policy Owner: Registered Manager
Approved By: Directors of Imperial Medica Limited1. POLICY STATEMENT
Imperial Medica Limited is committed to providing safe, effective, caring, responsive and well-led healthcare services.
We recognise that despite our best efforts there may be occasions when patients, relatives, carers or representatives are dissatisfied with the service received.
We welcome complaints, concerns, comments and compliments as valuable opportunities to:
· Improve patient care
· Improve patient experience
· Learn from mistakes
· Identify service improvements
· Promote openness and transparency
· Meet regulatory requirements
We are committed to ensuring that all complaints are handled:
· Promptly
· Fairly
· Transparently
· Respectfully
· Without discrimination
· Without detriment to ongoing care
No individual will be treated unfairly for raising a concern or complaint.
2. PURPOSE
The purpose of this policy is to ensure compliance with:
· Health and Social Care Act 2008
· Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
· CQC Regulation 16: Receiving and Acting on Complaints
· Duty of Candour Regulations
· NHS and Independent Healthcare Complaints Guidance
· GMC Good Medical Practice
· Equality Act 2010
This policy establishes a clear framework for:
· Receiving complaints
· Investigating complaints
· Responding to complaints
· Learning from complaints
· Monitoring complaint trends
3. SCOPE
This policy applies to:
· Patients
· Parents
· Guardians
· Relatives
· Carers
· Advocates
· Representatives acting on behalf of patients
It applies to all services delivered by Imperial Medica Limited including:
· GP consultations
· Video consultations
· Telephone consultations
· Face-to-face consultations
· Health screening services
· Blood testing services
· Weight management services
· Ear microsuction services
· Minor surgery services
· Joint injection clinics
· Administrative services
4. DEFINITIONS
Concern
A concern is an issue raised that may be resolved immediately without formal investigation.
Complaint
A complaint is an expression of dissatisfaction requiring investigation and formal response.
Complainant
The individual making the complaint.
Duty of Candour
The legal requirement to be open and honest when things go wrong.
5. COMPLAINTS PRINCIPLES
Imperial Medica is committed to:
Accessibility
Patients must be able to raise concerns easily.
Fairness
All complaints will be investigated objectively.
Confidentiality
Information will only be shared on a need-to-know basis.
Timeliness
Complaints will be addressed promptly.
Learning
Complaints will drive service improvement.
Non-Retaliation
Care will never be adversely affected because a complaint has been made.
6. WHO CAN MAKE A COMPLAINT
Complaints may be made by:
· Patients
· Parents
· Legal guardians
· Individuals with legal authority
· Representatives with patient consent
· Next of kin where appropriate
Where a complaint is submitted by a third party, written consent may be required before confidential information is disclosed.
7. HOW TO MAKE A COMPLAINT
Complaints may be submitted:
In Writing
Email: [Insert Complaints Email]
Postal Address: Imperial Medica Limited [Insert Address]
By Telephone
[Insert Number]
In Person
Patients may speak with a member of staff who will document the complaint.
8. INFORMAL RESOLUTION
Many concerns can be resolved quickly without formal investigation.
Staff should attempt to:
· Listen carefully
· Clarify concerns
· Apologise where appropriate
· Resolve issues immediately where possible
If resolution is not achieved, the matter will be escalated to the formal complaints process.
9. FORMAL COMPLAINTS PROCEDURE
Upon receipt of a formal complaint:
Stage 1 – Acknowledgement
The complaint will be acknowledged within:
Three (3) working days
The acknowledgement will include:
· Confirmation of receipt
· Summary of complaint issues
· Investigation process
· Expected timescale
Stage 2 – Investigation
The complaint will be reviewed by:
· Registered Manager
· Clinical Lead
· Director
depending on the nature of the complaint.
The investigation may include:
· Review of medical records
· Staff interviews
· Review of correspondence
· Review of policies
· Review of systems and processes
Stage 3 – Response
Imperial Medica aims to provide a full written response within:
Twenty (20) working days
Where this is not possible:
· The complainant will be updated.
