College responds to the GOC Standards of Practice review

Q1. Do you think there should be any difference in our expectations of students and fully qualified registrants?

• Yes 
• No 
• Not sure

While all students are rightly expected to ensure the care and safety of their patients and the public and to uphold professional standards, all new statements, new standards and revised standards throughout should recognise the evolution of learning, development and acquisition of knowledge, skills and professional judgment over the period of students’ training. 

See our response to Q10.

Q2. Do you think any of the proposed changes could affect any individuals or groups with one or more of the protected characteristics defined in the Equality Act 2010?

• Yes
• No
• Not sure

Q3. Do you think any of the proposed changes could affect any other individuals or groups, either positively or negatively?

• Yes
• No
• Not sure

See our response to Q16 - Standard 2.2.

Q4. Will the proposed changes have effects, whether positive or negative, on:  
(a) opportunities for persons to use the Welsh language, and  
(b) treating the Welsh language no less favourably than the English language?

• Yes 
• No 
• Not sure 

Q5. Could the proposed changes be revised so that they would have positive effects, or increased positive effects, on: 
(a) opportunities for persons to use the Welsh language, and  
(b) treating the Welsh language no less favourably than the English language?

• Yes 
• No 
• Not sure 

Q6. Could the proposed changes be revised so that they would not have negative effects, or so that they would have decreased negative effects, on: 
(a) opportunities for persons to use the Welsh language, and  
(b) treating the Welsh language no less favourably than the English language? 

• Yes
• No
• Not sure

Q7. Is there anything else you think we should consider as part of the proposed changes?

• Yes
• No
• Not sure

Standards of Practice for Optometrists and Dispensing Opticians: additional focus on education and leadership. 

Whilst we welcome the mention of education as an example of leadership in the introduction, we feel that as regulated healthcare professionals, optometrists and dispensing opticians should be under a specific obligation to contribute to sharing good practice through education. We think it should be a standard, and accordingly be associated with specific obligations or a domain in CPD.

Q8. Do you think there should be a short implementation period after the new standards are published and before they come into effect? The purpose of an implementation period would be to give registrants time to adapt; to adjust their conduct and enable stakeholders to review the standards and make any necessary amendments to practice, policy, guidance, or training material?  

• Yes 
• No 
• Not sure 

We agree that there should be a short implementation period before the new standards come into effect and recommend it to be of a minimum of 8 months, as it was when the GOC last consulted on these standards in 2015; they came into effect 8 months (1 April 2016) after publication on 28 July 2015.This would give enough time for registrants, practice owners and businesses to adapt and adjust to the new standards, and to the optical sector bodies, including The College of Optometrists, to review their resources and make the necessary amendments to practice, policy, guidance, and training materials.

We also recommend that the GOC delivers appropriate education and promotional activity to help registrants become familiar with the new standards before they come into effect.

In addition, we recommend aligning the implementation dates for the three sets of Standards, so they all come into effect once the revision of the Standards for optical businesses is completed. As mentioned by the GOC, business owners and employers have a role in creating a culture and environment in which registrants feel comfortable to “step up” and lead. They set standards of performance and create protocols to be followed within their practices by their employees. Although optical businesses are required to support registrants to meet their professional requirements, registrants should not be expected to comply with new individual standards that would be different or stricter to those expected from optical businesses while the business standards are being updated. This would add a disproportionate burden for registrants and put them in a difficult position where they would be required by their employer to behave in one way while the GOC standards require them to behave in a different manner.

Q9. To what extent do you agree that the addition to the introduction on leadership is clear? 

• Strongly agree
• Somewhat agree
• Neither agree nor disagree
• Somewhat disagree
• Strongly disagree

See our response to Q10.

Q10. To what extent do you agree that the addition to the introduction on leadership sets appropriate minimum expectations of registrants? 

• Strongly agree
• Somewhat agree
• Neither agree nor disagree
• Somewhat disagree
• Strongly disagree

Standards for Optical Students: Addition to the introduction on leadership. 

While we support the development of leadership skills for students, the College would recommend amending this statement as below:

“All registrants are expected to demonstrate emerging leadership skills, attributes and behaviours, relevant to their scope of practice.” 

