NHS Lanarkshire – Register of Interests

6 June 2013
NHS Lanarkshire

All members of NHS Lanarkshire staff are provided with a copy of our Standards of Business policy, which requires staff to declare any interests to their line manager.This information is held by individual department managers and is not centrally recorded. To find this information would require each individual manager to manually check their records to identify whether a member of their staff has submitted a register of interest. This information gathering would exceed the charging threshold prescribed in the Regulations made by the Scottish Ministers which constitutes a ground of exemption in terms of Section 12 of the Freedom of Information (Scotland) Act 2002.

However, I can provide the following information, which I hope you will find useful.

NHS Lanarkshire Board
All members of NHS Lanarkshire Board complete a declaration of interest form. Currently, none of the declarations forms from Board members include any association with a pharmaceutical company. The declaration of interests for 2012 is available on the NHS Lanarkshire website at the following link: http://www.nhslanarkshire.org.uk/About/B…. The forms for 2013 will be submitted to the Board later in June.

NHS Lanarkshire Drugs and Therapeutics Committee
All members of our NHS Lanarkshire Drugs and Therapeutics Committee are also required to complete a register of declaration of interest form. This form is required at all meetings where medicines are being contracted for or where decisions are being made regarding which drugs to include in the NHS Lanarkshire formulary. I have attached a copy of the declaration of interest forms for the Area Drug and Therapeutics Committee for the year 2011/12, adjusted to exclude anything which would constitute personal data in respect of which the first condition referred to in Section 38 of the Act is satisfied. The details edited from the document are the signatures of the members of staff.

Hairmyres Hospital
All members of NHS Lanarkshire staff are provided with a copy ofour Standards of Business policy, which requires staff to declare any interests to their line manager. I have attached a copy of the centrally recorded hospitality register for staff at Hairmyres Hospital. There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

Wishaw General Hospital
All members of NHS Lanarkshire staff are provided with a copy of our Standards of Business policy, which requires staff to declare any interests to their line manager. There are currently no entries in the centrally recorded register for staff at Wishaw General Hospital There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

Monklands Hospital
All members of NHS Lanarkshire staff are provided with a copy of our Standards of Business policy, which requires staff to declare any interests to their line manager. There are currently no entries in the centrally recorded register for staff at Monklands Hospital. There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

North Lanarkshire Community Health Partnership
There are currently no entries in the centrally recorded register for staff in North Lanarkshire Community Health Partnership. There may also be declarations of interests made to individual line managers. To find this information would require each manager to manually check their records and this would be exempt under Section 12 of FOISA as detailed above.

South Lanarkshire Community Health Partnership
Declarations of interest for South Lanarkshire Community Health Partnership are recorded in the minutes at each Operating Management Committee meeting. There are currently no entries for staff in South Lanarkshire Community Health Partnership

Yours sincerely
Linda Brownlie
Freedom of Information Officer
NHS Lanarkshire

From: Peter J Gordon
6 June 2013

Dear Fiona Snedden,,
Thank you for your reply under FOI.

I note that NHS Lanarkshire have circulated NHS Lanarkshire ‘Standards of Business policy’

I also note only three submissions to NHS Lanarkshire Hospitality Register (S. Miller – on 2 occasions) (N . Mathias – on 1 occasion). I note on neither occasion was this valued in financial terms.

I would worry, on behalf of the public, and transparency, that the Hospitality Register of NHS Lanarkshire falls short of the Scottish Government position, as stated in: A Common Understanding 2012 – Working Together For Patients. published 2 Nov 2012:http://www.scotland.gov.uk/Publications/…

Would NHS Lanarkshire agree with such concern? FOI enquiries from Scottish NHS Boards on ‘Hospitality Registers’ have been variable but no other Board has so far met (under FOI requests) Scottish Government Guidance. I thought it important to share this evidence.

Yours sincerely,
Peter J Gordon

Note: NHS Lanarkshire has no central register. NHS Lanarkshire repeatedly cites excemption under Section 12 of FOISA.

Full correspondence with NHS Lanarkshire is here:
https://www.whatdotheyknow.com/request/register_of_payments_from_pharma_159#outgoing-279071

Alex Neil, Secretary for Health and Wellbeing considers this matter here:

Alex-Neil-on-Reg-of-Interes

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