Dr James Woolley
FRCP FRCPsych

Consultant Psychiatrist

Specialist in Aviation Psychiatry

I am trained and recognised as an aviation psychiatrist, reviewing aviation professionals at the request of AMEs or the CAA as part of licence suitability assessments.

As an ex-pilot, I understand the regulatory requirements, time pressures and demands and produce reports and guidance for AMEs in a format suitable to assist the CAA (or regulators in other countries such as the FAA and EASA) as straightforwardly as possible in their decision-making.

I work with AMEs based at any of the UK Aeromedical centres, most directly with Centreline and reviews can be booked either online usually as a video-consultation.

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Reports are generally turned around in 7 days and if as a condition of licensing follow-up reviews are required, this can also be arranged.

I work within Aviation Mental Health Services to provide assessments, reports and consultation within the aviation sector.

Costs and appointments are on the appointments link. Bookings can be made online with immediate confirmation 24/7, and if plans change nearer the time, cancellations can be made online up to 48 hours before the booking.

Independently collected customer reviews on I Want Great Care:

Would listen to all issues, very understanding and was very easy to talk to.
…very professional and precise in addressing all the necessary points for my psychiatric report. It was a very relaxed one on one talk, and I felt understood and heard.
Very approachable Dr and very understanding. Got my aviation report sorted within a couple of days.

Not all licence applicants require a psychiatric assessment. Initial screening for mental health conditions will be done by your Aeromedical Examiner (AME) which includes aspects such as

  • appearance
  • speech
  • mood
  • thinking
  • perception
  • cognition
  • insight
  • signs of alcohol or drug misuse
If extra detail is required then you may be required to book a specialist psychiatric assessment which is where I can help.

It is your responsibility as the licence applicant to arrange and fund the assessment and your contract is with me to produce it. The report is then provided back to you to pass back to your AME (or I can send it directly back to them too with your consent).

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Class 1 & 2 medical certificate - pilots

In the UK, a Class 1 or Class 2 refers to the medical certification required for pilots.

1. Class 1 Pilot License: A Class 1 medical certificate is the highest level of medical certification for pilots. It is required for pilots involved in commercial air transport operations, including airline pilots. To obtain a Class 1 medical certificate, pilots undergo a comprehensive medical examination conducted by an approved Aeromedical Examiner (AME). The examination assesses various aspects of the pilot's health, including physical and mental fitness, vision, hearing, cardiovascular health, neurological function, and general medical condition. Class 1 medical certificates are valid for specific durations depending on the age of the pilot and may require periodic renewals.

2. Class 2 Pilot License: A Class 2 medical certificate is a lower level of medical certification compared to Class 1. It is required for pilots involved in non-commercial aviation activities, such as private pilots, recreational pilots, and student pilots. Similar to the Class 1 medical examination, the Class 2 medical examination is conducted by an approved AME and assesses the pilot's physical and mental fitness, vision, hearing, cardiovascular health, neurological function, and general medical condition. Class 2 medical certificates are also valid for specific durations and may require periodic renewals.

Both Class 1 and Class 2 medical certificates are important for ensuring the health and fitness of pilots to safely operate aircraft. The specific requirements and regulations regarding medical certification may vary depending on the country and aviation authority. Pilots need to comply with the medical certification requirements and maintain a valid medical certificate corresponding to the type of flying activities they are involved in.

It's important to note that aviation regulations and licensing structures may change over time, and it's advisable to consult the appropriate aviation authorities, such as the Civil Aviation Authority (CAA) in the UK, for the most up-to-date and accurate information regarding pilot licensing.

Mental Health Assessment Requirements:

A psychiatric assessment is not a standard part of a medical assessment. However, if there are any aspects of your current or past mental health about which your AME requires additional clarification, as part of the submission to the regulatory authority then they may require one.

It is then up to you to arrange an assessment, which is where we can help.

Sometimes it can be relatively straightforward - for example, assessing the impact of past episodes of treatment or counselling and whether there is any effect of this which would affect licensing at the moment. On other occasions, it may focus more on demonstrating resilience and effective coping strategies in the face of external stresses.

Or it can be more complex, for example, significant past episodes of mental illness, previous trauma or suspected conditions where your AME (and potentially the licensing authority) will require a more detailed assessment and formal report.

Often this is a one-off assessment and report as part of the initial licensing process or sometimes after a period of sickness as part of a return to work after some time being assessed as unfit. Occasionally the regulatory authority may require ongoing periodic mental health assessment and monitoring, which we can also provide.

Click here to book your online assessment and report

Class 3 medical certificate - ATCOs

In the UK, air traffic control staff are required to undergo medical assessments to obtain and maintain their medical certification. The medical licensing for air traffic control staff is conducted following the requirements set by the UK Civil Aviation Authority (CAA).

Anyone wishing to become an Air Traffic Control Officer (ATCO) will need to obtain a Class 3 medical certificate as part of the licensing requirements. The initial medical examination must be carried out at an Aeromedical Centre. The medical assessments for air traffic control staff aim to ensure that individuals are medically fit to perform their duties effectively and safely. These assessments typically include:

1. Initial Medical Examination: Before commencing employment as an air traffic control staff member, individuals are usually required to undergo an initial medical examination. This examination assesses their general health, vision, hearing, cardiovascular fitness, and overall medical fitness to perform the job.

2. Periodic Medical Assessments: After the initial examination, air traffic control staff are typically required to undergo periodic medical assessments at specified intervals. The frequency of these assessments may vary depending on factors such as age, role, and specific air traffic control environment. The purpose of these assessments is to monitor ongoing medical fitness and ensure that any changes in health conditions are appropriately managed.

The specific medical standards and requirements for air traffic control staff are detailed in the UK CAA publication CAP 1412, "Medical Requirements and Advice for Controllers." This document outlines the standards and guidance related to various medical conditions, medications, vision, hearing, and other relevant aspects of health for air traffic control personnel.

It's important to note that the medical licensing requirements may be subject to updates and changes. Therefore, individuals seeking accurate and up-to-date information should refer to the UK CAA and consult with the appropriate aviation medical examiner or authority regarding the specific medical licensing requirements for air traffic control staff in the UK.