The Standards for Optical Students should set a realistic expectation for students and give trainees the scope to learn, develop and practice these skills throughout their student experience. As it currently stands, this statement implies that students would need to develop these leadership skills prior to the start of their study which sets an unrealistic expectation and does not ensure trainees will be able to develop and hone these skills throughout their student experience.

Q11. To what extent do you agree that the addition to the introduction on providing care for patients in vulnerable circumstances is clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree

Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students: Addition to the introduction on patient vulnerabilities. 

We welcome the addition of this new statement as it will help reducing eye health inequalities. However, we recommend clarifying this statement as below:

“You must exercise particular care when providing services to patients who, due to their personal circumstances, are in need of special care, support or protection or are at risk of abuse or neglect and make all reasonable attempts to accommodate the person’s needs during the examination”.

In addition, we recommend that the GOC should develop further guidance on vulnerabilities to help registrants identify patients who may be vulnerable. Since vulnerability is not restricted to ill health or disability, or have visible signs, registrants may struggle to identify those patients who may be vulnerable, for example because they are handling a difficult set of life circumstances, without any visible sign of their vulnerabilities. 

We suggest using the following introductory text as a footnote under Standard 7.1 (6.1):

“Patients may be vulnerable for a range of reasons, including physical or mental health conditions, capability in managing their health, or handling a difficult set of life events. Levels of vulnerability may vary between contexts, and change over time, so a patient's vulnerabilities should be considered as part of each consultation.” 

Standards for Optical Businesses: 

We recommend that the GOC ensures patients’ vulnerabilities are also considered when revising the standards for optical businesses, as they have a greater role to play in supporting registrants to accommodate patients’ needs during the examination.

Q12. To what extent do you agree that the addition to the introduction on providing care for patients in vulnerable circumstances sets appropriate minimum expectations of registrants?

• Strongly agree 
• Somewhat agree  
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree

See our response to Q11.

Q13. To what extent do you agree that the revised standards are clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree

Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students: 

1. Standard 7.1 (6.1) 

See our response to Q11. We recommend adding the following sentences from the introductory text as a footnote to clarify what vulnerabilities are: 

“Patients may be vulnerable for a range of reasons, including physical or mental health conditions, capability in managing their health, or handling a difficult set of life events. Levels of vulnerability may vary between contexts, and change over time, so a patient's vulnerabilities should be considered as part of each consultation.” 

2.  Standard 13.8 (12.6), Standard 15.1 (14.1) and Standard 15.2 (14.2)

The wording “vulnerable circumstances” is unclear. There cannot be vulnerable circumstances, but certain circumstances can make a person vulnerable. 

We recommend amending Standard 13.8 (12.6) as below: 

“Consider and respond to the needs of patients with a disability or who may be considered vulnerable. Make reasonable adjustments to your practice to accommodate these and improve access to optical care.” 

We recommend amending Standard 15.1 (14.1) as below:

“Maintain appropriate boundaries with your patients, students, colleagues and others with whom you have a professional relationship and take special care when dealing with people who may be considered vulnerable. Maintaining appropriate boundaries applies to your behaviours, actions, and communications.”

We recommend amending Standard 15.2 (14.2) as below:

“Never abuse your professional position to exploit or unduly influence your patients or the public, whether politically, financially, sexually or by other means which serve your own interest. Take particular care when dealing with people who may be considered vulnerable.”

Q14. To what extent do you agree that the revised standards set appropriate minimum expectations of registrants?

• Strongly agree
• Somewhat agree
• Neither agree nor disagree
• Somewhat disagree
• Strongly disagree

See our response to Q11, Q12 and Q13.

Q15. To what extent do you agree that the revised standards are clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree

Standards of Practice for Optometrists and Dispensing Opticians: 

• Standard 2.5, Standard 3.1.4, Standard 6.4 (6.3).

Standards for Optical Students:

• Standard 5.3 

For all of the above standards, we support the GOC’s proposed revision but would suggest including a definition of “appliances” for clarity as the Optician Act refers to “optical appliances”.

Q16. To what extent do you agree that the revised standards set appropriate minimum expectations of registrants?

• Strongly agree
• Somewhat agree
• Neither agree nor disagree
• Somewhat disagree
• Strongly disagree

Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students: 

1.  Standard 2.2 

We support the proposed revision as it is aligned with the longstanding ‘Hello, my name is’ campaign, which has a strong track history of improving compassionate care delivery through the use of an introduction at the start of every clinical interaction.  

