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Comms with BAPIO and MDS

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Dr Sandeep Bansal

Dear General Medical Council,

Hi

Can you please provide me all un-redacted communication between BAPIO and/or Medical Defence Shield (MDS) in the last 4 years please.

If you can categorise the communications into two categories:

1) with GMC leadership team

2) Rest of GMC

Thank you

Yours faithfully,

Dr Sandeep Bansal

FOI, General Medical Council

Thank you for getting in touch. Please note this is an automated email.
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In the meantime, if you want any further information about the GMC, please
visit our website: [1]Home - GMC (gmc-uk.org)

General Medical Council

We work with doctors, patients, and other stakeholders to support good,
safe patient care across the UK. We set the standards doctors and those
who train them need to meet, and help them achieve them. If there are
concerns these standards may not be met or that public confidence in
doctors may be at risk, we can investigate, and take action if needed.

This email may contain privileged or confidential information which should
only be used for the purpose for which it has been sent.

If you are not the addressee or have received this email in error, please
do not read, print, re-transmit, store or act in reliance on it or any
attachments. Please email the sender and then immediately delete it.

The General Medical Council is a charity registered in England and Wales
(1089278) and in Scotland (SC037750)

You are welcome to contact us in Welsh. We will respond in Welsh, without
this causing additional delay.

_________________________________________________________________

Cyngor Meddygol Cyffredinol

Rydym yn gweithio gyda meddygon, cleifion a rhanddeiliaid eraill i
gynorthwyo gofal da a diogel i gleifion ar draws y DU. Rydym yn gosod y
safonau y bydd angen i feddygon a’r rhai sy’n eu hyfforddi eu bodloni, ac
yn eu helpu i’w cyflawni. Os bydd pryderon efallai na fydd y safonau hyn
yn cael eu cyflawni neu y gallai hyder y cyhoedd mewn meddygon fod mewn
perygl, gallwn ymchwilio, a gweithredu os oes angen.

Efallai bod y neges e-bost hon yn cynnwys gwybodaeth freiniol neu
gyfrinachol, y dylid ei defnyddio at y diben y’i hanfonwyd yn unig.

Os nad chi yw’r derbynnydd neu os ydych chi wedi cael yr e-bost hwn mewn
camgymeriad, peidiwch â’i ddarllen, argraffu, ail-anfon, storio na
gweithredu mewn ffordd sy’n dibynnu arni neu unrhyw atodiadau os gwelwch
yn dda. Dylech anfon e-bost at yr anfonwr ac yna, ei ddileu ar unwaith.

Mae’r Cyngor Meddygol Cyffredinol yn elusen gofrestredig yng Nghymru a
Lloegr (1089278) ac yn Yr Alban (SC037750)

Mae croeso i chi gysylltu â ni yn Gymraeg. Byddwn yn ymateb yn Gymraeg,
heb i hyn achosi oedi ychwanegol.

References

Visible links
1. https://www.gmc-uk.org/

FOI, General Medical Council

Dear Dr Sandeep Bansal,

 

Your information request – IR1-4473282695

 

Thank you for your Email below dated 27^th June 2024.

 

How we will consider your request

We are going to consider your request under the Freedom of Information Act
2000 (FOIA). The FOIA gives us 20 working days to respond, but we’ll come
back to you as soon as we can.

 

Your request will be allocated to a member of the team. If you have any
queries please email [1][GMC request email].

 

Kind regards,

 

Information Access Team

General Medical Council

3 Hardman Street

Manchester

M3 3AW

 

show quoted sections

Matthew McCoig-Lees, General Medical Council

Dear Dr Bansal

 

Reference numbers: IR1-4466480477, IR1-4466565855, IR1-4466566151,
IR1-4466566198, IR1-4466566337, IR1-4466566474, IR1-4466566574,
IR1-4466566639, IR1-4473282695

 

I write further to previous correspondance with a response under the
Freedom of Information Act 2000 (FOIA).

