PID submission: FGM now, what next?

The government has done much to tackle FGM 1, 2, 3 but the planned rollout of FGM Enhanced Data Collection across the NHS in October 2015 is ill considered.

So wrote leading medics in a letter to the BMJ.

All healthcare professionals will be legally obliged to submit highly sensitive, patient identifiable information on every woman with FGM attending the NHS for whatever reason. A woeful consultation preceded the ministerial direction, which also says patient consent is not needed. While stating that confidential data will not be released to third parties (such as police, Crown Prosecution Service), the reassurance is inadequate and not future proofed. 4, 5, 6. The legal responsibility for communicating that this information will be collected, where it will be sent, and what may happen to it is devolved to frontline clinicians. 7, 8. The push to implement an electronic infrastructure and opt-out that is not fit for purpose will bring already compromised patient confidence closer to breaking point. 9, 10. The initiative has no evidence of benefit, wastes precious clinical time, and will profoundly damage trust in health professionals who will either collude or ignore the imperative.

Correspondence with the minister of public health and civil servants remains unanswered. The Department of Health seems wilfully unaware of the wider ramifications of breaching confidentiality and the impact on the human and healthcare rights of already disadvantaged women and their families. Rather than tackling FGM, this measure is likely to be counterproductive and hinder eradication strategies.

Confidentiality is not absolute, but it underpins the doctor-patient relationship. 11. Without reiterating countervailing ethical and professional duties, the GMC recently emailed all doctors about their obligation to breach confidentiality if the government has made a law compelling them to do so. 12. But such law is unnecessary and misguided. The government still has time to reflect and pull back from a policy that wrecks the basic medical promise of confidentiality.

Authors

Susan Bewley, professor of complex obstetrics, Brenda Kelly, consultant obstetrician and clinical lead for the Oxford Rose Clinic, Katrina Darke, general practitioner and clinical lead for the Bristol Community Rose Clinic, Katrina Erskine, consultant obstetrician and gynaecologist and associate medical director, Clare Gerada, general practitioner, Patricia Lohr, medical director, Paquita de Zulueta, honorary senior clinical lecturer.

References

1↵O’Dowd A. Improve reporting of female genital mutilation, MPs tell doctors. BMJ 2015;350:h1467. (18 March.) FREE Full Text

2↵Department of Health. Safeguarding women and girls at risk of FGM. 2015. www.gov.uk/government/publications/safeguarding-women-and-girls-at-risk-of-fgm.
3↵Department of Health. Services for girls and women with FGM. 2015. www.gov.uk/government/publications/services-for-women-and-girls-with-fgm.
4↵Department of Health. FGM enhanced dataset: guidance on NHS staff responsibilities. 2015. www.gov.uk/government/publications/fgm-enhanced-dataset-guidance-on-nhs-staff-responsibilities.
5↵Health and Social Care Information Centre. Female genital mutilation enhanced dataset. Information governance statement. www.hscic.gov.uk/media/18125/FGM-Enhanced-Dataset-IG-Statement/pdf/FGM_Enhanced_Dataset_IG_Statement.pdf.
6↵Health and Social Care Information Centre. Female Genital Mutilation Datasets. www.hscic.gov.uk/fgm.
7↵UK Government. Data Protection Act, 1998. www.gov.uk/data-protection/the-data-protection-act.
8↵Health and Social Care Information Centre. Female Genital Mutilation (FGM) Enhanced Dataset: Requirements Specification. 2015:48 www.hscic.gov.uk/media/16781/2026122014spec/pdf/2026122014spec.pdf.
9↵London clinic leaks HIV status of patients. BBC News2015. www.bbc.co.uk/news/uk-england-london-34127740
10↵Royal College of Physicians. RCGP voices concerns over care.data. 2014. www.rcgp.org.uk/news/2014/february/rcgp-voices-concerns-about-care-data.aspx.
11↵Royal College of Physicians. Future physician: changing doctors in changing times. Report of a working party. 2010. www.rcplondon.ac.uk/sites/default/files/documents/future-physician.pdf.
12↵GMC News. Email dated September 10th 2015 “New mandatory duty to report cases of FGM.”

This letter to the British Medical Journal was first published here 30 September 2015.

BMJ 2015;351:h5146