However, this revised standard has the potential to result in some unintended consequences. Service users may decline to be seen by a student or a non-registrant, making delegating some tasks more difficult and possibly creating tensions between service users and support staff. Staff on the front line are increasingly subject to verbal abuse from service users and this proposed revision may contribute to a further increase in verbal abuse for trainees and non-registrants. Employers and all practice staff need additional support and signposting to help manage and respond to any such abuse or discrimination.
 
2. Standard 7.6 (6.6) 

We recommend amending this standard as below: 

“Only provide or recommend examinations, treatments, drugs or appliances if these are clinically justified and in the best interests of the patient. Give patients information about all the options available to them, including choosing the option of no treatment or intervention, in a way they can understand.” 

As part of the consent process for any treatment, the clinician should provide service users with the option of choosing no treatment or intervention and provide sufficient information about the outcomes and material risk of no treatment or intervention to support a service user make an informed decision.

Supporting people to consider the “option of no treatment or intervention” implies maintaining an ongoing professional relationship between the service user and clinician working in partnership to deliver evidence-based patient centred care. Using the wording “declining” may imply a termination of this professional relationship.

Q17. To what extent do you agree that the revised standards are clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree 

See our response to Q18.

Q18. To what extent do you agree that the revised standards set appropriate minimum expectations of registrants? 

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree 

Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students: 

1.  New sub-standard under standard 7 (6) 

We recommend amending this sub-standard as below for clarification:

“Be aware of the limitations of digital technologies and apply your professional judgement when utilising data generated by digital technologies to inform decision-making.”

Q19. To what extent do you agree that the revised standards are clear? 

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree

Q20. To what extent do you agree that the revised standards set appropriate minimum expectations of registrants? 

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree 

Q21. To what extent do you agree that the addition to the business standard is clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree 

See our response to Q22.

Q22. To what extent do you agree that the addition to the business standards sets appropriate minimum expectations of business registrants?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree

Standard for Optical Business 

1.  New sub-standard under 3.3. 

While we welcome this new proposed standard requiring optical businesses to provide support for staff who have experienced discrimination, bullying and/or harassment in the workplace, we recommend that this standard requires optical businesses to have clear policies in place, and ensure that staff know what they are and where to find them. All staff should have clear information on how to raise a concern and/or make a complaint if needed as well as what’s expected of them in terms of their own behaviour.

Q23. To what extent do you agree the revised standards are clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree

Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students: 

1.  Standard 14.3 (13.2)

The proposed change to this standard may result in registrants believing it is acceptable to share medical information online and on social media without the patient’s explicit consent, even if the identifiable information has apparently been removed. This includes special category data, which is unique and could be processed to become biometric in future, such as retinal and iris images. As highlighted in a recently published review by Nakayama et al [1], retinal scans are considered personal data under GDPR because they can lead to either direct or indirect identification of an individual.  Although not currently possible, it is highly likely that in future an individual can be identified via a retinal scan as large datasets of retinal images linked to personal information become more available through the development of AI and other machine learning systems.  

Nakayama et al recommend that explicit patient consent is “a valid solution to data collection and secondary use for medical, scientific, and educational purposes”. In addition, they recommend data sharing, including retinal scans, should only be performed in a “trusted research environment where there are data use agreements and credentialing of researchers, including requirements of responsible data use training” to reduce the risk of data reidentification.

We believe the policy intention (as set out in paragraph 94 of the GOC consultation document) is that consent must be specific and valid when sharing patient data with others, but this is not clear.

The standard conflates the consent that a member of the public may give to registrants to provide direct patient care, or to share via agreed local pathways for advice and guidance or referral, with consent for clinicians to share medical images for various other reasons, including education, reflective practice, research or even curiosity (i.e. sharing an “interesting” case) on social media.

We agree that written consent is not required to obtain and share images for the purpose of providing clinical care, or in order to use the images for quality or governance purposes, such as clinical audit or when sharing images via NHS.net from one registered clinician to another.

However, as set out in our Guidance for Professional Practice and clinical file on sharing ophthalmic imaging on forums, we recommend registrants ensure they have gained written, informed and explicit patient consent before sharing anonymised images online, via social media or in a professional forum, be that for education, marketing, or to share for reflective practice, even if it is on a site for practitioners and is not accessible to the public. This would protect them from future claims of a breach of patient confidentiality where anonymised images could become identifiable due to their unique nature, or processed in a way that was not originally intended.