· Reasons for delay will be explained.
· A revised timescale will be provided.
10. CONTENT OF FINAL RESPONSE
The final response should include:
· Summary of complaint
· Investigation findings
· Conclusions reached
· Actions taken
· Apology where appropriate
· Service improvements identified
· Further escalation options
11. DUTY OF CANDOUR
Where an incident meets the statutory Duty of Candour threshold, Imperial Medica will:
· Inform the affected patient promptly
· Offer an apology
· Explain what happened
· Explain actions taken
· Provide written confirmation
The apology will not constitute admission of legal liability.
12. COMPLAINTS INVOLVING CLINICAL CARE
Clinical complaints may require review by:
· Clinical Lead
· Independent clinician
· External specialist advisor
Clinical investigations may consider:
· Clinical decision making
· Documentation
· Consent processes
· Communication
· Prescribing decisions
· Referral decisions
13. COMPLAINTS INVOLVING STAFF CONDUCT
Complaints concerning staff behaviour may involve:
· Internal investigation
· Disciplinary procedures
· Additional training
· Supervision arrangements
Appropriate confidentiality will be maintained throughout.
14. COMPLAINTS INVOLVING DATA PROTECTION
Where complaints concern:
· Confidentiality
· Data breaches
· Information sharing
· Records access
The matter may additionally be investigated under:
· UK GDPR
· Data Protection Act 2018
· Information Governance procedures
15. COMPLAINTS INVOLVING DISCRIMINATION
Complaints alleging discrimination will be investigated with reference to:
· Equality Act 2010
· Human Rights Act 1998
Appropriate corrective action will be taken where concerns are substantiated.
16. COMPLAINTS RECORDS
A complaints register will be maintained.
Records will include:
· Complaint reference number
· Date received
· Complainant details
· Nature of complaint
· Investigation outcome
· Actions taken
· Date closed
Records will be stored securely.
17. LEARNING FROM COMPLAINTS
Imperial Medica recognises complaints as an important source of learning.
Following investigation we may implement:
· Policy changes
· Staff training
· Clinical audits
· Process improvements
· Governance reviews
Learning outcomes may be discussed at:
· Governance meetings
· Significant event meetings
· Clinical meetings
· Board meetings
18. COMPLAINT TREND ANALYSIS
Complaints will be reviewed periodically to identify:
· Recurring themes
· Service weaknesses
· Training needs
· Risks to patient safety
Trend analysis forms part of the clinic’s quality assurance framework.
19. COMPLIMENTS AND FEEDBACK
Positive feedback is welcomed.
Compliments may be used:
· To recognise staff performance
· To support service development
· As evidence of good practice
Patient confidentiality will be respected.
20. COMPLAINTS TO EXTERNAL ORGANISATIONS
Patients should generally allow Imperial Medica the opportunity to investigate complaints first.
If a complainant remains dissatisfied, they may contact relevant organisations.
21. CARE QUALITY COMMISSION
The Care Quality Commission does not normally investigate individual complaints.
Patients may however notify the CQC of concerns regarding regulated services.
Care Quality Commission
Citygate Gallowgate Newcastle upon Tyne NE1 4PA
Website: www.cqc.org.uk
Telephone: 03000 616161
22. INFORMATION COMMISSIONER’S OFFICE
Complaints relating to personal data may be referred to:
Information Commissioner’s Office
Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Website: www.ico.org.uk
Telephone: 0303 123 1113
23. VEXATIOUS OR UNREASONABLE COMPLAINTS
Imperial Medica will investigate all genuine complaints fairly.
However, where complaints become:
· Abusive
· Threatening
· Excessive
· Repetitive
· Harassing
the Clinic reserves the right to:
· Limit communication channels
· Require written correspondence only
· Decline further responses once all issues have been fully addressed
This will be considered carefully and proportionately.
24. CONFIDENTIALITY
All complaints will be handled confidentially.
Information will only be shared with individuals involved in:
· Investigation
· Resolution
· Governance review
Records will be retained securely.
