Step 2: Evaluate the safety of proxy access

Once clinical professionals and staff have determined that proxy access is necessary and relevant, they must check the patient's and proxy's records to inform their assessment of any potential safeguarding concerns or risk of harm to the patient that may arise from proxy access. Where present, the organisation's safeguarding lead must be involved at this stage.

In the case of families or household members, clinical professionals and staff should consider whether to review the records of people in the household. They must look for signs of coercion, abuse, and/or neglect recorded in all records, and consider risk factors for misuse of proxy access that are present such as substance misuse and social factors including forensic history.

The patient's and proxy's mental health should also be considered, particularly serious mental health issues, and whether proxy access could have a detrimental impact. For example, a young person under the care of CAMHS might not want their parents seeing information about their mental health consultations.

Clinical professionals and staff can also check an authoritative source of safeguarding information to establish safeguarding concerns. For example, Child Protection Information Sharing (CP-IS), a national service, can be used to check if a child is on a child protection plan as part of deciding on proxy access.

This safeguarding check will inform what information, if any, should be redacted if proxy access is granted. The presence of anything other than trivial levels of redaction from a record should trigger a considered evaluation of the appropriateness of proxy access because:

• at the time of writing, redaction applies to both self-access and proxy access within most clinical systems. This risks disadvantaging patients who currently benefit from self-access.
• there is a higher chance of there being existing or future information which requires redaction, and the risk of harm increases with every entry to the record.