We recognise that online professional communities are an increasingly common and valuable way to participate in reflective practice and develop clinical decision-making skills. As people are increasingly using online forums, including WhatsApp groups that are not public, to communicate and share clinical matters, we have created a consent form template (PDF) that registrants can use in practice.

We recommend amending standard 14.3 (13.2) as below to set clearer expectations of registrants in this area by ensuring that an image can only be shared if it is both anonymised and specific, written and informed consent has been given:

“Maintain confidentiality when communicating publicly, including speaking to or writing in the media, when writing and sharing images online, including on social media. Ensure appropriate and explicit consent has been given before sharing images online or on social media.”

Standard 3.3 on consent refers especially to the examination or treatment when sharing patient data, whereas standard 14.3 (13.2) is much broader and not limited to this. This is why explicit consent should be sought and needs to be specifically mentioned in standard 14.3 (13.2), as acknowledged by the GOC in paragraph 94 of the consultation document.

Furthermore, image sharing on social media is governed by GDPR and the law on consent. 

References:

1. Luis Filipe Nakayama et al., Retinal Scans and Data Sharing: The Privacy and Scientific Development Equilibrium, Mayo Clinic Proceedings: Digital Health, Volume 1, Issue 2, 2023, Pages 67-74, ISSN 2949-7612,

Other useful sources:

• The College of Optometrists, Clinical files. March 2021: Case on sharing ophthalmic imaging on forums - College of Optometrists (college-optometrists.org)
• The College of Optometrists, Guidance for Professional Practice. Social media and online behaviour - College of Optometrists (college-optometrists.org)
• Dr Carol Chu, Medico-legal - Sharing medical images, GPonline, 6 December 2013.
• Information Commissioner’s Office (ICO), Biometrics: insight, 26 October 2022, Version 1.0
• ICO, Guidance on special category data, 9 April 2024. What is special category data? | ICO
• Segal, J.P., Hansen, R. Medical images, social media and consent. Nat Rev Gastroenterol Hepatol 18, 517–518 (2021)
• The Society and College of Radiographers, Guidance for the radiography workforce on the professional use of Social Media
• The Society of Radiographers (SoR), The dangers of using medical images on social media, 13 July 2020. The dangers of using medical images on social media | SoR
• Rahmani, G. (2023), Sharing images on social media without patient consent. J Med Imaging Radiat Oncol, 67: 653-655. https://doi.org/10.1111/1754-9485.13582
   

2.  Standard 16.6 (15.6) 

The College of Optometrists fully support this revised standard; however, we are of the opinion that this standard could be reinforced by adding a reference to the relevant Advertising Standards Authority (ASA) guidance in the new statement on legal requirements added to the introductory wording.

3. Standard 3.3 

The College of Optometrists recommends clarifying this standard as below: 

“Ensure that the patient's consent remains valid at each stage of the examination, treatment or subsequent use or processing of the patient’s data. For example, when sharing patient data with others for invasive procedures, post examination analysis and during any research in which they are participating.”

Q24. To what extent do you agree that the revised standards set appropriate minimum expectations of registrants?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree

See our response to Q23.

Q25. To what extent do you agree that the revised standards are clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree 

Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students:

1.  Standard 15.1 (14.1) 

We support this revised standard and recommend that the GOC develops further guidance on maintaining appropriate boundaries. As acknowledged by the GOC in paragraph 109 of the consultation document, some registrants are already in relationships with their colleagues or others with whom they have a professional relationship, which may make this standard more challenging to implement and scrutinise in some instances.

Q26. To what extent do you agree the revised standards set appropriate minimum expectations of registrants?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree
• Strongly disagree 

See our response to Q25.

Q27. To what extent do you agree with the inclusion of an additional standard that specifically addresses the issue of sexual harassment? 

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree 

We welcome the inclusion of this standard. All forms of sexual misconduct, including all forms of sexual harassment, are unacceptable. All forms of alleged harassment must be taken seriously, and complaints should be investigated and acted on swiftly, with a clear message that this behaviour will not be tolerated. 