25. RETENTION OF COMPLAINTS RECORDS
Complaint records shall normally be retained for:
Minimum 10 years
or longer where:
· Litigation is ongoing
· Regulatory investigation is ongoing
· Insurance requirements apply
26. RESPONSIBILITIES
Directors
Responsible for:
· Oversight
· Governance
· Quality assurance
Registered Manager
Responsible for:
· Complaint management
· Investigation oversight
· Compliance with Regulation 16
Clinical Lead
Responsible for:
· Clinical complaint review
· Clinical learning
· Clinical governance actions
Staff
Responsible for:
· Reporting complaints
· Supporting investigations
· Promoting a positive complaints culture
27. MONITORING COMPLIANCE
Compliance with this policy will be monitored through:
· Governance meetings
· Complaints audits
· Annual policy review
· Patient feedback reviews
28. REVIEW
This policy will be reviewed:
· Annually
· Following significant incidents
· Following regulatory changes
· Following learning from complaints
29. POLICY APPROVAL
Approved by: Mr Anas Ahmed
Imperial Medica Limited Directors
Date: 01/07/2026
Review Date: 01/07/2027
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Version: 1.0
Effective Date: 01/07/2026
Review Date: Annually
Owner: Registered Manager
Approved By: Directors of Imperial Medica Limited1. POLICY STATEMENT
Imperial Medica Limited is committed to protecting the privacy, confidentiality, integrity and security of all personal information entrusted to us.
We recognise that patients place significant trust in us when sharing personal and sensitive health information. We are committed to handling all personal data fairly, lawfully, transparently and securely.
This Privacy Policy explains:
· What information we collect
· Why we collect it
· How we use it
· Who we share it with
· How we protect it
· Your legal rights
This policy applies to:
· Patients
· Parents and guardians
· Website users
· Prospective patients
· Staff
· Contractors
· Suppliers
2. DATA CONTROLLER
For the purposes of UK data protection legislation, Imperial Medica Limited is the Data Controller.
Data Controller:
Imperial Medica Limited
Company Number: 16001519Registered Office: [Insert Registered Office]
Email: [Insert Data Protection Email]
Telephone: [Insert Clinic Number]
3. LEGISLATION
This policy complies with:
· UK General Data Protection Regulation (UK GDPR)
· Data Protection Act 2018
· Human Rights Act 1998
· Common Law Duty of Confidentiality
· Health and Social Care Act 2008
· CQC Fundamental Standards
· General Medical Council Confidentiality Guidance
· Information Commissioner’s Office Guidance
4. PRINCIPLES OF DATA PROCESSING
Imperial Medica will ensure personal data is:
1. Processed lawfully, fairly and transparently.
2. Collected for specified legitimate purposes.
3. Adequate, relevant and limited.
4. Accurate and kept up to date.
5. Retained only as long as necessary.
6. Processed securely.
7. Accountable and auditable.
5. INFORMATION WE COLLECT
We may collect:
Personal Information
· Name
· Date of birth
· Address
· Email address
· Telephone number
· NHS number
· Passport details
· Identification documents
Health Information
· Medical history
· Medication history
· Allergies
· Examination findings
· Investigations
· Test results
· Referral information
· Clinical correspondence
· Images and recordings where relevant
Financial Information
· Billing information
· Payment details
· Transaction history
Website Information
· IP address
· Device information
· Browser information
· Cookies
· Website activity
6. SPECIAL CATEGORY DATA
Health information is classified as Special Category Data under UK GDPR.
We process such information only where lawful grounds exist.
