Purpose
This policy defines the framework for granting proxy access to GP online services and a patient’s medical information, ensuring compliance with NHS England guidance while safeguarding patient confidentiality, autonomy, and best interests.
Proxy access allows a designated individual (e.g., carer, family member, or legal representative) to manage aspects of a patient’s online account and/or information, including appointments, prescriptions, and where justified, medical records.
Scope
Applies to all patients registered at Manor View Practice and individuals requesting proxy access on their behalf.
Key Principles
1. Consent & Capacity
- Adults with capacity: Proxy access requires explicit, informed consent from the patient, documented via a signed proxy access form.
- Adults lacking capacity: Access may be granted if:
- The proxy holds Lasting Power of Attorney (LPA) for Health/Welfare or is a Court-Appointed Deputy.
- A GP Partner determines it is in the patient’s best interests under the Mental Capacity Act 2005.
2. Children (Under 16)
- Patients aged 12 – 15yrs will be invited to a face-to-face appointment with a GP Partner to discuss proxy access. A decision to grant / deny access will be made thereafter.
- Proxy access is likely only granted in exceptional circumstances, such as:
- Chronic/complex medical conditions requiring ongoing proxy management.
- Assessed lack of capacity to consent (e.g., severe learning disabilities).
- Parents/guardians must provide evidence of legal authority (e.g., court order) if the child falls into these exceptional circumstances for medical reasons but is competent but refuses consent.
3. Identity Verification
- Proxies must provide:
- Two forms of ID (one photo, one address proof) for detailed record access.
- One form of ID to prove birth certificate / legal guardianship (for child under 16) OR
- One form of ID to confirm lasting power of attorney (for adult lacking capacity)
- Face-to-face verification is required.
ID Verification
ID documents can be verified and Proxy Application submitted at the following times / sites:
| Site | Day | Time |
|---|---|---|
| Borehamwood | Wednesday | 1300 - 1700 |
| Borehamwood | Thursday | 0900 - 1500 |
| Bushey | Tuesday | 1000 - 1700 |
| Bushey | Wednesday | 1000 - 1700 |
| Bushey | Thursday | 1000 - 1700 |
| South Oxhey | Monday | 1100 - 1700 |
| South Oxhey | Wednesday | 0900 - 1400 |
| Watford | Monday | 1000 - 1600 |
| Watford | Tuesday | 1100 - 1800 |
| Watford | Wednesday | 0800 - 1100 |
4. Levels Of Access
| Access Level | Permissions | Verification Required |
|---|---|---|
| Standard | Book appointments, order repeat prescriptions | 1 form of ID (e.g., passport, driving licence) |
| Full (with medical record access) | View medical records (redacted if necessary) | 2 forms of ID + patient consent (or best interest decision) |
5. Decision Authority
- All proxy requests must be reviewed and approved/declined by:
- A GP Partner or the Director of Operations.
- Refusals must be documented with clear rationale in the patient’s notes.
Procedure
1. Request Submission
- Patient/proxy completes the Proxy Access Consent Form (see Appendix 1).
- Form must specify access level and include patient/proxy signatures.
Appendix 1 - Online & Proxy Access Patient Information
Online access is available to all patients who are aged 13 and over.
To set up an online account, please visit our website: https://manorviewpractice.co.uk/online-services/
This form must be completed in order that your request for proxy access to be processed.
The form must be completed and handed in to any of our reception team(s) and ID must be presented for verification at the same time.
For patients aged 16 and over, a decision to grant or deny access will be made following review of the application.
Patients aged 13 – 15 will be invited to attend a face-to-face appointment with a GP Partner to confirm their application, after which a decision to grant or deny access will be made.
If granted, proxy access should be set up within two weeks of receipt of the request.
If proxy access is granted, please note this will only be withdrawn if the patient requests this in writing or if an exception arises. The exceptions to this are:
Access via the NHS App
- If proxy access is granted, after setup, you can use the NHS App to switch to the linked profile by:
- Scrolling to the bottom of the home page and pressing “Switch profiles.”
- Selecting “Manage services for another person.”
