Posts Tagged ‘CMO’

Remedy loses battle to call CMO to account

By Francesca Robinson - 3rd June 2010 9:18 am

Doctors working as government or senior medical managers cannot be held to account by GMC for their actions, the High Court has ruled.

The judgement was made in a judicial review of a decision by the GMC not to investigate the professional and managerial decisions of two senior Department of Health managers in introducing the disastrous MTAS junior doctor recruitment scheme.

The campaign group Remedy UK brought the case, because it said the MTAS “architects” - former CMO professor Sir Liam Donaldson and Professor Sarah Thomas, who chaired the MTAS recruitment and selection steering group - should be investigated by the GMC’s fitness to practise procedures.

They had been responsible for introducing the scheme in 2007 that damaged doctors, patients and the standing of the profession, argued Remedy.

The GMC had rejected a request by Remedy that Donaldson and Thomas should be subjected to its disciplinary processes.

Remedy argued that the professional and managerial actions and conduct of Donaldson and Thomas in relation to MTAS fell seriously below the high standards that are expected by the profession, as laid out in GMC guidance.

But judges Lord Justice Elias and Justice Keith threw the case out because they said although Donaldson and Thomas used their medical skills and experience in their work for the Department of Health, their role in implementing government health policy was not a “medical function”. The functions they were exercising were too remote from the profession of medicine to bring them within the scope of the legislation governing the conduct of doctors.

The judges said that there was no allegation that the doctors had acted in bad faith and their conduct could not in any sense be deemed to be disreputable. “Bad judgment does not justify moral censure particularly where it is the decision of a committee of which the alleged wrongdoer is only one participant,” they ruled.

Matt Jameson Evans, Remedy co-chairman, said: “This is the worst possible outcome for ordinary doctors. We had always suspected that there was one rule for ‘them’ and one rule for ‘us’. Now we have it confirmed.”

Richard Marks, Remedy head of policy, said: “Lawyers across the country will be rubbing their hands in glee at the loopholes that this ruling will have created. The ramifications are that future CMOs and other senior management figures will be unaccountable to the GMC for deficient professional performance.”

He said their lawyers thought they had good grounds to appeal but at the moment Remedy could not afford the estimated costs of £20-40,000. Remedy is expecting it will have to pay £22,500 of the GMC’s total costs of over £45,000.

A GMC spokesperson said: ”We welcome the decision from Lord Justice Elias which confirms we were correct not to investigate complaints made by Remedy UK.”

Read the full judgement

What is Prof Sir Liam Donaldson’s legacy as CMO?

By Mike Broad - 26th May 2010 11:01 am

It’s the Chief Medical Officer for England’s last week in office.

Prof Dame Sally Davies is primed to act as interim CMO after Prof Sir Liam Donaldson’s departure. There will be an open competition for the role during the summer.

What lessons should the next CMO learn from Sir Liam’s 12-year tenure?

Well, there are quite a few. On the positive side, they would do well to emulate his campaigning style on public health issues.

The smoking ban in public places, introduced in 2005, will be remembered as Sir Liam’s greatest success. He galvanised political support - threatening to resign over the issue - following John Reid’s appointment as health secretary, who was opposed to legislation.

He’s also been campaigning aggressively, if a little piously, over a minimum pricing structure for units of alcohol. That debate is set to continue, though it’ll take something from his successor to enthuse the Tories.

Also on the plus side was our preparedness for Swine Flu. I know he took criticism for sensationalising the risk but, having chaired a flu pandemic conference a few years back, the potential consequences are truly terrifying. I’m looking at it as a decent practice run for the next one (and I just don’t buy into the pharma company conspiracy theories).

Other good stuff includes his advocacy for presumed consent on organ donation and rapid introduction of the WHO’s surgical safety checklist.

But, like all journalists, I’m more interested in the bad stuff. When it comes to supporting the profession, Sir Liam doesn’t come up smelling of roses.

In the past couple of weeks his name has been bandied about the high court as part of a pressure group’s legal action against the GMC. Remedy has taken the GMC to court over the alleged blocking of a fitness to practise enquiry into the CMO. It concerns Donaldson’s management of the disastrous computerised recruitment system, MTAS, in 2007.

He was complicit in damaging - and in some cases destroying - the careers of a generation of young doctors, who either found themselves in the wrong jobs or unemployed.

