PCN Policies and Procedures

How we use cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work more efficiently, and sometimes provide useful information to the owners of the site.

There are some cookies necessary to this site functioning, such as interacting with our accessibility toolbar. These cookies will usually remove themselves when you close your browsing session. More information can be found in the ‘Necessary cookies’ section.

We use some additional cookies, such as Google Analytics, to help us gather information and improve the website. You have the option to deny use of these cookies; more information can be found in the ‘Additional cookies’ section.

In order to help us to improve the content, format and structure of this website we record and analyse how visitors use the using Google Analytics.

You can read Google’s extensive information on data practices in Google Analytics.

You can opt-out of Google Analytics on our website by denying additional cookies or by using the Google Analytics Opt-out Browser Add-on.

The following necessary cookies allow the functions within our accessibility toolbar to work optimally.

Zero Tolerance Policy on Abuse and Aggressive Behaviour 

Apex PCN is committed to providing a safe, respectful, and inclusive environment for all patients, visitors, and staff. In line with NHS England guidance and UK law, we operate a Zero Tolerance Policy towards any form of abuse, aggression, or violence. 

We have a legal and moral duty to protect the health, safety, and wellbeing of our staff. Any behaviour that causes distress, intimidation, or harm—whether verbal, physical, or written—will not be tolerated. 

Unacceptable behaviour includes (but is not limited to): 

• Verbal abuse or threats 

• Physical aggression 

• Harassment or intimidation 

• Discriminatory or offensive language 

Anyone engaging in such behaviour will receive a formal warning from the PCN Manager. Repeated or serious incidents may result in removal from the practice list and, where appropriate, referral to the police. 

This policy is supported by the NHS Violence Prevention and Reduction Standard and the Assaults on Emergency Workers (Offences) Act 2018. 

We thank you for helping us maintain a safe and respectful healthcare environment. 

Why LGBTQIA+? 

While “LGBT” is widely recognized, it does not fully represent the diversity of identities within the community. We use LGBTQIA+ to promote active inclusion of all sexual orientations, gender identities, and expressions. Other inclusive terms include: 

• MOGAI (Minority Orientations, Gender Alignments, and Intersex) 

• QUILTBAG (an acronym used within the community) 

Legal and NHS Context (2025) 

• The Equality Act 2010 remains the cornerstone of anti-discrimination law in the UK, protecting individuals from discrimination based on sexual orientation and gender reassignment. 

• In April 2025, the UK Supreme Court issued a new interpretation of the definition of “sex” under the Equality Act, which may affect how single-sex spaces and services are managed Leading for all: supporting trans and non-binary healthcare staff | NHS Confederation 

• The NHS England LGBT+ Action Plan prioritizes reducing health inequalities, improving inclusive data collection, and training healthcare professionals to better support LGBTQIA+ patients  NHS England » LGBT+ action plan priorities 

• NHS organisations are encouraged to implement inclusive policies, support trans and non-binary staff, and ensure safe, respectful environments for all  

Key Terms and Identities 

Queer 

An umbrella term for people who do not conform to traditional gender or sexuality norms. Note: Due to its historical use as a slur, only use this term for someone if they self-identify with it. 

Questioning 

Someone exploring or unsure about their gender identity and/or sexual orientation. This is a valid identity and not “just a phase.” 

Gay 

Typically refers to someone attracted to people of the same gender. While often used for men, it can apply to anyone. 

Lesbian 

A woman who is exclusively attracted to other women. Lesbians may face lesbophobia, a mix of homophobia, misogyny, and sexism. 

Bisexual 

Attracted to more than one gender. Not limited to “men and women” — many define it as attraction to “same and other genders.” 

Pansexual 

Attracted to people regardless of gender. There is overlap with bisexuality, and some people identify as both. 

Asexual 

Experiences little or no sexual attraction. May still have romantic attractions (e.g., biromantic, panromantic) or identify as aromantic (no romantic attraction). 

Intersex 

Born with physical or genetic traits that don’t fit typical definitions of male or female. Intersex traits may be visible at birth, during puberty, or not at all. 

Transgender 

A person whose gender identity differs from the sex assigned at birth. The term transsexual is now considered outdated. 

• Trans = across from 

• Cisgender = identifies with assigned gender at birth 

Non-Binary 

A gender identity outside the male/female binary. Can be an umbrella term or a specific identity. 

Examples of non-binary identities: 

• Agender – no gender 

• Genderqueer – outside gender norms 

• Demiboy/Demigirl – partially male/female 

• Bigender – two genders 

• Genderfluid – shifts between genders 

• Pangender – identifies with all genders 

Pronouns: Non-binary people may use “they,” “xe,” “ze,” “co,” or others. Always ask and respect their choice. 

Commitment to Inclusion 

We are committed to: 

• Upholding the Equality Act 2010 and NHS inclusion standards 

• Providing safe, respectful, and affirming care 

• Supporting staff and patients of all identities 

• Promoting education and awareness to reduce stigma and discrimination 

For more information, visit: 

• NHS England LGBT+ Action Plan 

• NHS Confederation Guide on Trans and Non-Binary Inclusion 

Effective Date: 11 June 2025 

At Apex Primary Care Network (PCN), we are committed to protecting your personal information and being transparent about how we handle it. This Privacy Policy outlines how we collect, use, store, and share your data when you interact with our website and services, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. 

