Dental Protection believes that overall, it is helpful to include health, performance or conduct concerns into this document, and that this section is broadly clear.  We are pleased to see inclusion of reference to indemnifiers.

However, it may be helpful to include examples of what a conduct or performance issue entails. In part 1.2 we are pleased to see suggestions of local resolution, but more detailed inclusion of what warrants reporting to the GDC may be helpful to diminish the likelihood of malicious reporting between colleagues with a poor relationship. In particular, ‘reducing trust in the profession’ could be expanded on, including with examples, in order to better triage issues before they are reported to the GDC than requiring time and human resource to investigate.

Furthermore, registrants are advised that ‘If patients may be at risk because you have a health condition that could impact on your practice, you must take action to address this’, and there may be benefit in clarifying that the GDC is referring to unmanaged health issues that are putting patients at risk or that it could reduce trust in the profession, and not those who have pre-existing and well-managed conditions. While a registrant would doubtless not need reminding that their pre-existing conditions need reporting, there could be benefit in clarifying this for the same reasons regarding malicious complaints above.

Dental Protection believes that the proposed changes are beneficial and provide clear direction. The previous guidance was only one page long and was not as detailed as the proposed guidance. In particular, we believe registrants will find it useful to have the additional guidance on reporting past charges and convictions (page 3).

We are pleased to see the suggestion that “If you need advice as to whether you should declare you should contact your indemnifier, or the GDC at https://www.gdc-uk.org/contact-us” because of the significance of making a disclosure. In light of this significance, we would suggest that this line is changed to ‘…or, if you are unrepresented, the GDC at…” to ensure that a registrant prioritises contacting their indemnifier for independent advice. We are unsure how a registrant – in a straightforward or meaningful way – could get on advice on whether to disclose without inadvertently disclosing the information.

Dental Protection has not identified any ways in which the proposals would have an  impact on those with protected characteristics.

In our response to question 5 we have already suggested including further details on what warrants a health complaint in the first instance, but we wish to also note that those with health concerns that require reporting may also have disabilities that interact with a new health issue. How a health complaint is dealt with for those with existing medical conditions that fall under equalities legislation go beyond this document.

​Separately, given the importance of this document for dental professionals (and ultimately for patients) we think that there could be benefit in creating accessible versions of the Guidance for those with disabilities or learning difficulties related to reading or information processing e.g., dyslexia. Anecdotally, we are aware that some dentists and DCPs may benefit from the additional support in this regard and believe that the regulator taking such steps would not only be encouraging for such members of the dental team but could also increase adherence to the Guidance. While we are not best placed to advise on such additional formats, there could be a supplementary audio version and versions in a different font and text not on a white background.​