As the Health Select Committee subsequently said: “Candidates and assessors alike were justifiably outraged by the sheer inadequacy of MTAS. The period between February and August 2007 was characterised by unrelenting chaos and severe anxiety for thousands of junior doctors…The reputation of both the Department of Health and the leaders of the profession were severely diminished.”

The judges will make their decision later this month but, whatever the outcome, MTAS represents a big black mark against Sir Liam’s name.

I’d also suggest revalidation counts against the positive public health legacy.

The Shipman Inquiry was highly critical the GMC’s approach to managing dangerous and incompetent doctors, and called for reform. Dame Janet Smith, chair of the Shipman Inquiry, went on to challenge the GMC’s initial plans for revalidation.

The GMC postponed the introduction of revalidation and the Chief Medical Officer reviewed revalidation afresh. It culminated in the current plans, which include re-licensing.

But revalidation, as currently envisaged, is an expensive and overly complicated way of proving competence. It’s in danger of becoming a meaningless paper chase for the overwhelming majority of doctors.

So, what are the lessons for the next CMO? I’d suggest the first thing they do is clarify the role. On the DoH website, the CMO is described as the ‘UK government’s principal medical adviser and the professional head of all medical staff in England’.

The successes of the role have been in providing independent advice to the government on public health issues (and then campaigning hard for appropriate action).

However, when it came to being the ‘professional head of all medical staff’, the CMO appeared little more than a ‘Nulabour’ stooge.

If I were CMO for England, (Lord help us should it come to pass), I’d either get that bit struck from the job spec or take a crash course in understanding the real professional issues affecting medicine. So Dame Sally, if you want the job in a permanent capacity, you have been warned…

Read a summary of the CMO’s final annual report.

CMO’s view of 2009: swine flu, alcohol pricing and quality

By Mike Broad - 9:33 am

Prof Sir Liam Donaldson, the Chief Medical Officer for England, stands down this week. He’s been in post for 12 years, during the same period as the Labour government. His annual reports provide an interesting snapshot of the evolving health priorities over that period. His final one was released recently with little fanfare. Here’s a summary of the year and ongoing priorities, in his own words:

1. Swine flu

The predominant challenge of 2009 was the emergence of the first influenza pandemic for 40 years. From Mexico, the illness spread fast around the world. England was amongst the first countries to have cases of what was rapidly confirmed as a new flu virus - influenza A/H1N1.

England was well prepared. Initial efforts to slow transmission were maintained for several weeks. Inevitably, the number affected grew. A growing number of people were admitted to hospital. In June 2009, the country sadly saw its first death.

Demonstrating the unusual way in which pandemic flu viruses behave, rates of infection continued to swell into the summer months. General practice felt much of the strain, and handled it well.

When the strain was approaching a critical level, the National Pandemic Flu Service was activated. This was an entirely novel concept for the country, and formed an important part of the pandemic plan. The public had never previously been able to access an internet and telephone based diagnostic and treatment service that provided medication when appropriate. The National Pandemic Flu Service was well used, and relieved significant pressure on the mainstream NHS.

As summer turned to autumn, the picture was mixed. There had been deaths. Hospital capacity had been stretched significantly, particularly in intensive care. But rates of infection had peaked in August 2009 and were falling. For most people, the disease was milder than had been anticipated based on the early information from Mexico.

Some have called the public health response to the pandemic an overreaction. In so doing, they draw attention to the overall costs of antiviral drugs and vaccines. They speak of the relatively small number of deaths compared with previous influenza pandemics and seasonal influenza outbreaks. In describing the number of deaths in the present pandemic, they often use the prefix ‘only’. In response, it is important to ask a number of questions. Would it have been acceptable not to plan as well as we did for a pandemic nor procure countermeasures? Having done so, and in the face of emerging, worrying evidence from the first phase of the pandemic in Mexico, would it have been right not to deploy existing countermeasures and not to strengthen our holdings? Would it have been acceptable to hide and conceal statistical projections provided by statistical modellers of international standing, even though releasing them publicly caused alarm in some quarters? Would it have been right to take the view that it was acceptable to ‘tolerate’ a certain number of deaths, considering them low enough to accept, when a way of preventing them was available?