Mental Health Assessment Requirements:

A psychiatric assessment is not a standard part of a medical assessment. However, if there are any aspects of your current or past mental health about which your AME requires additional clarification, as part of the submission to the regulatory authority then they may require one.

It is then up to you to arrange an assessment, which is where we can help.

Sometimes it can be relatively straightforward - for example, assessing the impact of past episodes of treatment or counselling and whether there is any effect of this which would affect licensing at the moment. On other occasions, it may focus more on demonstrating resilience and effective coping strategies in the face of external stresses.

Or it can be more complex, for example, significant past episodes of mental illness, previous trauma or suspected conditions where your AME (and potentially the licensing authority) will require a more detailed assessment and formal report.

Often this is a one-off assessment and report as part of the initial licensing process or sometimes after a period of sickness as part of a return to work after some time being assessed as unfit. Occasionally the regulatory authority may require ongoing periodic mental health assessment and monitoring, which we can also provide.

Click here to book your online assessment and report

Cabin crew

The UK Civil Aviation Authority (CAA) does not have specific regulations or requirements solely dedicated to mental health assessments for cabin crew. However, the CAA recognises the importance of mental well-being in the aviation industry and promotes a comprehensive approach to ensure the fitness for duty of cabin crew, which includes considerations related to mental health.

The CAA oversees aviation safety and regulation in the UK, and they set standards and guidelines for the medical certification of aviation personnel, including cabin crew. The medical certification requirements for cabin crew encompass various aspects of health, including physical, mental, and emotional well-being. While the CAA does not outline specific mental health assessment procedures, they require the medical examination and assessment of cabin crew to ensure their fitness for the role.

The CAA's medical certification standards for cabin crew are outlined in CAP 1471, "Aircrew Medical Certification and Reports." This document guides medical practitioners and outlines the general medical standards that must be met for individuals to obtain and maintain their medical certification as cabin crew. The medical assessment for cabin crew typically covers physical health, vision, hearing, cardiovascular fitness, respiratory function, and other relevant aspects.

While mental health is not explicitly mentioned as a separate component in the CAA's medical certification standards, it is considered part of the overall assessment of an individual's fitness for duty. Medical practitioners conducting the medical examinations for cabin crew are expected to inquire about and evaluate mental health conditions or concerns as part of the comprehensive assessment.

Mental Health Assessment Requirements:

A psychiatric assessment is not a standard part of a medical assessment. However, if there are any aspects of your current or past mental health about which your AME requires additional clarification, as part of the submission to the regulatory authority then they may require one.

It is then up to you to arrange an assessment, which is where we can help.

Sometimes it can be relatively straightforward - for example, assessing the impact of past episodes of treatment or counselling and whether there is any effect of this which would affect licensing at the moment. On other occasions, it may focus more on demonstrating resilience and effective coping strategies in the face of external stresses.

Or it can be more complex, for example, significant past episodes of mental illness, previous trauma or suspected conditions where your AME (and potentially the licensing authority) will require a more detailed assessment and formal report.

Often this is a one-off assessment and report as part of the initial licensing process or sometimes after a period of sickness as part of a return to work after some time being assessed as unfit. Occasionally the regulatory authority may require ongoing periodic mental health assessment and monitoring, which we can also provide.

Click here to book your online assessment and report

Aviation Mental Health Conditions & Regulations

Mental health conditions

Mental health conditions are common - including in pilots. Having a mental health condition is not necessarily an exclusion. Not declaring one can be!

To illustrate how common mental health conditions, are a comprehensive study by the Mental Health Foundation demonstrated that one in six (17%) of people over the age of 16 had a common mental health problem in the week before being interviewed.

Nearly half (43.4%) of adults think that they have had a diagnosable mental health condition at some point in their life (35.2% of men and 51.2% of women). A fifth of men (19.5%) and a third of women (33.7%) have had diagnoses confirmed by professionals.

A third of people (36.2%) who self-identified as having a mental health problem in the surveys have never been diagnosed by a professional

In 2014, 19.7% of people in the UK aged 16 and older showed symptoms of anxiety or depression

Ref: Mental Health Foundation 2016

Aircrew prevalences all appear to be reduced: is this a true rate at which training and selection screen them out? Or partially a consequence of non-declaration?

Guiding principles from the UK CAA are that

  • Declaration is key to mental health assessment
  • Trust is crucial for a safe flying environment
The graphs below give further detail about the prevalence of common mental health conditions, none of which in themselves cause a problem concerning licensing.

Disqualifying conditions

Disqualifying conditions

  • Schizophrenia / schizotypal / delusional disorder
  • Mania
  • Certain psychoactive medication
Substances (medication, recreational drugs, alcohol) pose the greatest risk to flight safety in terms of accidents (both general aviation and commercial air transport).

Relevant CAA regulation extracts

MED.B.055 Psychiatry

(a)Applicants shall have no established medical history or clinical diagnosis of any psychiatric disease or disability, condition or disorder, acute or chronic, congenital or acquired, which is likely to interfere with the safe exercise of the privileges of the applicable licence(s).

(f) Applicants with an established history or clinical diagnosis of schizophrenia, schizotypal or delusional disorder shall be assessed as unfit.

MED.B.060 Psychology

(a) Applicants shall have no established psychological deficiencies, which are likely to interfere with the safe exercise of the privileges of the applicable licence(s).

The bottom line is that I have worked with professionals in many sectors, where there can commonly be reluctance to deal with mental health issues. This is often founded on stigma or misunderstanding and can lead to the situation deteriorating. In aviation, the most problematic issue is non-disclosure of anything which may be potentially relevant, so it is always better to mention issues - even if in the past, or if you feel they are not relevant - rather than choose not to.

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Why?

Mental health assessments are crucial for pilots, air traffic control staff, and cabin crew for a variety of reasons

1. Safety and Performance: The mental well-being of aviation personnel directly impacts their ability to perform critical tasks and make sound decisions. Mental health issues, if left unaddressed, can impair cognitive function, attention, concentration, judgment, and reaction times, which are essential for maintaining safety in aviation operations. Regular assessments help identify any underlying mental health concerns that could affect job performance and safety.