 

I am applying a costs exemption to your requests. This is because of the
amount of data you’ve asked for and the work that would be involved. Under
FOIA there’s an exemption for requests where it would cost the public
authority more than £450 to process - equivalent to 18 hours. This is
based on an hourly rate of £25 per hour, which is set by the Freedom of
Information (Fees and Appropriate Limit) Regulations 2004. This amount is
called the ‘appropriate limit.’

 

To estimate the cost, we can take into account determining, locating,
retrieving and extracting the information requested.

 

When a public authority estimates whether the appropriate limit is likely
to be exceeded, it can include the costs of complying with two or more
requests so long as the requests are:

 

•             Made for the same or similar information; and

•             Received within any period of 60 consecutive working
days         

 

I am including all your requests made on 20 June 2024 as well as the one
made on 27 June when determining if the ‘appropriate limit’ is exceeded.
Your requests are similar because they almost all are for communications
with external organisations and you are ‘most interested’ in
communications about physician associates and anaesthesia associates. The
sole request which is not for communications with external organisations
is specifically about physician associates and anaesthesia associates. The
request made on 27 June encompasses material about physician associates
and anaesthesia associates. The requests were all made within eight days.

 

There are some clarifications I would need to respond to a revised request
without which it makes providing further information about my cost
estimate difficult. I’ve set out more about this below but for my estimate
I’ve assumed that by GMC ‘leadership’ you mean the senior management team
and our council. This amounts to 19 people. I also believe there might be
a further 25 people who provide support to them who might reasonably have
sent communications out in their name. These are their executive
assistants if they have one and other people who directly support their
work. Therefore, there are a minimum of 44 people for whom we would have
to determine if they had sent correspondence out which falls into the
scope of your request and then locate, retrieve and extract it. I accept
that some of them might be able to rule out that they had done so very
quickly. However, others would not. On average, I believe that it is not
unreasonable to assume this process would take 30 minutes per person which
would take 22 hours in total. This would be over the appropriate limit.
This also does not account for correspondance from the ‘rest of the GMC’
in respect of your request dated 27 June which would encompass further
people.

 

However, this also does not take account of any other parts of your
requests such as reviewing the diaries of GMC ‘leadership’ to determine if
they had scheduled phone calls with the organisations or leadership of the
organisations you are interested in and them locate, retrieve and extract
material which fell into the scope of your request. I think this would
take at least a few hours.

 

It also does not include the time it would take to locate, retrieve and
extract the minutes and documentation from any council and board meetings
we have had in the last 12 months with regards to PA/AAs including those
from confidential sessions. This might also take a number of hours.

 

Finally, it does not account for the time spent determining what we might
hold.

 

Under the FOIA, the specific exemption which I believe applies is at
section 12. This states that we are not required to comply with a request
if we estimate that the cost of doing so would exceed the appropriate
limit.

 

Advice and Assistance

 

By way of preliminary remarks, firstly, your requests for communications
asks for ‘communication details.’ If you mean something other than ‘email,
telephone calls, text/instant communications,’ you’ll have to explain what
you mean.

 

Secondly, if you are interested in communications between the ‘leadership’
of various organisations including the GMC, I would need to understand who
you were referring to, preferably by reference to either their names, if
known, and/or job titles.

 

However, the main advice is to limit your request to written
correspondance to or from a more limited number of GMC employees. You
might also possibly pick the one or two organisations of most interest to
you. I would anticipate that this would be less likely to attract a costs
exemption.

 

Your right to appeal

 

If you would like to appeal this decision to the Information Access
Manager, please set out your reasons in writing to [GMC request email]. Please
note that we will only consider appeals received within 40 working days of
our response. You can also appeal to the Information Commissioner, the
regulator of the FOIA and DPA. Their online portal for freedom of
information requests is [1]here.