In the first pandemic of the 21st century, we had the option of fighting the illness to protect children and adults from its adverse consequences. It is vital that we learn from what we have seen in this pandemic, for the sake of those who find themselves tackling - and affected by - the next. It is likely to be worse.

2. Alcohol consumption

I made several recommendations, including the introduction of a minimum price per unit of alcohol. I have been pleased to see public health and medical leaders engaging so widely with this issue. Many of its representative bodies have spoken out in favour of a minimum price policy, including the Royal College of Physicians and the BMA. In July 2009, I gave evidence to the parliamentary Health Select Committee’s inquiry into alcohol. Its report, published in January 2010, also calls for a minimum price per unit. The price of alcohol is a crucial determinant of its consumption. Tackling the substantial harms caused by alcohol in this country requires this decisive action.

I remain concerned about young people’s drinking. The evidence shows that 11 to 17 year olds drink 20 million units of alcohol (the equivalent of 9 million pints of beer or 2 million bottles of wine) every week. Young people who binge drink in adolescence are more likely to be binge drinkers as adults, and have an increased risk of developing alcohol dependence. In December 2009, I published guidance on the consumption of alcohol by children and young people. I advised that an alcohol free childhood is the healthiest and best option.

3. High Quality Care for All

Published in 2008, Lord Darzi’s report High Quality Care for All marked an important milestone. Its central tenet is that quality should be the ‘organising principle’ of the NHS. It aims to set the health service on a path defined by the quality of its care. It seeks to promote quality from being the focus of specific workstreams to being at the heart of how the service operates and thinks.

In 2009, the health service began working on a particularly key means of achieving this. It has been collecting the necessary data to produce ‘Quality Accounts’ for 2009/10. Trusts will report their key measures of quality in the same way in which they report their key measures of financial performance. This is vitally important. Focus shifts to where measurement is made. The act of making and reporting measurements of quality will itself catalyse improvement, helping the NHS to continue developing the quality of the service that it provides to patients.

4. Surgical errors

The 2007 Annual Report, describing surgical safety, highlighted the fact that over 100,000 errors involving surgical patients were reported to the National Patient Safety Agency in that year.

My report recommended that clinical teams should pilot the World Health Organization’s Surgical Safety Checklist. A subsequent pilot study of this checklist involved hospitals in London and seven other locations around the world. It demonstrated that using the checklist could reduce the risk of death and postoperative complications significantly. In 2009, the National Patient Safety Agency started to implement its use nationwide. By late 2009, 80% of hospital trusts in England joined the implementation of this important work.

5. Women in medicine

The proportion of doctors who are women has been climbing rapidly over recent years. It now stands at 41%. In my 2006 Annual Report, I discussed some of the particular issues that this group faces. I formed a National Working Group on Women in Medicine to consider the issues and to develop solutions. I was pleased to receive its report in October 2009. The group proposes a series of steps to enhance opportunities for female doctors. The report makes clear recommendations for a number of bodies, including government departments, universities and NHS employers.

6. Discrimination

On a similar theme, my 2007 Annual Report drew attention to the barriers of racial discrimination that still exist within the medical profession. Substantial improvements have occurred in recent years, but work remains to be done. In 2009, I chaired a series of roundtable meetings on this issue. These brought together high level representatives from the NHS, the GMC and royal colleges. I am pleased by the progress that many of the national bodies are making in this area. I hope that this important issue will continue to receive the attention it deserves.

7. Revalidation

I am also pleased with the progress that is being made to introduce revalidation for doctors. In 2009, the GMC introduced the necessary categories of registration that will allow doctors to obtain and renew their licence to practise. The Department of Health has established a series of pilot sites through which the operational details of revalidation will be tested and refined. I hope that doctors will welcome revalidation. Between qualification and retirement, competence is simply assumed at present. For the vast majority, this assumption is justified. The revalidation process will allow doctors to move from assumption to demonstration. The process will also play an important part in identifying the small number for whom the current assumption is flawed.

Read the full report.

Rare diseases pose medico-legal risk

By Mike Broad - 29th March 2010 9:41 am

The diagnosis and referral of rare diseases pose a significant medico-legal risk for all doctors, a defence body has warned.

The MDDUS warns that doctors need to take steps to minimise their chances of missing a rare disease.

The Chief Medical Officer’s Annual Report in 2009 stated that two in five people with a rare disease have reported difficulty in getting a correct diagnosis and accessing the right services and support for themselves and their families.

