Step 10: Review and manage access on an ongoing basis

Proxy access should be reviewed and managed on an ongoing basis so that it remains safe and appropriate.

The organisation must have a process for managing proxy access that accounts for the following scenarios as a minimum.

Scenarios: what staff and clinical professionals need to do

New information is added to the patient's record

Consider if the information should be redacted from the proxy’s view if proxy access is in place. Anything more than trivial levels of redaction warrants a re-evaluation of proxy access by a responsible clinical professional and the organisation’s safeguarding lead. 

A safeguarding concern is identified in relation to the patient

If the safeguarding concern suggests that ongoing proxy access would no longer be appropriate, proxy access must be removed.  As in step 9, any communication about this decision to the proxy or the patient should prioritise patient safety.

A patient requests that proxy access is removed

If a patient requests that proxy access is removed, and they are Gillick competent or have the capacity to make this decision, then proxy access must be removed. If necessary, action must be taken by the safeguarding lead and responsible clinical professional to safeguard the patient.

Time-bound access reaches its end date

If time-bound access reaches its end date, then it should be removed. Access should automatically be removed when a child reaches age 16. Earlier milestones for suspension may be set based on local policy. Parents and carers should be informed ahead of access being removed.

A child is moved into the care of the local authority or is adopted

When a child is moved into care of the local authority or adopted, any proxy access previously granted on behalf of the child must be reviewed. Where possible, the safeguarding lead should work with the child’s responsible clinical professional and social worker to grant proxy access to the child’s foster parents or adopting parents.