2. Stress and Fatigue Management: Aviation professionals often face high levels of stress, irregular work schedules, and long hours, which can contribute to mental health challenges. Stress and fatigue can compromise decision-making abilities, situational awareness, and resilience. Mental health assessments provide an opportunity to identify and manage stressors, develop coping strategies, and promote well-being to mitigate the risk of burnout and potential errors.

3. Identification of Mental Health Conditions: Mental health conditions, such as anxiety, depression, substance abuse disorders, or other psychological issues, can have significant implications for aviation personnel. These conditions may impact cognitive functioning, emotional stability, and interpersonal interactions. Early detection through assessments allows for appropriate treatment and support, minimising the potential impact on job performance and safety.

4. Duty Fitness Determination: Mental health assessments play a role in evaluating an individual's overall fitness to perform their duties. Assessments can identify any conditions or circumstances that may impact an individual's ability to carry out their responsibilities safely and effectively. This ensures that individuals are in a suitable mental state to fulfil their roles and responsibilities in the aviation industry.

5. Regulatory Compliance: Aviation authorities and organisations have recognised the importance of mental health assessments and have incorporated them into regulatory frameworks. For example, the International Civil Aviation Organisation (ICAO) requires pilots to undergo periodic medical examinations that include mental health assessments. Compliance with these regulations helps maintain industry standards and promotes the overall safety of aviation operations.

6. Support and Treatment: Mental health assessments provide an opportunity for early intervention, support, and treatment when needed. Early identification of mental health concerns allows for appropriate referrals to mental health professionals who can provide the necessary support and treatment options. Timely intervention can improve outcomes, facilitate recovery, and enable individuals to return to their roles safely and confidently.

These assessments contribute to maintaining a mentally healthy workforce and enhancing the overall safety and well-being of aviation operations.

Related Incidents

1. Germanwings Flight 9525 (2015): The Germanwings Flight 9525 crash is one of the most well-known incidents related to crew mental health. The co-pilot deliberately crashed the aircraft into the French Alps, resulting in the deaths of all 150 people on board. It was later revealed that the co-pilot had a history of depression and had concealed his mental health issues from the airline.

2. Japan Airlines Flight 350 (1982): The crash of Japan Airlines Flight 350 highlighted the importance of psychological screening for pilots. The first officer, who had failed several flight training exams, intentionally caused the crash. Investigations revealed that the first officer had been suffering from mental health issues and had even previously attempted suicide.

3. SilkAir Flight 185 (1997): SilkAir Flight 185 crashed into the Musi River in Indonesia, killing all 104 passengers and crew members on board. The investigation suggested that the captain intentionally caused the crash, but his motive remains unclear. Subsequent analysis indicated that the captain had financial and personal problems, which could have affected his mental state.

4. JetBlue Airways Flight 191 (2012): This incident involved a JetBlue Airways captain who displayed erratic behaviour during the flight. The captain had a mental health episode, exhibiting signs of paranoia and delusion. He was eventually subdued by the passengers and crew members. The incident highlighted the need for protocols and support systems to identify and address mental health issues among crew members.

5. Emirates Flight 521 (2016): The crash landing of Emirates Flight 521 in Dubai was caused by the captain's failure to initiate a go-around despite multiple warnings from the first officer and the automated systems. The captain's decision-making abilities were compromised due to the psychological stress caused by personal and work-related issues. The incident emphasised the importance of mental well-being and stress management for pilots.

These incidents underline the critical need for robust mental health screening, support systems, and ongoing monitoring of crew members' well-being within the aviation industry to ensure the safety of passengers and crew alike.

As a trained aviation psychiatrist (and ex-pilot) I am able to provide informed mental health assessments for Aviation Medical Examiners, compliant with CAA/EASA/FAA procedures.

Appointments - book online

All appointment bookings are made online only through the booking form below - either for initial or follow-up appointments if required.

Payment is required at the point of booking to secure the assessment appointment.

To be fair to other clients and keep waiting times to a minimum, please note there is a 48-hour cancellation policy.

Preparation

Before your appointment

You may find it helpful to jot down some of the important details about your current and past situation. If it helps to write down a list of points, feel free - and sometimes sending them along beforehand is helpful too.

If you’re currently taking any medication, or have taken some in the past please have the details to hand, The details are important as some are OK with some regulators and some are not- detail is key.. Also take note of any other remedies such as alternative, homeopathic or over-the-counter medicines.

If there is a past history of mental or psychological diagnosis or treatment (for example with medication such as antidepressants from your GP, or counselling with a therapist) it will be very helpful to have precise details to hand. If you have had previous assessments or involvement with mental health teams or clinicians, then copies of any notes or letters will also assist our assessment and provide additional background and context to the licensing authorities should it be required.

Remember at all times that generally, non-disclosure of what may be a relevant past detail is typically viewed as more problematic to the authorities than being fully open and honest.

At the meeting

What's involved

An initial consultation usually takes about an hour. During this time I’ll ask you to describe past or current problems and the events around them which may have contributed.

I may also need to ask you about other contexts such as relationships, background and upbringing, some of which may have a bearing on your current circumstances.

Being medically qualified, I can make sense of diagnoses which may have been made in the past and assess how, if at all they may be relevant now, especially as regards eligibility for licence applications.

If you need follow-up appointments they usually last 30 minutes.

It’s not an intimidating process and is quite relaxed and informal.

I’ll send you a copy of the reports written usually within 7 days, for you to correct any points of fact and then the final report is sent to you (and your AME directly if you wish) to progress your application.

Contact

Please complete this form below to send an enquiry directly. You will usually hear back within 24 hours.

Please note that this form is for administrative and booking queries only. Contact details are never used for marketing or sold to third parties.

Urgent and/or clinical matters should not be sent from here.