7. PURPOSES FOR PROCESSING
We process information to:
Direct Healthcare
· Assess patients
· Diagnose conditions
· Provide treatment
· Prescribe medication
· Arrange investigations
· Make referrals
Administration
· Book appointments
· Manage records
· Contact patients
· Process payments
Legal Obligations
· Regulatory compliance
· Safeguarding
· Fraud prevention
· Reporting obligations
Quality Improvement
· Clinical audits
· Governance reviews
· Service improvement
Website Administration
· Improve functionality
· Security monitoring
· Usage analysis
8. LAWFUL BASIS FOR PROCESSING
We rely on:
Article 6 UK GDPR
· Contractual necessity
· Legal obligation
· Legitimate interests
· Vital interests
· Public task
Article 9 UK GDPR
· Provision of health care
· Health management systems
· Public health obligations
· Medical diagnosis
· Safeguarding responsibilities
9. CONSENT
Although healthcare processing is often not based upon consent under UK GDPR, we may seek consent where appropriate.
Examples include:
· Marketing communications
· Certain disclosures
· Photography
· Testimonials
Consent may be withdrawn at any time.
10. WHO WE MAY SHARE INFORMATION WITH
Information may be shared with:
Healthcare Providers
· GPs
· Specialists
· Hospitals
· Allied Health Professionals
Laboratories
· Blood testing providers
· Diagnostic providers
Pharmacies
· Dispensing pharmacies
· Medication suppliers
Regulatory Bodies
· Care Quality Commission
· General Medical Council
· NHS Counter Fraud Authority
Professional Advisers
· Solicitors
· Accountants
· Insurers
Government Authorities
Where legally required.
11. SHARING WITH NHS SERVICES
With patient consent where appropriate, we may share information with:
· NHS GP practices
· NHS Trusts
· Community services
· NHS specialists
to support continuity of care.
12. SAFEGUARDING DISCLOSURES
Information may be disclosed without consent where there is concern regarding:
· Child protection
· Vulnerable adults
· Serious crime
· Risk of harm
· Public safety
Such disclosures will be documented and justified.
13. WEBSITE DATA COLLECTION
When visiting our website, we may collect:
· Device type
· Browser information
· Pages viewed
· Referral sources
· Session duration
This information is primarily used for security and service improvement.
14. COOKIES
Cookies may be used to:
· Improve website functionality
· Enhance user experience
· Monitor website performance
· Maintain security
Users may manage cookies through browser settings.
15. CCTV
Where CCTV operates on clinic premises:
· Appropriate signage will be displayed.
· Recordings may be used for security.
· Access is restricted.
· Retention periods apply.
CCTV is not used for routine clinical monitoring.
16. SECURITY OF INFORMATION
Imperial Medica employs appropriate technical and organisational measures including:
· Encryption
· Secure servers
· Password protection
· Access controls
· Staff training
· Audit trails
· Cyber security monitoring
Access is restricted to authorised personnel.
17. MEDICAL RECORDS
Medical records are maintained in accordance with:
· GMC Guidance
· NHS Records Management Code of Practice
· CQC requirements
Only authorised personnel may access records.
18. RETENTION OF INFORMATION
Records are retained in accordance with legal and professional requirements.
Typical retention periods include:
Adult Medical Records
Minimum 8 years after last treatment.
Children’s Records
Until age 25 or longer where required.
Financial Records
Minimum 6 years.
Complaints Records
Minimum 10 years.
Retention periods may be extended where legally required.
19. INTERNATIONAL TRANSFERS
Imperial Medica generally stores data within the United Kingdom.
Where international transfers occur, appropriate safeguards will be implemented.
These may include:
· Adequacy regulations
· Standard Contractual Clauses
· Approved safeguards
20. AUTOMATED DECISION MAKING
Imperial Medica does not routinely make solely automated decisions affecting patients.
Clinical decisions are always subject to professional review.
21. PATIENT RIGHTS
Under UK GDPR patients have rights including:
Right to be Informed
You have the right to know how your information is used.
Right of Access
You may request access to your records.
Right to Rectification
Incorrect information may be corrected.
Right to Erasure
Applicable in limited circumstances.
Right to Restrict Processing
Where legally appropriate.
Right to Data Portability
Applicable in certain situations.
Right to Object
Subject to legal limitations.
Rights Regarding Automated Decision Making
Where applicable.