Recent figures revealed that inefficiencies in treating people with a rare disease are estimated to cost the NHS over £9million every year.

Dr John Holden, a senior medical adviser at MDDUS, said: “In order to minimise the risk of overlooking a rare diagnosis it is important to assess patients carefully by means of a full history, an examination and by providing or arranging advice, investigations or treatment and by referring to a specialist when the doctor considers that this would be in the patient’s best interests.”

Professor Sir Liam Donaldson listed the diagnosis of rare diseases among five key areas of public health. A disease is classed as ‘rare’ when it affects fewer than five in every 10,000 people. But given that there are more than 6,000 rare diseases, it means that one person in every 17 will present with a rare disease - around 3 million people in England.

MDDUS advises that to avoid potential difficulties in all patient consultations doctors should follow GMC guidance which stresses the importance of recognising and working within your competence, respecting a patient’s right to seek a second opinion and seeking the advice of colleagues when appropriate.

Holden said: “Clear contemporaneous records should also be kept of all discussions and actions relating to a patient’s care.

“Primarily this will aid the care of the patient, and enhance the transfer of information between health professionals, especially if a patient moves away and registers with another GP. Good records are also invaluable should a complaint or claim arise as the result of a delay in diagnosis.”

 

England’s Chief Medical Officer to step down in May

Healthcare Republic - 15th December 2009 9:22 pm

Sir Liam Donaldson, England’s chief medical officer (CMO), is to retire in May.

Sir Liam took up the role in 1998 and is the 15th person to hold the position since it was established in 1855. He is longest serving CMO of modern times.

Sir Liam had originally envisaged leaving his post when he turned 60 in mid-2009. He agreed to stay in his role to supervise the response to the swine flu pandemic. He has stated that, if the pandemic should unexpectedly worsen, he will extend his tenure beyond May 2010.

In his resignation letter Sir Liam said he had been immensely privileged to serve in the post.

“I have been pleased to see many of my policy recommendations - stem cell research, smoke-free public places, reforms to the GMC, changes to consent for organ and tissue retention and the creation of the Health Protection Agency - carried forward into legislation,” he said.

“I have been pleased too, that reforms I proposed to improve quality and safety of NHS care - clinical governance, a patient safety programme, procedures to identify, and prevent harm from, poor clinical practice - are fully embedded in the service and have been also adopted in many other parts of the world.”

Read more at Healthcare Republic.

Swine flu could kill 65,000, says CMO

The Guardian - 17th July 2009 11:57 am

Up to 65,000 people could die from swine flu in the UK in a worst case scenario set out by the chief medical officer as the government launched a national service for patients to obtain antiviral drugs over the internet and telephone.

With 29 deaths now linked to the pandemic and a further 53 patients in intensive care, the cabinet’s emergency planning committee, Cobra, is meeting three times a week to prepare for the impact of the rapidly spreading pandemic.

On a day of dramatic revelations, the Department of Health revealed:

1. The launch of the National Pandemic Flu Service helpline for England

2. 55,000 new infections last week

3. More than 650 people in hospital

4. Half of the UK’s children might fall ill

5. 132 million doses of a vaccine – still in development – have been ordered, enough for two injections for every UK citizen.

Read more at The Guardian.

Flu planning: holiday in the Outer Hebrides…

By Katherine Teale - 14th July 2009 8:21 am

The hospital has a bed shortage (it is, after all, the middle of July). As usual, all other management activity ceases amid hysterical attempts to slip patients having major bowel resections onto our day-surgery unit.

At the same time, CMO Liam Donaldson is reassuring everyone that we’re “well-placed” to deal with the flu pandemic. Yeah, right. So long as it only involves one patient, who doesn’t need ITU, and not, of course, over a weekend. Or after 5 O’clock.

Setting aside for the moment the fact we haven’t got any spare beds unless we cancel elective surgery, (which is so unthinkable that I can barely bring myself to type the words), the situation is exacerbated by the fact that we won’t actually have any staff.

Apparently, to avoid swamping GPs’ surgeries - the last thing you should do if you feel ill is to go to your doctor, who has far more important things to do and, anyway, might catch something - patients will be able to sign themselves off for two weeks without a doctor’s note.

Carte blanche, the cynics among us might be tempted to think, for anyone with a tendency to feeling a bit lethargic to have a duvet fortnight.