Emergencies should be referred to your local GP on-call service or local hospital Accident and Emergency department. Details of your nearest unit can be found at www.nhs.uk

Fees & Legal Info

Fees

Appointment and other fees (updated May 2023)

Aviation Mental Health Services: Psychiatric assessment and report £550 (no VAT payable)
Fees are reviewed periodically so please make sure you’re aware of the latest update.
Fee payable at the time of making the online booking.

Additional medical reports

There’s a standard fee of £200 for the completion of additional medical reports requested by your employer, AME or other party. If a requested report requires extra time or other resources then I’ll check this with you or the organisation requesting the report before proceeding, and will invoice for the additional work accordingly.

Video and telephone consultations and written/email advice

Fees apply for all consultations, correspondence or advice via phone, email, and video and are charged at a similar rate to face-to-face consultations (at 10-minute intervals).

Cancellations or changes to appointments

To be fair to all my patients I operate a strict 48-hour notice policy for all cancellations and changes to appointments.

I recognise that flexibility is important and will try to accommodate requests to reschedule appointments wherever possible. However, costs are incurred when changes are made at short notice. So for appointments that are cancelled or postponed with less than two working days' notice, the full fee is charged.

If you need to cancel, this is done online from the link sent in your appointment confirmation email.

Timekeeping

Occasionally I’ll be delayed whilst in consultation with another patient and request your understanding in this matter. Your appointment will not be shortened as a consequence. However, if you leave before waiting for 30 minutes, the full fee for the appointment will be payable.

If you have any queries about fees, please do not hesitate to get in touch.

Terms

Thank you very much for choosing Aviation Mental Health Services for your psychiatric evaluation. We appreciate that this can be a stressful time so we have prepared the following notes which we hope will improve the understanding of the process.

All assessments are completed in good faith, and according to current best practice guidelines wherever possible and/or appropriate. However, the effectiveness of this is crucially dependent on you. You must reply honestly when asked for information and you must not withhold information even if you are not sure whether it may be relevant or not. If you have any queries please do not hesitate to discuss them with me during your appointment.

The medical will consist of a comprehensive mental health assessment as required by the competent authorities and governing bodies of Aviation to which you are applying.

This is the case even if you currently hold a valid medical with another authority. Details of all recorded your current and past medical history are required, even if another authority has it previously. If there are abnormal findings on your assessment, this may result in your being declared unfit, and your other medical/s being suspended pending further investigation.

Abnormal findings require further investigation. If, on a subsequent investigation, no abnormality is found, that is reassuring but does not necessarily invalidate the initial result.

Once all the information is received as part of our assessment it will be collated, reviewed, and a summary report made back to you and your AME. This can take up to 14 days depending on the complexity.

Our mental health report is to assist your AME who represents the authority and collects data and information on its behalf. They are obliged to pass on all relevant information from all communications with the applicant and of supporting staff.

It is with this understanding that all authorities require a signature on the medical application form (MED 160or equivalent), confirming that not only a full health declaration has been made, but also that all information may be shared.

If you provide us with any information at any time, it may be shared with the authority. If you feel the information is confidential, please let us know in advance. However, we may be obliged to share it with the authority if any risk to flight safety is perceived. If you state that information cannot be shared with the authority, we may not be able to issue a report and may still need to inform your AME about the withheld consent to share clinical information.

There may be additional fees charged such as for reviewing lengthy detailed medical records.
All complaints are shared with the relevant Aviation authority.

Disclaimer

Whilst every effort has been made to ensure the accuracy of the information on this site, the author and web hosting service cannot accept any responsibility for any loss and/or liability of any kind whatsoever incurred by the users or by any other person arising out of the use of the information available on this site.

Please note that any medical information contained within this site is not intended as a substitute for consultation with a professional physician. The content provided on this website is for information purposes only and is in no way intended as a substitute for diagnostic assessment or treatment. Links to other sites are included for information only and do not necessarily reflect the opinion or endorsement of the author.

About us

Dr James Woolley Ltd trading as Aviation Mental Health Services

Company number 08017921
Registered Office Address: 2 Upperton Gardens, Eastbourne, East Sussex, BN21 2AH

Registered with the Information Commissioners Office

Dr Woolley is licensed and revalidated by the General Medical Council, registration number 4303776. More details at www.drwoolley.info

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IT Security

Increasingly, medical records at hospitals and GP surgeries are held electronically.

The security of these records is critical and as a result, the electronic notes system I use has been carefully selected to be even more secure than traditional paper-based systems.

Records are hosted in state of the art datacentre facilities. Physical access is controlled both at the perimeter and at building ingress points by professional security staff utilising video surveillance, intrusion detection systems, and other electronic means.

The facility has achieved the following accreditations and certifications;

  • PCI DSS Level 1 (Payment Card Industry Data Security Standard)
  • ISO 27001 (Information Security Management System)
  • FIPS 140-2 (United States Federal Information Processing Standard).

It also participates in the Safe Harbour program assisting with meeting international privacy requirements, as required by the UK Information Commissioner's Office (ICO), and runs completely under HTTPS. This means your data is 256-bit encrypted end-to-end during transfer.

Identifiable data is never emailed or transferred to unencrypted external storage media.

Written consent is required if you want to communicate via email as you should be aware this is not confidential. If sent electronically, letters will be as encrypted PDF files and/or via secure messaging platforms such as Egress.

Video consultations using are via a secure connection (128-bit SSL), encrypted end-to-end.

I am fully registered with the UK Information Commissioner as a Data Controller, under the provisions of the Data Protection Act.

Privacy Notice

Executive summary

1. As your treating clinician and therefore custodian of personal information relating to your medical treatment, I must only use that information under all applicable law and guidance. This Privacy Notice provides you with a detailed overview of how I will manage your data from the point at which it is gathered and onwards, and how that complies with the law. I will use your personal information for a variety of purposes including, but not limited to, providing you with care and treatment, and sharing it with other medical professionals and research/clinical audit programmes.

2. In addition, you have several rights as a data subject. You can, for instance, seek access to your medical information, object to me using your information in particular ways, request rectification of any information which is inaccurate or deletion of information which is no longer required (subject to certain exceptions). This Privacy Notice also sets out your rights in respect of your personal information, and how to exercise them.

