Doctors are commonly asked to share information about their appraisal with employers whether as part of pre-employment processes or within the organisation’s routine governance arrangements. This is a valid process described in the Information Flows guidance produced by NHS England.

However, doctors report that the request can extend beyond simple proof of appraisal or provision of the appraisal outputs, to include the full portfolio. They can feel pressure to comply, with the implication that their position may be jeopardised if they do not.

Organisations are reminded that the appraisal documentation is confidential between the doctor and their appraiser. This is important for the integrity of the appraisal process so that doctors can reflect openly, with confidence in the limits of access to the information by other persons. A doctor’s responsible officer may also have access in order to discharge their statutory function, most commonly when considering the doctor’s revalidation recommendation. While other agencies may have access this is unusual and must be described and controlled by the organisation’s privacy policy (e.g. for NHS England, the Appraisal Documentation Access Statement).

On one hand a doctor is at liberty to disclose whatever personal information they choose to a third party. However, it should be sufficient for the doctor to share their appraisal outputs and not their full portfolio in the circumstance described above. Organisations should consider whether asking for more may be classed as forced consent under GDPR. If information beyond the outputs is required, the specific nature and justification should be discussed with the doctor so that they can make an informed decision whether to provide it.

In reassurance to organisations taking on a doctor whose prescribed connection is elsewhere, if information of note about the doctor’s practice is known to their responsible officer, the information flows guidance allows for this to be passed to the other places where the doctor works. This occurs outside the appraisal process. The guidance therefore also encourages organisations to open a channel of communication with a doctor’s responsible officer when they engage the doctor, so this flow can occur as necessary.

• NHS England – Information flows
• NHS England – Medical Appraisal Documentation Access Statement

This information sheet is relevant to all designated bodies in England.

Released December 2019.