1. Who We Are 

Apex PCN is a collaboration of GP practices working together to deliver better health outcomes for patients in our local area. Our website is: https://www.ApexPCN.co.uk 

2. What Information We Collect 

We may collect and process the following data: 

Contact details (e.g. name, email address, phone number) when you submit a contact form or feedback 

Technical data such as your IP address, browser type, and browsing behaviour via cookies 

Correspondence when you contact us via email or online forms 

Job application data, if you submit interest via recruitment forms or NHS Jobs links 

3. How We Use Your Information 

We use your data for the following purposes: 

To respond to queries or feedback submitted through our website 

To improve website performance and user experience 

To support staff recruitment and engagement processes 

To meet legal obligations as part of NHS data governance 

4. Legal Basis for Processing 

We process personal data under the following legal bases: 

Consent – when you give us permission via forms 

Legal obligation – when we’re required to retain data under NHS rules 

Legitimate interests – to help manage and improve our services 

5. Cookies and Analytics 

Our website uses cookies to enhance user experience. You can choose to accept or decline cookies when visiting our site. 

We may use: 

Google Analytics (to monitor traffic) 

NHS-assured tools for website performance 

Session cookies (to improve accessibility) 

🔗Read our Cookie Policy here (replace with actual link- I am sure Frank can provide you with one as appear the cookie thing straight when you go into website) 

6. Sharing Your Data 

We do not sell your personal data. We only share it: 

With relevant NHS organisations (e.g. practices, CCG/ICB partners) 

With trusted third-party processors under strict agreements 

When required by law (e.g. for safeguarding or regulatory reporting) 

7. How We Store and Protect Your Data 

All personal data is: 

Stored on secure NHS-compliant systems 

Accessed only by authorised staff 

Retained only as long as necessary, per NHS retention schedules 

8. Your Data Protection Rights 

Under UK GDPR, you have the right to: 

Access the data we hold about you 

Request correction or deletion of your data 

Object to certain types of processing 

Withdraw consent at any time 

Lodge a complaint with the Information Commissioner's Office (ICO) 

You can go directly to their complaint page here: Make a complaint | ICO 

Or call them: 0303 123 1113 (Monday to Friday, 9am–5pm) 

9. Contacting Us 

For any queries or requests about your data, please contact our Data Protection Officer (DPO): 

Data Protection Lead – Apex PCN: Dr Nicholas Smith

Email: licb.websiteapexpcn@nhs.net

This accessibility statement applies to the website and/or domain associated with Apex Primary Care Network.

Our website is hosted by Frank Design Ltd, and we work closely with our host to ensure that as many people as possible can use our website. This means that users should be able to:

• Change colours, contrast levels and fonts

• Zoom in up to 300% without the text spilling off the screen

• Navigate most of the website using only a keyboard

• Navigate most of the website using speech-recognition software

• Listen to most of the website using a screen reader (including JAWS, NVDA and VoiceOver)

We have also made the website text as simple as possible to understand. For guidance on making your device easier to use if you have a disability, visit AbilityNet.

How Accessible This Website Is

We know that some parts of this website are not fully accessible:

• Some older PDF documents are not fully accessible to screen-reader software

• Some images do not have appropriate alternative text

• Some interactive forms are difficult to navigate using a keyboard (for example, some form controls are missing labels)

• Live video streams do not have captions

Feedback and Contact Information

If you need information on this website in a different format — such as large print, easy read, audio recording, Braille or as a PDF — please contact us:

Email: licb.websiteapexpcn@nhs.net

We aim to respond to your request as quickly as possible.

If you are unable to view the map on our ‘Contact Us’ page, please contact us via email or phone using the details above, and we will provide directions in an accessible format.

Reporting Accessibility Problems With This Website

We are always looking to improve the accessibility of this website. If you find any problems not listed on this page or think we are not meeting accessibility requirements, please contact:

Digital and Transformation Lead: Sophie Robertson

Email: licb.websiteapexpcn@nhs.net

Enforcement Procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the accessibility regulations. If you are not satisfied with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS):https://www.equalityadvisoryservice.com

Contacting Us by Phone or in Person

For details on how to contact us by phone or visit us in person, please see our Contact Us page.

Technical Information About This Website’s Accessibility

Apex Primary Care Network is committed to making its website accessible, in accordance with The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

Compliance Status

This website is partially compliant with the Web Content Accessibility Guidelines version 2.1 AA standard, due to the non-compliances and exemptions listed below.

Non-Accessible Content

The content listed below is non-accessible for the following reasons:

Non-compliance with the accessibility regulations

• Images missing alt text: Some images do not have a text alternative, so users relying on a screen reader cannot access the information. This fails WCAG 2.1 success criterion 1.1.1 (non-text content).Planned fix: We aim to add appropriate alt text by 31/08/2025.

• Forms missing labels: Some form fields are not correctly labelled, making them difficult to use with a screen reader or keyboard. This fails WCAG 2.1 success criterion 1.3.1 (info and relationships).Planned fix: These forms will be updated by 30/09/2025.

• PDF documents: Some older PDF documents are not accessible to screen-reader software. This fails WCAG 2.1 success criterion 4.1.2 (name, role, value).Planned fix: We aim to replace key PDF content with accessible HTML or updated accessible PDFs where possible by 31/12/2025.

Content that’s not within the scope of the accessibility regulations

• Live video: Live video streams do not have captions. This content is exempt from meeting the accessibility regulations under Regulation 4(2)(b).

Preparation of This Accessibility Statement

This statement was prepared on 17 June 2025. It was last reviewed on 17 June 2025.