3. For ease of reference, this Notice is broken into separate sections below with headings which will help you to navigate through the document.

Click here for full detailed privacy notice

Introduction

1. This Privacy Notice sets out details of the information that I, as a clinician responsible for your treatment (and including my medical secretaries), may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully.

About me

2. In this Privacy Notice I use "I" or "mine" or "my" to refer to me as the clinician who is using your personal information.

3. If you have any queries, comments or concerns with respect to how I have used, or potentially will use, your personal information then you should contact me directly at contact@drwoolley.info and I would be happy to discuss further.

Your personal data

4. I am a Data Controller and Processor with respect to your personal information which I hold about you. This will mainly relate to your medical treatment but will be likely to also include other information such as financial data about billing. I must comply with the data protection legislation and relevant guidance when handling your personal information, and so must any medical secretary who assists me in an administrative capacity. Your personal data may include any images taken about your treatment which must not only be managed under the law, this Privacy Notice but also all applicable professional standards including guidance from the General Medical Council and British Medical Association.

5. I will provide your treatment from the private consulting rooms of an NHS Trust or an independent healthcare provider and, in due course, it may be necessary for these organisations to also process your personal data. I will do so following the law, and the principles of this Privacy Notice and to the extent that it is necessary to do so. This could be where these organisations need to arrange other healthcare services as part of your treatment, such as nursing, psychological therapy or inpatient care, or support other aspects of the treatment which I provide to you. In that case, the involved organisation will become a joint Data Controller concerning your personal information and will provide you with a copy of their Privacy Notice which sets out how they will manage that information.

6. Your personal information will be handled following the principles set out within this Privacy Notice. This means that whenever I use your personal data, I will only do so as set out in this Privacy Notice. From time to time, I may process your personal information at a non-hospital site (medical or non-medical), as may my medical secretary.

What personal information do I collect and use from patients?

7. I will use “special categories of personal information” (previously known as "sensitive personal data") about you, such as information relating to your physical and mental health.

8. If you provide personal information to me about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Notice. I will also process such information following this Privacy Notice.

9. In addition, you should note that in the event you amend data which I already hold about you (for instance by amending a pre-populated form) then I will update our systems to reflect the amendments. Our systems will continue to store historical data.

Personal information

10. As one of my patients, the personal information I hold about you may include the following:

a) Name
b) Contact details, such as postal address, email address and telephone number (including mobile number)
c) Financial information, such as credit card details used to pay us and insurance policy details
d) Occupation
e) Emergency contact details, including next of kin
f) Background referral details

Special Categories Personal Information

11. As one of my patients, I will hold information relating to your medical treatment which is known as a special category of personal data under the law, meaning that it must be handled even more sensitively. This may include the following:

a) Details of your current or former physical or mental health, including information about any healthcare you have received from other healthcare providers such as GPs, dentists or hospitals (private and/or NHS), which may include details of clinic and hospital visits, as well as medicines administered. I will provide further details below on how I handle such information.
b) Details of services you have received from me
c) Details of your nationality, race and/or ethnicity
d) Details of your religion
e) Details of any genetic data or biometric data relating to you
f) Data concerning your sex life and/or sexual orientation

12. The confidentiality of your medical information is important to me, and I make every effort to prevent unauthorised access to and use of information relating to your current or former physical and mental health (or indeed any of your personal information more generally). In doing so, I will comply with UK data protection law, including the Data Protection Act 2018, UK GDPR and all applicable medical confidentiality guidelines issued by professional bodies including, but not limited to, the General Medical Council.

How do I collect your information?

13. I may collect personal information from several different sources including, but not limited to:

a) GPs
b) Dentists
c) Other hospitals, both NHS and private
d) Mental health providers
e) Commissioners of healthcare services / insurance companies / employers
f) Other clinicians (including their medical secretaries)

Directly from you

14. Information may be collected directly from you when:

a) You enter into a contract with me or other healthcare organisations for the provision of healthcare services
b) You use those services
c) You complete enquiry forms on my or other healthcare organisation websites
d) You submit a query to me including by email or by social media
e) You correspond with me by letter, email, telephone or social media.

From other healthcare organisations

15. My patients will usually receive healthcare from other organisations, and so to provide you with the best treatment possible I may have to collect personal information about you from them. These may include:

a) Medical records from your GP
b) Medical records from other clinicians (including their medical secretaries)
c) Medical records from your dentist
d) Medical records from the NHS or any private healthcare organisation

16. Medical records include information about your diagnosis, clinic and hospital visits and medicines administered.
From third parties

17. As detailed in the previous section, it is often necessary to seek information from other healthcare organisations. I may also collect information about you from third parties when:

a) You are referred to me for the provision of services including healthcare services
b) I liaise with your current or former employer, health professional or other treatment or benefit provider
c) I liaise with your family
d) I liaise with your insurance policy provider
e) I deal with experts (including medical experts) and other service providers about services you have received or are receiving from me
f) I deal with NHS health service bodies about services you have received or are receiving from us
g) I liaise with credit reference agencies
h) I liaise with debt collection agencies
i) I liaise with Government agencies, including the Ministry of Defence, or the Home Office.
How will I communicate with you?
18. I may communicate with you in a range of ways, including by telephone, SMS, email, and / or post. If I contact you using the telephone number(s) that you have provided (landline and/or mobile), and you are not available which results in the call being directed to a voicemail and/or answering service, I may leave a voice message on your voicemail and/or answering service as appropriate, and including only sufficient basic details to enable you to identify who the call is from, very limited detail as to the reason for the call and how to call me back.

19. However:
a) to ensure that I provide you with timely updates and reminders concerning your healthcare (including basic administration information and appointment information (including reminders)), I may communicate with you by SMS and/or unencrypted email (where you have provided me with your SMS or email address)

b) to provide you with your medical information (including test results and other clinical updates) and/or invoicing information, I may communicate with you by email (which will be encrypted) where you have provided me with your email address.