Meanwhile, the hospital has been attempting to fit everyone with flu-virus repelling surgical facemasks. The fitting process, which involves donning a large hood and looking so ludicrous that, frankly, a mild dose of flu is probably preferable, excludes anyone with significant facial hair, and those with “unusual” lower facial contours - two groups which mysteriously seem to contain many of the same individuals.

Given the current failure rate, and since I have no beard (yet, although my mother did recently ask me, when she thought no one else was listening, if I had ever considered waxing), I fear I will be the only person in the hospital able to care for flu sufferers should any be allowed to access medical care.

To cap it all, we are also told by a group of government advisors, who I suspect may be London-based, that if the flu epidemic reaches expected proportions, the UK could “grind to a halt” - the two areas particularly singled out are the London Underground and Broadband internet access.

Neither prospect really presses my panic button, partly because, like 90% of the population, my need for the Underground is geographically limited. As for Broadband, I only got it two years ago, so I retain my skills of picking up a telephone, and going to a library to look something up in a book.

So, what’s my plan? Things are looking quite serious as I read the news of two of the latest deaths. Plan A: emigrate to the Outer Hebrides. Rejected this on the grounds that I’d probably go mad in about 6 minutes. Plan B: do what we British do best. Keep calm and carry on.

The summer holidays are coming up, and surely even a flu virus wouldn’t be presumptious enough to mutate while politicians are enjoying their low-budget, recession-friendly holidays in Rhyl as prescribed by Messers Brown and Cameron?

By September the men in white coats may have come up with a vaccine, and the hospital’s 18-week elective surgery target will be saved. As, incidentally, will we.

CMO calls for calm after ‘healthy’ flu death

Healthcare Republic - 13th July 2009 1:11 pm

England’s CMO Sir Liam Donaldson has said that further deaths from swine flu among healthy people who do not have underlying health conditions will be rare.

The call follows the announcement from NHS authorities in Essex that a healthy patient has died from swine flu.

Previous deaths from swine flu had all been among patients with serious underlying health problems.

Sir Liam added that despite the tragic death, the vast majority of people who have been infected by the virus have only suffered from mild symptoms. There have been 16 deaths so far.

Read more at Healthcare Republic.

Will women have what it takes to lead the profession?

By Mike Broad - 18th June 2009 2:54 pm

There’s much to celebrate on the advancement of women within the medical profession.

It wasn’t so long ago that women faced considerable, and at times seemingly insurmountable, barriers to both entering the profession and advancing. Now they’re afforded the same career opportunities as men and, research suggests, there are no delays to career progression if they work full-time.

There are, however, potential implications for women becoming the majority of doctors within 10 years, as predicted by the Royal College of Physicians’ report Women and medicine: the future. Many more doctors will want career breaks, to work part time, and work within certain specialties. For starters, it will demand more consultants and for NHS work to be organised differently. The NHS needs to take note and plan for it.

There’s less to celebrate when it comes to developing the next generation of medical and academic leaders. Paradoxically, we could find that as the proportion of women increases the leadership talent pool dries up.

It was a salient point made by Professor Dame Carol Black back in 2004 but quickly became lost in the media frenzy. Female dominated professions have a tendency to lose their influence. 

But, let’s be clear about what level of leadership we’re talking about.

There should be no shortage of leaders at clinical service levels. With the investment in the NHS, the prospects for a woman to achieve a consultant post are high.

They form the majority of entrants now embarking on specialist training in the majority of specialties. And women already represent 47% of the very small number of early appointed UK-trained consultants aged between 30 and 34, according to the Royal College of Physicians’ report.

Furthermore, a paper by Oxford’s UK Medical Careers Research Group suggests that women doctors who work full-time have similar career progression to men, even if they’ve had children. This contrasts sharply with other professions such as law or accountancy.

Working part-time is clearly compatible with holding an NHS consultant post in many specialties. And, what’s more, the overall numbers of male doctors are also increasing so there should be plenty of leadership candidates at a local, clinical level.   

The real problem lies with elite roles, such as clinical and medical directors, presidents of royal colleges and leading societies, medical school and deanery leads, even chief executives.

Data is thin apparently but what does exist suggests at these rarified levels women are in short supply.