 

 

---

Kind Regards

 

Matt

 

Matthew McCoig-Lees

Senior Information Access Officer

Information Access Team

General Medical Council

3 Hardman Street

Manchester

M3 3AW

Email: [2][email address]

Website: [3]www.gmc-uk.org

Tel: 0161 923 6579

 

I sometimes work flexibly and therefore this email may reach you outside
of core working hours. I don’t expect you to respond outside of your own
working hours.

 

General Medical Council

We work with doctors, patients, and other stakeholders to support good,
safe patient care across the UK. We set the standards doctors and those
who train them need to meet, and help them achieve them. If there are
concerns these standards may not be met or that public confidence in
doctors may be at risk, we can investigate, and take action if needed.

This email may contain privileged or confidential information which should
only be used for the purpose for which it has been sent.

If you are not the addressee or have received this email in error, please
do not read, print, re-transmit, store or act in reliance on it or any
attachments. Please email the sender and then immediately delete it.

The General Medical Council is a charity registered in England and Wales
(1089278) and in Scotland (SC037750)

You are welcome to contact us in Welsh. We will respond in Welsh, without
this causing additional delay.

_________________________________________________________________

Cyngor Meddygol Cyffredinol

Rydym yn gweithio gyda meddygon, cleifion a rhanddeiliaid eraill i
gynorthwyo gofal da a diogel i gleifion ar draws y DU. Rydym yn gosod y
safonau y bydd angen i feddygon a’r rhai sy’n eu hyfforddi eu bodloni, ac
yn eu helpu i’w cyflawni. Os bydd pryderon efallai na fydd y safonau hyn
yn cael eu cyflawni neu y gallai hyder y cyhoedd mewn meddygon fod mewn
perygl, gallwn ymchwilio, a gweithredu os oes angen.

Efallai bod y neges e-bost hon yn cynnwys gwybodaeth freiniol neu
gyfrinachol, y dylid ei defnyddio at y diben y’i hanfonwyd yn unig.

Os nad chi yw’r derbynnydd neu os ydych chi wedi cael yr e-bost hwn mewn
camgymeriad, peidiwch â’i ddarllen, argraffu, ail-anfon, storio na
gweithredu mewn ffordd sy’n dibynnu arni neu unrhyw atodiadau os gwelwch
yn dda. Dylech anfon e-bost at yr anfonwr ac yna, ei ddileu ar unwaith.

Mae’r Cyngor Meddygol Cyffredinol yn elusen gofrestredig yng Nghymru a
Lloegr (1089278) ac yn Yr Alban (SC037750)

Mae croeso i chi gysylltu â ni yn Gymraeg. Byddwn yn ymateb yn Gymraeg,
heb i hyn achosi oedi ychwanegol.

References

Visible links
1. https://ico.org.uk/make-a-complaint/foi-...
2. mailto:[email address]
3. http://www.gmc-uk.org/

Dr Sandeep Bansal

Dear Matthew McCoig-Lees,

thanks for the purpose of meeting cost envelope, I will amend my request.

The timeframe, instead of 4 years, it can be the last 6 months

Thanks

Yours sincerely,

Dr Sandeep Bansal

FOI, General Medical Council

Dear Dr Bansal,

 

Your information request - IR1-4513575698

Thank you for your email dated 19 July, in which you ask for
communications with BAPIO and MDS in the last 6 months.

 

How we will consider your request

We note that you’ve titled your email ‘internal review of Freedom of
Information request - Comms with BAPIO and MDS.’. However we consider that
you have in fact made what is a new request and therefore we’re going to
consider your request under the Freedom of Information Act 2000 (FOIA).
The FOIA gives us 20 working days to respond, but we’ll come back to you
as soon as we can.

 

Kind Regards,

 

Information Access Team

General Medical Council

3 Hardman Street

Manchester

M3 3AW

 

 

 

show quoted sections

Matthew McCoig-Lees, General Medical Council

Dear Dr Bansal

Reference numbers: IR1-4513757894, IR1-4513708957, IR1-4513746003,
IR1-4513745890, IR1-4513746056, IR1-4513746112, IR1-4513575698,
IR1-4513575542, IR1-4516508303, IR1-4509636892, IR1-4524928907

I write further to previous correspondance with a response under the
Freedom of Information Act 2000 (FOIA).