- Choosing the name of the person whose account you wish to access and pressing the green “Switch profile” button.
- From there, you can book appointments, order prescriptions, and view medical records on behalf of the person you are caring for
Proxy access is granted from the date the application is approved rather than being backdated to earlier dates. This is for two important reasons:
- patient consent – when proxy access is set up, both the patient (unless they lack capacity) and the proxy must provide explicit consent, and their identities are verified. Granting access from the approval date ensures that all necessary checks and consent procedures have been properly completed before any access is allowed.
- data protection – granting access prospectively (i.e., from the approval date) helps protect sensitive patient information. It prevents any unauthorised or premature access to records before all safeguards are in place.
Exceptions – In some cases, the GP may agree to provide longer or retrospective access if this is considered beneficial for the patient and all necessary safeguards are in place.
However, this is not standard practice and is only done after careful consideration and agreement between the patient (or their representative), the care provider, and the GP practice
Approved proxies receive a confirmation SMS from Manor View Practice plus unique login credentials via email.
If for any reason, proxy access is denied, a reason will be provided to the person who submitted the application. Please note any decisions made regarding proxy access are final and cannot be appealed.
For any queries regarding proxy access, please email the practice on mvp.manorview@nhs.net
2. Assessment
A GP Partner or manager will:
- Verify identity
- Assess capacity (if applicable)
- Approve / decline the request, based on clinical circumstances and/or need
3. Approval & Setup
Approved proxies receive unique login credentials via email.
Access is revoked if:
- Patient withdraws consent.
- Proxy breaches confidentiality (e.g. sharing login details).
4. Documentation
Signed forms will be scanned into the patient’s record to record:
- Consent status.
- Access level granted.
- Identity verification method.
Exceptions & Safeguards
- Coercion risk: If coercion is suspected, the GP must assess the patient privately.
- Care homes: Requires manager authorisation and annual access reviews.
- Revocation: Patients may withdraw consent at any time via written request.
Definitions:
Exceptional Circumstances:
- Patient has a Carer.
- Patient has Learning Difficulties.
- Patient has difficulties managing own health due to memory or speech issues.
- Patient has a long-term condition and requires support in managing own health.
- Patient has a Health & Welfare Lasting Power of Attorney (“LPA”).
Health & Welfare Lasting Power of Attorney:
- Third parties with an LPA for Health & Welfare are not given automatic proxy access. These requests need to be assessed by a Partner to ensure proxy access is deemed to be in the best interests of the patient. Evidence of the LPA must be obtained and passed to the Partner.
- An LPA for Property & Affairs does not entitle a third party to proxy access under any circumstance.
Excepted Circumstances:
- Patient is under 16: proxy access will be automatically withdrawn when patient turns 16 and a new application for proxy access will need to be made.
- Patient lacks capacity: a review of the proxy access will take place if a change in capacity is deemed to have taken place (i.e., patient reacquires capacity).
- Patient loses capacity after proxy access is given: a review of the proxy access will take place if a patient is deemed to have lost the ability to consent after proxy access has been given.
Additional Given Reasons Why Proxy Access Would Not Be Granted:
- Not in best interests of patient.
- Patient or third party has previously misused online services.
- Concerned third party will not keep patient information safe.
- Concerned patient is being coerced into giving proxy access.
- Patient is not able to make decisions for themselves and there is no clear justification as to why third party should be given proxy access.
References:
NHS England Proxy Access Guidance, Mental Capacity Act 2005, and Manor View Practice’s Data Protection Policy.
Key Points on ID Requirements:
Summary Table
| Who must provide ID? | Purpose of ID check | Additional requirements |
|---|---|---|
| Patient | Confirm identity and consent | May need to prove capacity to consent |
| Proxy (applicant) | Confirm identity and eligibility | May need to show legal authority if patient lacks capacity |
| Proof of relationship | Not always required, but may be requested | Consent or legal authority is essential |
In short: MVP requires ID from both the proxy applicant and the patient to verify their identities. The main focus is on confirming consent and ensuring the arrangement is in the patient’s best interests, not necessarily on proving the relationship itself.
Proxy Access Patient Information Leaflet & Application Form