The College of Optometrists has published various resources to support registrants who may be harassed by a patient or colleague, or who may be aware of sexual misconduct of a patient or colleague. These include:

• The College of Optometrists, Guidance for Professional Practice. Maintaining boundaries - College of Optometrists (college-optometrists.org)) 
• Abi Millar, Don’t put up with pests, 2022. Don't put up with pests - College of Optometrists (college-optometrists.org)
• The College of Optometrists, Clinical file on bullying and harassment in the workplace, August 2023. August 2023: Case on bullying and harassment in the workplace - College of Optometrists (college-optometrists.org) 
• The College of Optometrists, Podcast on dealing with bullying and harassment in the workplace, January 2024. Dealing with bullying and harassment in the workplace - College of Optometrists (college-optometrists.org)

In addition, as mentioned in our response to Q22, we recommend that optical businesses and practice owners have clear policies in place, and make sure that staff know what they are and where to find them. Practice owners and managers have an important role to play to create the right working environment and reinforce the message regarding what is and is not acceptable. Organisations must have a culture that promotes dignity and respect for all at work and takes a zero-tolerance approach against any form of inappropriate behaviour.

 Q28. To what extent do you agree that the additional standard is clear?

• Strongly agree
• Somewhat agree
• Neither agree nor disagree
• Somewhat disagree
• Strongly disagree

We recommend adding a statement in the introductory text of the Standards of Practice for Optometrists and Dispensing Opticians, and the Standards for Optical Students to set out the GOC’s interpretation of ‘acting in a sexual way’. The statement will make clear that all registrants are expected to maintain proper professional boundaries with patients, students and others.  ‘Acting in a sexual way’ can include – but is not limited to – verbal or written comments, displaying or sharing images, as well as unwelcome physical contact.

We recommend adding examples of unacceptable sexual behaviours as listed in the GMC Guidance on Maintaining personal and professional boundaries.

Q29. To what extent do you agree that the revised standards are clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree 

Q30. To what extent do you agree that the revised standards set appropriate minimum expectations of registrants? 

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree

Q31. To what extent do you agree with the inclusion of an additional standard that specifically addresses the issue of serious communicable diseases? 

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree 

See our response to Q32.

Q32. To what extent do you agree that the additional standard is clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree

While we acknowledge that the GOC has not defined ‘serious communicable disease’ as this could change in response to emerging public health diseases, the lack of any definition may leave some ambiguity for registrants.

We recommend using the term ‘high consequence infectious diseases’ as defined and set out by the UKHSA. 

The GMC guidance on Good medical practice uses the term ‘serious communicable diseases’ in relation to immunisation, and the term ‘serious condition that you can pass onto patients’ in terms of seeking independent professional advice about registrants’ ability to work. As such it is confusing for registrants that the GOC is using the term 'serious communicable diseases', with a different meaning and policy intention to how the GMC have used the very same term.

COVID and influenza are prevalent conditions which many registrants will be affected by each year, however none of these are listed by the UKHSA as a high consequence infectious disease. NB. COVID was removed from the list in 2023. 

In addition, we recommend updating the relevant Standards for Optical Businesses, as occupational health responsibilities of employers and services users sit with each individual member of staff and the organisation. An undue burden would be placed on individual registrants without a commensurate change to the Standards for Optical Businesses.

We recommend including supporting guidance, examples and case studies to help registrants understand this new standard and determine what may and may not be included in the ‘serious communicable disease’ category.

Q33. To what extent do you agree that the addition to the introduction on compliance with legislation is clear?

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree 

See our response to Q34.

Q34. To what extent do you agree that the addition to the introduction on compliance with legislation sets appropriate minimum expectations of registrants? 

• Strongly agree 
• Somewhat agree 
• Neither agree nor disagree 
• Somewhat disagree 
• Strongly disagree 

Standards of Practice for Optometrists and Dispensing Opticians and Standards for Optical Students: 

1. Addition to the introduction on legal requirement. 

While we understand the list of legal requirements is not exhaustive, we recommend adding to this list as a minimum the following examples of legal requirements that specifically applies to clinicians’ professional practice:  

• The Human Medicines Regulations 2012 
• Advertising Standards Authority codes of practice 

Health and Safety legal requirements are very important and affect all businesses and employees, whether they are registrants or not, while the two examples provided above specifically apply to clinicians and therefore may be more relevant.

Q35. Do you have any other comments about the proposed revisions or additions to the standards?

No further comment.