I am again applying a costs exemption to your requests. This is because of
the amount of data you’ve asked for and the work that would be involved.
Under FOIA there’s an exemption for requests where it would cost the
public authority more than £450 to process - equivalent to 18 hours. This
is based on an hourly rate of £25 per hour, which is set by the Freedom of
Information (Fees and Appropriate Limit) Regulations 2004. This amount is
called the ‘appropriate limit.’

To estimate the cost, we can take into account determining, locating,
retrieving and extracting the information requested.

Amalgamation of requests

When a public authority estimates whether the appropriate limit is likely
to be exceeded, it can include the costs of complying with two or more
requests so long as the requests are:

• Made for the same or similar information; and

• Received within any period of 60 consecutive working days.

I am including all your requests made on 19 July 2024 as well as the
requests made on 18, 23 and 25 July when determining if the ‘appropriate
limit’ is exceeded. Most are again requests for communications with
various organisations about physician associates and anaesthesia
associates. Other requests concern minutes of meetings with or about them,
our consultation concerning them, and finally communication with a
particular PA. The requests were all made within eight days.

Exemption

I appreciate that you have not resubmitted all your previous requests
concerning communications with various organisations and have focussed on
email communications. In my response of 19 July, I assumed that by GMC
‘leadership’ you meant the senior management team and our council,
amounting to 19 people. I also believed there might be a further 25 people
who provide support to them who might reasonably have sent communications
out in their name. I explained how I reached an estimate that it would
take 22 hours to determine if they had sent correspondance out which falls
into the scope of your request and then locate, retrieve and extract it
and that this would be over the appropriate limit. It stands to reason
that since you have omitted two organisations from your current requests,
the amount of time it would take the 44 people to determine, locate,
retrieve and extract the information in the scope of the request is less
than 22 hours. How much less is difficult to calculate but this part of
your request could still be over the appropriate limit because of the
number of staff involved and at least some of your requests concern all
email communications rather than just being about physician associates and
anaesthesia associates. 

However, in terms of justifying the exemption, there are other elements of
your request to consider.  I would anticipate it would take additional
hours to identify meeting minutes and associated communications and
documentation as well as the information you requested concerning our
survey about the regulation of physician associates and anaesthesia
associates.

Furthermore, one of your original requests was as follows:

Can you please provide me all un-redacted communication between BAPIO
and/or Medical Defence Shield (MDS)  in the last 4 years please.

If you can categorise the communications into two categories:

1) with GMC leadership team

2) Rest of GMC   

You amended it to six months, however since it refers to every GMC
employee I believe that this request, on its own, is over the appropriate
limit. The GMC employs over 1700 staff members. Taking the 1700 number,
even if it took each staff member only one minute each on average to
determine, locate, retrieve and extract the material in respect of each of
them, this alone would take over 28 hours.

Therefore, overall it is clear that the S12 applies when considering your
requests collectively in accordance with the amalgamation rules as set out
above.

Advice and assistance

One option would be narrow your request concerning communications with
external organisations to fewer GMC staff and/or organisations and exclude
every other type of request. Another option would be to focus only on one
of your other requests.

Your right to appeal

If you would like to appeal this decision to the Information Access
Manager, please set out your reasons in writing to [1][GMC request email].
Please note that we will only consider appeals received within 40 working
days of our response. You can also appeal to the Information Commissioner,
the regulator of the FOIA and DPA. Their online portal for freedom of
information requests is [2]here.

---

Kind Regards

Matt

Matthew McCoig-Lees

Senior Information Access Officer

Information Access Team

General Medical Council

3 Hardman Street

Manchester

M3 3AW

Email: [3][email address]

Website: [4]www.gmc-uk.org

Tel: 0161 923 6579

I sometimes work flexibly and therefore this email may reach you outside
of core working hours. I don’t expect you to respond outside of your own
working hours.

