The PDA was broadly supportive of the proposed guidance and we found it well written, helpful and clear. The language and content were tailored well to its target audience – pharmacists, and in our view, it will achieve its aim of helping to protect the public.
We recommended that the scope of the guidance be broadened to encompass “patients and others that pharmacists interact with in the course of their work.”
Our other recommendations included:
- The term ‘people receiving care’ in the guidance should be replaced with ‘patients and others that pharmacists interact with in the course of their work’.
- Paragraph 1.5 in the “About this Guidance” section should be amended by adding words to the effect that “The circumstances of any potential fitness to practice proceedings will be evaluated on a case-by-case basis.”
- In the section on chaperones, the PSNI should add a requirement that it is the responsibility of pharmacy owner to ensure that there are sufficient staff to ensure a chaperone can be available as required.
- The PSNI could use the definition of sexual harassment highlighted by the Equality Commission for Northern Ireland, rather than the PSA’s 2008 definition of sexualised behaviour, as the latter does not seem suitable.
- On paragraph 1.2, the text “(who has access to relevant information and resources)” should be removed. The imbalance of power between a healthcare professional and a patient is not created merely by access to relevant information and resources, but also by other factors such as the power to make the decision as to what care is received, if any.
Download the PDA’s full response here