22. SUBJECT ACCESS REQUESTS
Patients may request copies of their records.
Requests should be submitted in writing.
Identity verification may be required.
Responses are normally provided within one month.
Requests that are manifestly excessive may incur lawful administrative charges.
23. DATA BREACHES
Imperial Medica maintains procedures for identifying and managing data breaches.
Where required:
· Breaches will be investigated.
· ICO notifications will be made.
· Individuals will be informed.
Corrective actions will be implemented.
24. STAFF CONFIDENTIALITY
All staff are subject to:
· Confidentiality agreements
· Information governance requirements
· Mandatory training
· Professional standards
Unauthorised disclosure may result in disciplinary action.
25. MARKETING COMMUNICATIONS
Marketing communications will only be sent where:
· Consent has been obtained; or
· Another lawful basis applies.
Patients may unsubscribe at any time.
26. CHILDREN’S DATA
Where services are provided to children, information will be handled in accordance with applicable laws relating to parental responsibility, competence and confidentiality.
27. COMPLAINTS REGARDING DATA PROTECTION
Concerns should initially be directed to Imperial Medica.
If unresolved, individuals may complain to:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AFWebsite: www.ico.org.uk
28. REVIEW OF POLICY
This policy shall be reviewed annually or sooner where:
· Legislation changes
· Regulatory guidance changes
· Significant incidents occur
· Organisational changes occur
29. CONTACT
For questions regarding this Privacy Policy please contact:
The Data Protection Lead
Imperial Medica Limited
Email: [Insert Email]
Telephone: [Insert Telephone Number]
**FOR OUR WEBSITE BUILDER (SQUARESPACE) SPECIFICALLY**
Analytics : This website collects personal information to power our site analytics, including:
Information about your browser, network, and device
Web pages you visited prior to coming to this website
Your IP address
This information may also include details about your use of this website, including:
Clicks
Internal links
Pages visited
Scrolling
Searches
Timestamps
We provide this information to Squarespace, our website analytics provider, to learn about site traffic and activity.
Cookies:This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.
These necessary and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.
These analytics and performance cookies are used on this website, as described below, only when you acknowledge our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.
For Website Visitors:This website is hosted by Squarespace. Squarespace collects personal information when you visit this website, including:
Information about your browser, network and device
Web pages you visited prior to coming to this website
Web pages you view while on this website
Your IP address
Squarespace needs the data to run this website, and to protect and improve its platform and services. You can read more about how Squarespace uses your data (site usage information of end users) for its own purposes in their Privacy Policy.
-
Version: 1.0
Effective Date: 01/07/2026
Review Date: Annually
Policy Owner: Registered Manager
Approved By: Directors of Imperial Medica Limited1. POLICY STATEMENT
Imperial Medica Limited is committed to providing safe, respectful, dignified and patient-centred care at all times.
We recognise that some examinations, consultations and procedures may be considered intimate, sensitive or potentially distressing by patients.
This policy ensures that patients are offered appropriate support through the availability of trained chaperones and that clinicians are protected from misunderstandings, allegations or inappropriate behaviour.
The policy supports:
· Patient dignity
· Patient privacy
· Patient safety
· Safeguarding responsibilities
· Professional standards
· Clinical governance
· Compliance with Care Quality Commission (CQC) requirements
· Compliance with General Medical Council (GMC) guidance
2. PURPOSE
The purpose of this policy is to:
· Protect patients during examinations and procedures.
· Ensure patients understand their right to request a chaperone.
· Ensure clinicians offer chaperones where appropriate.
· Support staff undertaking chaperone duties.
· Promote transparency and trust.
· Reduce risks to patients and staff.
· Meet regulatory requirements.
