Guidance for GP registrars and GP Educators on recording consultations for GP training purposes

While there is no part of GP training (including all three elements of the MRCGP: WPBA, AKT, and SCA) where it is mandatory for a GP registrar to record their consultations, there are instances where recording a consultation can provide educational value. This guidance seeks to provide information on the areas where consultations may be recorded, and to signpost to additional guidance and regulation around recording consultations.

Do GP registrars need to record consultations as part of GP training?

Recording consultations is not mandatory across Workplace Based Assessments (WPBA), but it is often considered a useful tool for learning and feedback in several areas of GP training. The Consultation Observation Tool (COT) explicitly allows consultations to be assessed either through direct observation or by reviewing a recorded consultation. This includes face-to-face and virtual consultations, and recording may be a useful tool to improve consultation skills. Recorded consultations can have advantages over direct observation as they can be paused, replayed and provide direct evidence of the consultation for analysis and discussion. This can help facilitate GP registrars to observe their own behaviours and learn from discussing these. For telephone consultations, an Audio-COT is used, which naturally involves audio recordings.

Other WPBA tools, such as Mini-CEX, are typically based on live observation but may use recorded consultations for feedback purposes. Reflective assessments like Case-Based Discussion (CbD) do not require recordings, though GP registrars may choose to reference recorded consultations as supporting evidence.

Guidance and Regulation on recording consultations

The GMC has produced cross-specialty guidance on making and using recordings. The GMC guidance is intended to apply to both pre- and post- CCT, stating:

"This guidance covers visual and audio recordings of patients made and used in any circumstances where medical professionals work in a professional capacity. This includes recordings made… for purposes such as teaching, training or assessment of healthcare professionals and students".

Anyone considering recording consultations must ensure that they familiarise themselves with - and comply with - the following:

  • The GMC's guidance mentioned above;
  • Any guidance, policies or procedures produced by - or applying to - the deanery in which the GP registrar is training;
  • Any other guidance, policies or procedures produced by employers, or the organisation in which the GP registrar's post is based (e.g. the practice in which they're currently working).

The GMC's guidance sets out a series of principles for making and using visual and audio recordings of patients. These are listed below, grouped under a series of headings with some additional commentary from the RCGP where appropriate, to provide further guidance on how these principles should be applied in the context of GP training.

Patient consent

The GMC's guidance states that someone recording consultations for GP training purposes must:

  • give patients the information they want, or need, about the purpose of the recording
  • make recordings only where you have appropriate consent or other valid authority for doing so
  • make sure that patients are under no pressure to give their consent for the recording to be made
  • where practicable, stop the recording if the patient asks you to, or if it is having an adverse effect on the consultation or treatment.

And they must not:

  • make, or participate in making, recordings against a patient’s wishes, or where a recording may cause the patient harm
  • disclose or use recordings for purposes outside the scope of the original consent without obtaining further consent (except in the circumstances set out in [the GMC's guidance]).

Within GP training, this will generally mean obtaining a valid consent form (or other approved method of documenting consent) for each recording. As much notice as possible should be given to patients that the consultation may be recorded for training purposes. It must be clear to patients how long recordings will be stored for (and this must be in line with any local or national requirements), and for what purpose they're being stored for (if this is just for training purposes, then the recordings must only be used for training purposes). Once the consultation is finished, the patient should be asked if they still consent to the recording.

Making and storing recordings

The GMC's guidance states that someone recording consultations for GP training purposes must:

  • anonymise or code recordings before using or disclosing them for a secondary purpose, if this is practicable and will serve the purpose
  • disclose or use recordings from which patients may be identifiable only with consent or other valid authority for doing so
  • make appropriate secure arrangements for storing recordings
  • be familiar with, and follow, the law and local guidance and procedures that apply where you work.

It is vital that anyone recording consultations for GP training understands how to securely record and store a consultation. It is never acceptable to record a consultation on a personal device unless using specifically approved applications that instantly transmit and delete recordings. All recorded consultations must be stored with the same level of security as any other patient record and in compliance with GDPR. Recordings should never be saved to personal cloud storage or hard drives. We would recommend that GP registrars use recording options and equipment that have been approved by their individual practices, in line with practice policy and GMC guidance.