20. Please note that although providing your mobile number and email address and stating a preference to be communicated by a particular method will be taken as an affirmative confirmation that you are happy for us to contact you in that manner, I am not relying on your consent to process your personal data to correspond with you about your treatment. As set out further below, processing your personal data for those purposes is justified on the basis that it is necessary to provide you with healthcare service.

What are the purposes for which your information is used?

21. I may 'process' your information for several different purposes, which is essentially the language used by the law to mean using your data. Each time I use your data I must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data. When the information that we process is classed as a “special category of personal information”, I must have a specific additional legal justification to use it as proposed.

22. Generally I will rely on the following legal justifications, or 'grounds':
a) Taking steps at your request so that you can enter into a contract with me to receive healthcare services from us.
b) To provide you with healthcare according to a contract between you and I. I will rely on this for activities such as supporting your medical treatment or care and other benefits, supporting your nurse, carer or other healthcare professional and providing other services to you.
c) I have an appropriate business need to process your personal information and such business need does not cause harm to you. I will rely on this for activities such as quality assurance, maintaining my business records, monitoring outcomes and responding to any complaints.
d) I have a legal or regulatory obligation to use such personal information.
e) I need to use such personal information to establish, exercise or defend my legal rights.
f) You have provided your consent to my use of your personal information.
23. Note that failure to provide your information further to a contractual requirement with me may mean that I am unable to set you up as a patient or facilitate the provision of your healthcare.

24. I provide further detail on these grounds in the sections below.


Appropriate business needs

25. One legal ground for processing personal data is where I do so in pursuit of legitimate interests and those interests are not overridden by your privacy rights. Where I refer to use for my appropriate business needs, I am are relying on this legal ground.

The right to object to other uses of your personal data

26. You have a range of rights in respect of your personal data, as set out in detail in sections 72-90. This includes the right to object to me using your personal information in a particular way (such as sharing that information with third parties), and I must stop using it in that way unless specific exceptions apply. This includes, for example, if it is necessary to defend a legal claim brought against me, or it is otherwise necessary for the purposes of your ongoing treatment or overriding clinical risk to yourself or other.

You will find details of my legal grounds for each of our processing purposes below. I have set out individually those purposes for which I will use your personal information, and under each one I set out the legal justifications, or grounds, which allow me to do so. You will note that I have set out a legal ground, as well as an 'additional' legal ground for special categories of personal information. This is because I have to demonstrate additional legal grounds where using information which relates to a person's healthcare, as I will be the majority of the times I use your personal information.

Purpose 1: To set you up as my patient, including carrying out fraud, credit, anti-money laundering and other regulatory checks

27. As is common with most business, I have to carry out necessary checks in order for you to become a patient. These include standard background checks, which I cannot perform without using your personal information.

28. Legal ground: Taking the necessary steps so that you can enter into a contract with me for the delivery of healthcare.

29. Additional legal ground for special categories of personal information: The use is necessary for reasons of substantial public interest, and it is also in my legitimate interests to do so.

Purpose 2: To provide you with healthcare and related services

30. Clearly, the reason you come to me is to provide you with healthcare, and so I have to use your personal information for that purpose.

31. Legal grounds:
a) Providing you with healthcare and related services
b) Fulfilling my contract with you for the delivery of healthcare

32. Additional legal grounds for special categories of personal information:
a) I need to use the data in order to provide healthcare services to you
b) The use is necessary to protect your vital interests where you are physically or legally incapable of giving consent

Purpose 3: For account settlement purposes

33. I will use your personal information in order to ensure that your account and billing is fully accurate and up-to-date

34. Legal grounds:
a) My providing you healthcare and other related services
b) Fulfilling my contract with you for the delivery of healthcare
c) My having an appropriate business need to use your information which does not overly prejudice you
d) Your consent

35. Additional legal grounds for special categories of personal information:
a) I need to use the data in order to provide healthcare services to you
b) The use is necessary in order for me to establish, exercise or defend my legal rights
c) Your consent


Purpose 4: For medical audit/research purposes

Clinical audit

36. I may process your personal data for the purposes of local clinical audit – i.e. an audit carried out by myself or my direct team for the purposes of assessing outcomes for patients and identifying improvements which could be made for the future. I am able to do so on the basis of my legitimate interest and the public interest in statistical and scientific research, and with appropriate safeguards in place. You are, however, entitled to object to my using your personal data for this purpose, and as a result of which I would need to stop doing so. If you would like to raise such an objection then please contact me using the details provided in paragraph 3 above.

37. I may also be asked to share information with your healthcare insurers and U.K. registries for which ethical approval is not necessarily required but which form part of the National Clinical Audit programme, hosted by NHS England and who provide a list of National Clinical Audit and Clinical Outcome Review programmes and other quality improvement programmes which we should prioritise for participation. I may do so without your consent provided that the particular audit registry has received statutory approval, or where the information will be provided in a purely anonymous form, otherwise your consent will be needed and either I will seek this from you or the registry themselves will do so.

Medical research

38. I may also be asked to participate in medical research and share data with ethically approved third party research organisations.

39. I will share your personal data only to the extent that it is necessary to do so in assisting research and as permitted by law. Some research projects will have received statutory approval such that consent may not be required in order to use your personal data. In those circumstances, your personal will be shared on the basis that:

Legal grounds:
a) I have a legitimate interest in helping with medical research and have put appropriate safeguards in place to protect your privacy

Additional legal grounds for special categories of personal information:
b) The processing is necessary in the public interest for statistical and scientific research purposes

40. In the event that consent is required then either I will seek this from you, or the research agency will do so.

Purpose 5: Communicating with you and resolving any queries or complaints that you might have.

41. From time to time, patients may raise queries, or even complaints, with me and healthcare providers I work from and I take those communications very seriously. It is important that I am able to resolve such matters fully and properly and so I, as well as other involved healthcare providers will need to use your personal information in order to do so.