General Medical Council

We work with doctors, patients, and other stakeholders to support good,
safe patient care across the UK. We set the standards doctors and those
who train them need to meet, and help them achieve them. If there are
concerns these standards may not be met or that public confidence in
doctors may be at risk, we can investigate, and take action if needed.

This email may contain privileged or confidential information which should
only be used for the purpose for which it has been sent.

If you are not the addressee or have received this email in error, please
do not read, print, re-transmit, store or act in reliance on it or any
attachments. Please email the sender and then immediately delete it.

The General Medical Council is a charity registered in England and Wales
(1089278) and in Scotland (SC037750)

You are welcome to contact us in Welsh. We will respond in Welsh, without
this causing additional delay.

_________________________________________________________________

Cyngor Meddygol Cyffredinol

Rydym yn gweithio gyda meddygon, cleifion a rhanddeiliaid eraill i
gynorthwyo gofal da a diogel i gleifion ar draws y DU. Rydym yn gosod y
safonau y bydd angen i feddygon a’r rhai sy’n eu hyfforddi eu bodloni, ac
yn eu helpu i’w cyflawni. Os bydd pryderon efallai na fydd y safonau hyn
yn cael eu cyflawni neu y gallai hyder y cyhoedd mewn meddygon fod mewn
perygl, gallwn ymchwilio, a gweithredu os oes angen.

Efallai bod y neges e-bost hon yn cynnwys gwybodaeth freiniol neu
gyfrinachol, y dylid ei defnyddio at y diben y’i hanfonwyd yn unig.

Os nad chi yw’r derbynnydd neu os ydych chi wedi cael yr e-bost hwn mewn
camgymeriad, peidiwch â’i ddarllen, argraffu, ail-anfon, storio na
gweithredu mewn ffordd sy’n dibynnu arni neu unrhyw atodiadau os gwelwch
yn dda. Dylech anfon e-bost at yr anfonwr ac yna, ei ddileu ar unwaith.

Mae’r Cyngor Meddygol Cyffredinol yn elusen gofrestredig yng Nghymru a
Lloegr (1089278) ac yn Yr Alban (SC037750)

Mae croeso i chi gysylltu â ni yn Gymraeg. Byddwn yn ymateb yn Gymraeg,
heb i hyn achosi oedi ychwanegol.

References

Visible links
1. mailto:[gmc%20request%20email]
2. https://ico.org.uk/make-a-complaint/foi-...
3. mailto:[email%20address]
4. http://www.gmc-uk.org/

Dear Matthew McCoig-Lees,

Sure.

Lets refine it to just email communications

Last 6 months please.

Yours sincerely,

Dr Sandeep Bansal

FOI, General Medical Council

Dear Dr Bansal,

Your information request - IR1-4576940459

Thank you for your email dated 3 September.

How we will consider your request

We’re going to consider your request under the Freedom of Information Act
2000 (FOIA). The FOIA gives us 20 working days to respond, but we’ll come
back to you as soon as we can.

Yours sincerely

Information Access Team

General Medical Council

3 Hardman Street

Manchester

M3 3AW

From: Dr Sandeep Bansal <[FOI #1142711 email]>
Sent: Tuesday, September 3, 2024 11:25 AM
To: Matthew McCoig-Lees <[email address]>
Subject: Re: GMC FOI Responses

Dear Matthew McCoig-Lees, Sure. Lets refine it to just email
communications Last 6 months please. Yours sincerely, Dr Sandeep Bansal
-----Original Message----- Dear Dr Bansal Reference numbers:
IR1-4513757894, IR1-4513708957, IR1-4513746003,

Dear Matthew McCoig-Lees,

Sure.

Lets refine it to just email communications

Last 6 months please.

Yours sincerely,

Dr Sandeep Bansal

show quoted sections

We don't know whether the most recent response to this request contains information or not – if you are Dr Sandeep Bansal please sign in and let everyone know.