3. LEGISLATION AND GUIDANCE
This policy is informed by:
· Health and Social Care Act 2008
· CQC Fundamental Standards
· GMC Good Medical Practice
· GMC Intimate Examinations and Chaperones Guidance
· Equality Act 2010
· Human Rights Act 1998
· Safeguarding legislation
· Data Protection Act 2018
· UK GDPR
4. SCOPE
This policy applies to:
· Doctors
· Nurses
· Healthcare Assistants
· Allied Health Professionals
· Administrative staff acting as chaperones where appropriately trained
· Contractors providing services on behalf of Imperial Medica
This policy applies to:
· Face-to-face consultations
· Intimate examinations
· Clinical procedures
· Diagnostic assessments
· Any examination where a patient may feel vulnerable
5. DEFINITION OF A CHAPERONE
A chaperone is an impartial individual present during an examination or procedure who:
· Supports the patient.
· Provides reassurance.
· Assists communication where appropriate.
· Helps safeguard patient dignity.
· Acts as an independent observer.
· Supports professional conduct.
· Provides protection for both patient and clinician.
The chaperone is not present solely as a witness but plays an active safeguarding role.
6. WHAT IS AN INTIMATE EXAMINATION?
An intimate examination may include:
Female Examinations
· Breast examination
· Pelvic examination
· Vaginal examination
· Cervical smear examination
Male Examinations
· Genital examination
· Testicular examination
· Prostate examination
Other Examinations
Some patients may regard other examinations as intimate including:
· Rectal examinations
· Groin examinations
· Chest examinations
· Examination requiring removal of clothing
· Procedures involving exposure of sensitive body areas
The patient’s perception should always be respected.
7. PATIENT RIGHTS
Patients have the right to:
· Be offered a chaperone.
· Request a chaperone.
· Decline a chaperone.
· Request a different chaperone where available.
· Request postponement of a non-urgent examination if a suitable chaperone is unavailable.
Patients will not be treated less favourably because they request a chaperone.
8. WHEN A CHAPERONE SHOULD BE OFFERED
A chaperone should routinely be offered:
· During intimate examinations.
· During intimate procedures.
· Where safeguarding concerns exist.
· Where communication difficulties exist.
· When examining children.
· When examining vulnerable adults.
· When either patient or clinician would feel more comfortable.
Clinicians may offer a chaperone during any consultation they consider appropriate.
9. WHEN A CHAPERONE MAY BE REQUIRED
Imperial Medica reserves the right to require a chaperone where:
· An intimate examination is planned.
· The clinician considers a chaperone necessary.
· There are safeguarding concerns.
· There is a history of challenging behaviour.
· The patient or clinician may be vulnerable.
If a patient declines a required chaperone, the clinician may:
· Decline to proceed.
· Rearrange the appointment.
· Refer to another clinician.
This decision will be documented.
10. WHO MAY ACT AS A CHAPERONE?
A chaperone should ideally be:
· A trained healthcare professional.
· A trained member of clinic staff.
· A person familiar with confidentiality obligations.
Chaperones should:
· Understand their role.
· Receive appropriate training.
· Understand safeguarding responsibilities.
· Maintain confidentiality.
11. FAMILY MEMBERS AND FRIENDS
Family members or friends may provide emotional support but are generally not considered formal chaperones.
They do not replace the role of a trained chaperone.
Where a patient wishes a family member to be present:
· This request will normally be accommodated.
· A formal chaperone may still be offered or required.
12. CHILDREN AND YOUNG PEOPLE
When examining children:
· Parents or guardians should usually be present.
· The wishes of competent young people should be respected.
· Safeguarding principles must be followed.
Where concerns arise:
· The clinician should seek advice from the safeguarding lead.
· Additional safeguarding measures may be implemented.
13. VULNERABLE ADULTS
Extra consideration should be given to:
· Learning disabilities
· Cognitive impairment
· Mental health difficulties
· Communication challenges
Additional support may be offered where appropriate.
14. SAME-SEX CHAPERONES
Patients may request a same-sex chaperone.
Imperial Medica will make reasonable efforts to accommodate such requests.
However:
· Availability cannot be guaranteed.
· Delays or rearrangement may be required.
15. REMOTE CONSULTATIONS
A formal chaperone is generally not required for telephone consultations.
During video consultations:
· Patients may request another person to be present.