42. Legal grounds:
a) Providing you with healthcare and other related services
b) Having an appropriate business need to use your information which does not overly prejudice you

43. Additional legal grounds for special categories of personal information:
a) The use is necessary for the provision of healthcare or treatment pursuant to a contract with a health professional
b) The use is necessary in order for me to establish, exercise or defend my legal rights

Purpose 6: Communicating with any other individual that you ask us to update about your care and updating other healthcare professionals about your care.

44. In addition, other healthcare professionals or organisations may need to know about your treatment in order for them to provide you with safe and effective care, and so I may need to share your personal information with them. Further details on the third parties who may need access to your information is set out at section 58 below.

45. Legal grounds:
a) Providing you with healthcare and other related services
b) I have a legitimate interest in ensuring that other healthcare professionals who are routinely involved in your care have a full picture of your treatment

46. Additional legal ground for special categories of personal information:
a) I need to use the data in order to provide healthcare services to you
b) The use is necessary for reasons of substantial public interest under UK law
c) The use is necessary in order for me to establish, exercise or defend my legal rights

47. I also participate in initiatives to monitor safety and quality, helping to ensure that patients are getting the best possible outcomes from their treatment and care. The Competition and Markets Authority Private Healthcare Market Investigation Order 2014 established the Private Healthcare Information Network (“PHIN”), as an organisation who will monitor outcomes of patients who receive private treatment. Under Article 21 of that Order, some specialities (though not mental health yet) are required to provide PHIN with information related to your treatment, including your NHS Number in England and Wales, CHI Number in Scotland or Health and Care Number in Northern Ireland), the nature of your procedure, whether there were any complications such as infection or the need for readmission/admission to a NHS facility and also the feedback you provided as part of any PROMs surveys. PHIN will use your information in order to share it with the NHS, and track whether you have received any follow-up treatment. I will only share this information with PHIN if you have provided your consent for me to do so, if at a future point treatment for mental health also becomes part of PHIN’s scope.

48. The records that I share may contain personal and medical information about patients, including you. PHIN, like me, will apply the highest standards of confidentiality to personal information in accordance with data protection laws and the duty of confidentiality. Any information that is published by PHIN will always be in anonymised statistical form and will not be shared or analysed for any purpose other than those stated. Further information about how PHIN uses information, including its Privacy Notice, is available at www.phin.org.uk.

Purpose 7: Complying with our legal or regulatory obligations, and defending or exercising our legal rights
49. As a provider of healthcare, I am subject to a wide range of legal and regulatory responsibilities which is not possible to list fully here. I may be required by law or by regulators to provide personal information, and in which case I will have a legal responsibility to do so. From time to time, clinicians are unfortunately also the subject of legal actions or complaints. In order to fully investigate and respond to those actions, it is necessary to access your personal information (although only to the extent that it is necessary and relevant to the subject-matter).

50. Legal grounds:
a) The use is necessary in order for us to comply with our legal obligations

51. Additional legal ground for special categories of personal information:
a) I need to use the data in order for others to provide informed healthcare services to you
b) The use is necessary for reasons of the provision of health or social care or treatment or the management of health or social care systems
c) The use is necessary for establishing, exercising or defending legal claims

52. I am also required by law to conduct audits of health records, including medical information, for quality assurance purposes. Your personal and medical information will be treated in accordance with guidance issued by the Care Quality Commission (England), Health Inspectorate Wales and Healthcare Improvement Scotland

Purpose 8: Managing my business operations such as maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice (e.g. tax or legal advice)

53. In order to do this, I will not need to use your special categories of personal information and so I have not identified the additional ground to use your information for this purpose.

54. Legal grounds:
a) My having an appropriate business need to use your information which does not overly prejudice you

Purpose 9: Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.

55. As a provider of private healthcare services, I need to carry out marketing but am mindful of your rights and expectations in that regard. As a result, I will only provide you with marketing which is relevant to my business and only where you have specifically confirmed your consent to do so.

56. Legal grounds:
a) My having an appropriate business need to use your information which does not overly prejudice you
b) You have provided your consent

Disclosures to third parties:

57. I may disclose your information to the third parties listed below for the purposes described in this Privacy Notice. This might include:

a) A doctor, nurse, carer or any other healthcare professional involved in your treatment
b) Other members of support staff involved in the delivery of your care, like receptionists and porters
c) Anyone that you ask me to communicate with or provide as an emergency contact, for example your next of kin or carer
d) NHS organisations, including NHS Resolution, NHS England, Department of Health
e) Other private sector healthcare providers
f) Your GP
g) Your dentist
h) Other clinicians (including their medical secretaries)
i) Third parties who assist in the administration of your healthcare, such as insurance companies
j) Private Healthcare Information Network
k) National and other professional research/audit programmes and registries, as detailed under purpose 4 above
l) Government bodies, including the Ministry of Defence, the Home Office and HMRC
m) Our regulators, like the Care Quality Commission, Health Inspectorate Wales and Healthcare Improvement Scotland
n) The police and other third parties where reasonably necessary for the prevention or detection of crime
o) Our insurers
p) Debt collection agencies
q) Credit referencing agencies
r) Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers
s) Selected third parties in connection with any sale, transfer or disposal of our business
t) I may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for me to do so.

58. I may communicate with these third parties in a variety of ways including, but not limited to, email, post, fax and telephone.

What marketing activities do I carry out?

59. I may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for me to do so.

60. If you no longer wish to receive marketing emails, you can click on the "unsubscribe" link that appears in all of my emails, otherwise you can always contact me using the details set out in section 3 to update your contact preferences.

61. If you no longer wish to receive non-website based marketing information, please contact me.


How long do I keep personal information for?

62. I will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with my legal and regulatory obligations.

63. I aim to comply with NHS national standards “Records Management Code of Practice for Health and Social Care 2016” found at https://digital.nhs.uk/data-and-information/looking-after-information/data-security-and-information-governance/codes-of-practice-for-handling-information-in-health-and-care

64. For the purposes of mental health records this stipulates that from the point of discharge or last appointment, records are retained for 20 years or 8 years after the death of a patient. These are minimum standards and in some cases may be extended. This particularly applies where the person has been cared for under the Mental Health Act 1983 as amended by the Mental Health Act 2007. Retention solely for any patients who have been sectioned under the Mental Health Act 1983 may be considerably longer than 20 years where the case may be ongoing. Milder forms of adult mental health treated in a community setting where a full recovery is made may be treated as standard adult records and kept for 8 years after discharge. All are be reviewed prior to destruction, taking into account any additional serious incident, legal or other advisory retention requirements.