Women and medicine: the future suggests that women are in the minority on royal college councils, and there is yet to be a female president of a royal surgical college. In 2007, only 12% of all clinical professors on university contracts were women. In 2006, six medical schools had no female professors. And just two out of 34 medical school deans were women.

The picture is no better in primary care with very few women chairing the professional executive committees of PCTs.

It’s in part due to a legacy of male dominance – with women accounting for less than 20% of the entire pool of consultants over 55.

But, it’s also due to the requirements of getting into that elite role. Landing one of these jobs is difficult. It demands single-minded determination and involves long work hours, either attending many meetings and events, or building up a portfolio of research in addition to clinical responsibilities, or both. It’s not for those who want to spend a lot of time with their family.

Unless current trends change, women doctors will continue to work part-time in large numbers; take more time off than male counterparts and focus on particular specialties.

The report suggests that it’s unlikely that most women will make it to the top in proportion to their increased entry into the profession. Senior echelons will be made up of ‘best of the rest’ and the quality of leadership - both medically and academically - could be compromised.  

But, Professor Bhupinder Sandhu, co-chair of the BMA’s equal opportunities committee, disagrees. She doesn’t believe there will be a shortage of female leaders in future and the trends that have seen a dramatic rise in female leadership in her health community in Bristol will play out across the country.

She believes that the quality of leadership among recent luminaries has been high – and points to the Department of Health’s Professor Sally Davies, Professor Parveen Kumar, co-author of Clinical Medicine and former BMA president, Dame Deirdre Hine, chairman of the RSM, and Professor Shelia Hollis, Professor Dame Janet Husband and Professor Dame Carol Black, all former presidents of royal colleges.

“Many other potential women leaders already exist but are held back by the culture and ethos that has historically existed. This is slowly changing and will continue to do so,” she says.

A working group convened by Chief Medical Officer Sir Liam Donaldson, and chaired by Baroness Ruth Deech, to discuss problems faced by women in medicine is due to report before the end of the year. It’s anticipated that it will provide a range of recommendations to improve the availability of part-time training and working, and encouraging leadership development.  

Dr Helen Goodyear, president of the Medical Women’s Federation, believes women doctors need more encouragement to put themselves forward for leadership roles.

She says: “Role models are few and there will be a need for mentorship as well as resolution of the gender pay gap for women to succeed in these areas.

 

RCP report’s recommendations for accommodating more female doctors  

1. The organisational implications of changing workforce patterns and preferences with respect to working hours and specialty choices should be urgently examined so that the effective delivery and continuity of patient care is not compromised.

2. The economic impact of changing work patterns and their interaction with policy initiatives already under way needs to be evaluated.

3. Critical information gaps must be filled with some urgency to gain timely, rigorous and systematic insights into the implications of the new workforce trends.

4. The scope and detailed coverage of workforce planning needs to be extended and its analytic methods upgraded to take full account of the demographic shifts now under way.

5. Individual doctors at each stage in their career - and especially at the point of selecting their preferred specialty - should be provided with far more extensive information, guidance, and feedback on their career choices and aspirations.

We have to keep racism out of revalidation

Dr Raman Lakshman, BAPIO's vice chair of policy - 30th May 2009 5:52 pm

In July 2008, the Chief Medical Officer’s report acknowledged the existence of racism in the NHS, which has damaged individual careers and harmed patients. Now we have licensing to practise and revalidation will be introduced over the next few years. BAPIO understands that these processes are necessary to ensure quality care and patient safety.

However, we are concerned that there is scope for abuse and discrimination and careers and lives are at stake. A large number of ethnic minority doctors and international medical graduates already fear the worst over revalidation.

Revalidation will give a small number of individuals huge power to both support doctors but to also expose incompetencies. This by its very nature needs people, who in the main would be medical directors, to act fairly and in an evidence-based manner and without consideration to matters outside professional competence.

Much work and thought is necessary to make sure this works fairly and without prejudice. Equality and diversity training must be mandatory for all individuals involved in revalidation. The framework for revalidation must be transparent and robust and decisions must be based on multiple evidences rather than on the views of a few individuals.

The GMC, as the regulator, has the responsibility to ensure there is no discrimination by its members. It must ensure it is easy for individuals to complain to it about discriminatory matters, that the threshold for investigating such complaints is not inappropriately high and demonstrate that it takes such complaints seriously and will investigate them thoroughly.

Are we confident all this will be in place?