· Clinicians may recommend support persons where appropriate.
Remote consultations involving intimate examinations will generally not be undertaken.
16. ROLE OF THE CHAPERONE
The chaperone should:
· Introduce themselves.
· Explain their role.
· Remain attentive throughout.
· Observe the examination.
· Maintain professional conduct.
· Report concerns.
· Support patient dignity.
The chaperone should not:
· Leave during the examination.
· Use mobile phones.
· Breach confidentiality.
· Undertake tasks outside their competence.
17. PRIVACY AND DIGNITY
Imperial Medica will ensure:
· Private clinical rooms.
· Appropriate curtains or screens.
· Minimal exposure.
· Clear explanations before examinations.
· Respect for cultural and religious preferences.
Patients should only remove clothing necessary for the examination.
18. CONSENT
Before any examination:
The clinician must explain:
· Why the examination is required.
· What the examination involves.
· Potential findings.
· The availability of a chaperone.
Consent must be obtained.
Consent may be withdrawn at any time.
19. DOCUMENTATION
The medical record must document:
Where Chaperone Accepted
“Chaperone offered and accepted.”
Record:
· Name
· Role
· Date
Example:
“Chaperone offered and accepted. Mrs Jane Smith (Practice Nurse) present throughout examination.”
Where Chaperone Declined
“Chaperone offered and declined.”
Where Chaperone Required But Declined
Document:
· Discussion held
· Decision not to proceed
· Alternative arrangements made
20. STAFF TRAINING
All staff acting as chaperones should receive training covering:
· Chaperone responsibilities
· Confidentiality
· Safeguarding
· Professional boundaries
· Documentation
· Escalation procedures
Training records will be maintained.
21. SAFEGUARDING
Chaperones have a responsibility to raise concerns where they observe:
· Abuse
· Neglect
· Inappropriate behaviour
· Breaches of dignity
· Safeguarding risks
Concerns should be reported immediately to:
· Clinical Lead
· Registered Manager
· Safeguarding Lead
Where necessary, safeguarding procedures will be activated.
22. PROFESSIONAL CONDUCT
All staff must:
· Behave professionally.
· Respect patient dignity.
· Maintain confidentiality.
· Follow clinic policies.
Any breach may result in:
· Investigation
· Disciplinary action
· Referral to professional regulators
23. CONFIDENTIALITY
Chaperones must maintain strict confidentiality.
Information obtained during examinations:
· Must not be disclosed.
· Must only be shared where necessary for care or safeguarding.
· Must be stored securely.
24. INCIDENT REPORTING
Any concerns relating to:
· Patient safety
· Chaperone conduct
· Clinician conduct
· Safeguarding issues
must be reported through the clinic incident reporting process.
Incidents will be investigated and reviewed through governance processes.
25. AUDIT AND MONITORING
Compliance with this policy will be monitored through:
· Clinical record audits
· Complaints reviews
· Incident reviews
· Governance meetings
Audit findings will inform service improvements.
26. EQUALITY AND DIVERSITY
Imperial Medica is committed to:
· Equality
· Diversity
· Inclusion
Reasonable adjustments will be made where required.
The clinic will respect:
· Cultural preferences
· Religious beliefs
· Gender identity
· Communication needs
while maintaining patient safety.
27. RESPONSIBILITIES
Directors
Responsible for:
· Oversight of policy implementation.
· Governance monitoring.
Registered Manager
Responsible for:
· Policy implementation.
· Staff training oversight.
· Compliance monitoring.
Clinical Lead
Responsible for:
· Clinical governance.
· Audit and review.
Staff
Responsible for:
· Following policy requirements.
· Maintaining professional standards.
28. REVIEW
This policy shall be reviewed:
· Annually
· Following significant incidents
· Following regulatory changes
· Following safeguarding concerns
29. POLICY APPROVAL
Approved By: Mr Anas Ahmed
Imperial Medica Limited Directors
Date: 01/07/2026
Review Date: 01/07/2027