65. If you would like further information regarding the periods for which your personal information will be stored, please contact me using the details outlined in section 3.

International data transfers

66. I may store or process information collected about you in countries outside the European Economic Area ("EEA") on my clinical notes system (www.cliniko.com). Where I make a transfer of your personal information outside of the EEA I will take the required steps to ensure that your personal information is protected.

67. In using this records, scheduling and invoicing system I have separately entered into a Data Protection Addendum (DPA) with Cliniko. This is an additional agreement which means that although Cliniko and its subprocessors aren't physically in the EU/EEA, they are approved as offering sufficient safeguards and protection for data that's processed outside of the EU/EEA.

68. Specific security measures include:

- Databases are hosted in state of the art datacentre facilities
- Physical access is controlled both at the perimeter and at building ingress points by professional security staff utilising video surveillance, intrusion detection systems, and other electronic means.
- The facility has achieved the following accreditations and certifications;
o PCI DSS Level 1 (Payment Card Industry Data Security Standard)
o ISO 27001 (Information Security Management System)
o FIPS 140-2 (United States Federal Information Processing Standard)
o Participates in the Safe Harbour program assisting with meeting EU and UK privacy requirements, as required by the UK Information Commissioner's Office (ICO)
o Runs completely under HTTPS. This means your data is 256-bit encrypted end-to-end during transfer.

69. If you would like further information regarding the steps I take to safeguard your personal information, please contact me using the details provided in section 3 above.

70. Please note that we have listed above the current common transfers of personal data outside of the EEA but it may be necessary, in future, to transfer such data for other purposes. In the event that it is necessary to do so, we will update this Privacy Notice.

Your rights

71. Under data protection law you have certain rights in relation to the personal information that I hold about you. These include rights to know what information I hold about you and how it is used. You may exercise these rights at any time by contacting me using the details provided at section 3 above.

72. There will not usually be a charge for handling a request to exercise your rights.

73. If I cannot comply with your request to exercise your rights we will usually tell you why.

74. There are some special rules about how these rights apply to health information as set out in legislation including the Data Protection Act (current and future), the General Data Protection Regulation as well as any secondary legislation which regulates the use of personal information.

75. If you make a large number of requests or it is clear that it is not reasonable for me to comply with a request then we do not have to respond. Alternatively, I can charge for responding.

Your rights include:

The right to access your personal information

76. You are usually entitled to a copy of the personal information I hold about you and details about how I use it.

77. Your information will usually be provided to you in writing, unless otherwise requested. If you have made the request electronically (e.g. by email) the information will be provided to you by electronic means where possible.

78. Please note that in some cases I may not be able to fully comply with your request, for example if your request involves the personal data of another person and it would not be fair to that person to provide it to you.

79. You are entitled to the following under data protection law.
1. Under Article 15(1) of the GDPR I must usually confirm whether I have personal information about you. If I do hold personal information about you I usually need to explain to you:
i. The purposes for which I use your personal information
ii. The types of personal information I hold about you
iii. Who your personal information has been or will be shared with, including in particular organisations based outside the EEA.
iv. If your personal information leaves the EU, how I will make sure that it is protected
v. Where possible, the length of time I expect to hold your personal information. If that is not possible, the criteria I use to determine how long I hold your information for
vi. If the personal data I hold about you was not provided by you, details of the source of the information
vii. Whether I make any decisions about you solely by computer and if so details of how those decision are made and the impact they may have on you
viii. Your right to ask me to amend or delete your personal information
ix. Your right to ask me to restrict how your personal information is used or to object to my use of your personal information
x. Your right to complain to the Information Commissioner's Office

2. I also need to provide you with a copy of your personal data, provided specific exceptions and exemptions do not apply.

The right to rectification

80. I take reasonable steps to ensure that the information I hold about you is accurate and complete. However, if you do not believe this is the case, you can ask me to update or amend it.

The right to erasure (also known as the right to be forgotten)

81. I may update this Privacy Notice from time to time to ensure that it remains accurate, and the most up-to-date version can be found at www.drwoolley.info/privacynotice.html. In the event that there are any material changes to the manner in which your personal information is to be used then I will provide you with an updated copy of this Privacy Notice.

82. In some circumstances, you have the right to request that I delete the personal information I hold about you. However, there are exceptions to this right and in certain circumstances I can refuse to delete the information in question. In particular, for example, I do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercising or defending legal claims.

The right to restriction of processing

83. In some circumstances, I must "pause" our use of your personal data if you ask me to do so, although I do not have to comply with all requests to restrict my use of your personal information. In particular, for example, I do not have to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercise or defending legal claims.

The right to data portability

84. In some circumstances, I must transfer personal information that you have provided to you or (if this is technically feasible) another individual/ organisation of your choice. The information must be transferred in an electronic format.

The right to object to marketing

85. You can ask me to stop sending you marketing messages at any time and I must comply with your request. You can do this by contacting me using the details provided at section 3 above.

The right to withdraw consent

86. In some cases I may need your consent in order for my use of your personal information to comply with data protection legislation. Where we do this, you have the right to withdraw your consent to further use of your personal information. You can do this by contacting me using the details provided at section 3 above.

The right to complain to the Information Commissioner's Office

87. You can complain to the Information Commissioner's Office if you are unhappy with the way that I have dealt with a request from you to exercise any of these rights, or if you think I have not complied with our legal obligations.

88. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/

89. Making a complaint will not affect any other legal rights or remedies that you have.

Updates to this Privacy Notice

90. I may update this Privacy Notice from time to time to ensure that it remains accurate. In the event that these changes result in any material difference to the manner in which I process your personal data then I will provide you with an updated copy of the Policy.

91. This Privacy Notice was last updated on 6th February 2023

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