A letter that the Scottish Parliament felt unable to publish

With careful thought, and backed with full supporting evidence,  I sent the following letter of the 2nd February 2016 to support my petition for a Sunshine Act for Scotland.

The Senior Clerk of the Parliamentary Committee was of the view that this letter did not comply with the Scottish Parliament’s policy on the treatment of written evidence. I was therefore asked to redact significant sections of the letter.

After considerable communications to and fro, I replied as per this e-mail of the 3rd March 2016:

I fully respect the right of the Scottish Parliament to determine 
what it publishes.

I feel very strongly that my letter without the highlighted text 
merely reiterates what I have already said, and fails to provide 
the evidence that I have repeatedly been asked for.

So my position is that I do not wish to amend my letter of the 
1st February on PE1493.

My petition has since been closed. I therefore have decided to publish my letter to the Scottish Parliament in full along with supporting evidence. I have had professional advice that what is contained in this letter is not defamatory as it is based on veritas and has full supporting evidence:

Dear Mr McMahon
Petition PE01493: A Sunshine Act for Scotland

I realise that the Committee must receive a great amount of correspondence however I hope that the committee might agree that what follows is extremely important when considering PE1493.

Since I last wrote to the committee I attended, for accredited continuing medical education, the Royal College of Psychiatrists in Scotland Winter Meeting held on the 29th January 2016. It is this that has compelled me to write this update as it demonstrates beyond doubt that lack of transparency around financial conflicts of interest remains a serious issue. An issue with implications for both patient safety and healthcare budgets. It also demonstrates that Government action is the only way to address this.

The full powerpoint presentations of this Accredited meeting for 
Continuing Professional Development can be accessed here - but only
for members of the Royal College of Psychiatrists. 

I am a member of the Royal College of Psychiatrists and I am of the 
view, as a scientist, that these lectures should be available to all 
and not just to members.

One speaker highlighted the increase in prescribing costs in her health board area which was due to the high prescribing rate of a new antipsychotic injection, palperidone depot (XEPLION®). The next speaker demonstrated both the inferior effectiveness of this drug when compared to existing (far cheaper) depot medications and the perception amongst Scottish psychiatrists that it was more effective. Below you will see the flyer sent to mental health professionals in Scotland when this drug was launched:

002 Financial Conflicts of Interest, Scottish Psychiatry

I have highlighted one of the paid speakers, Dr Mark Taylor, because he also spoke at this week’s meeting where he reminded us that he was Chair of SIGN Guideline 131: The Management of Schizophrenia, which was published in March 2013.

At this week’s meeting Dr Taylor presented his declarations as follows: “Fees/hospitality: Lundbeck; Janssen, Otsuka; Roche; Sunovion”.

Dr Taylor commented on these declarations with the statement that “you are either abstinent or promiscuous when it comes to industry. Well you can see which side I am on”. Audience laughter followed.

The general question that arises is whether an influential professional such as a Chair of National Guidelines might earn more from the pharmaceutical industry than in his or her role as a healthcare professional? At present it is impossible for anyone to establish the scale of competing financial interests. To remind the committee the following avenues are not illuminating:

1. Royal College of Psychiatrists. This week’s meeting did not appear on the college database. In any case this database is neither searchable nor does it include specific details of payments and dates

2. NHS Boards. The committee has already established that, across Scotland, HDL62 is not being followed.

3. SIGN guidelines. The committee is aware of significant governance failings particularly in comparison with NICE which includes details of financial sums paid and associated dates.

4. Discussions with Senior Managers in NHS Scotland relating to the General Medical Council’s expected level of transparency has brought forth written responses describing my interest as “highly unusual” and “offensive and unprofessional”

5. The forthcoming ABPI register allows any professional to opt out of inclusion.

It is also worth repeating that the information provided to the public consultation on this petition failed to highlight most of the issues identified in points 1 to 5 above.

In terms of cost both to the public purse and the individual patient the Government’s stated wish for a “robust, transparent and proportionate” response would be fulfilled if a single, searchable, open register of financial conflicts of interest that has a statutory basis were to be introduced


My view is that we all have conflicts of interest.

Science however cannot ignore financial conflicts of interest.

We can find no record

The above was a recent statement by the Scottish Government in response to my petition for a Sunshine Act.

This statement by the Scottish Government reminded me of why so many of my healthcare colleagues would choose not to express any concern about lack of transparency

My experience in asking, as fairly and politely as I can, about the governance of: Good Medical Practice” (General Medical Council); NHS Scotland (HDL62) and Royal College of Psychiatrists (CR148) has met with calls of being “unprofessional”.

Annexe A, GMCHDL-62CR148 cover

It was disappointing how many colleagues used the term “unprofessional” when asked about governance of the declarations of financial conflicts of interest.

“PULSE Live is heading to Scotland”: the Corn Exchange

My wife is a GP working in NHS Scotland and was recently invited to the “PULSE LIVE 2015″ educational conference to be held in Edinburgh on the 19 May 2015:Pulse Live 1

This educational conference is to be held in Edinburgh’s Italianate and historical CORN EXCHANGE. General Practitioners can register for a free place and 7 CPD hours are accredited:Pulse Live 2

In my earlier career I trained as a Landscape Architect at Edinburgh University and was awarded the Scottish Chapter prize. This will explain to you why old buildings and designed landscapes interest me. The Corn Exchange was where traders brought grain to sell. It was a place of barter: where goods were exchanged for money:Former corn exchange

With this in mind it is worth looking at the PULSE LIVE 2015 programme and noting that a significant number of the educational talks are sponsored by the pharmaceutical industry or other commercial enterprises. The speakers are mostly from NHS Scotland and it is fair to reasonably conclude that they will receive honoraria for giving their talks:Dr Douglas Elder, Bayer HealthCare, 2015 Dr Paul Newman, Johnson & Johnson, 2015 Dr Richard Watson, Lundbeck, 2015 Dr Tom Fardon, Pfizer, 2015 LUTS, 2015, Pulse Live, Astellas

My interest in this area relates to my wish to consider the ethics of medical practice. In this instance, my interest is in public transparency of any financial transactions between healthcare workers/academics and wider commerce.

I should make it very clear: I understand that conflicts of interest are part of life.

Over a few years I have collected the invites to NHS doctors to attend pharmaceutical sponsored education. These invites are collected here and demonstrate that financial sponsorship by the pharmaceutical industry (or commercial enterprises), as included in PULSE Live 2015, is generally the norm. Dr McCartney has considered this in her BMJ Column of last week: Forever indebted to pharma—doctors must take control of our own education:009b

My petition to the Scottish Government for A Sunshine Act is a request that transparency surrounding (non NHS) financial payments made to all those involved in healthcare (including academics and all those involved in medical education) to be a requirement by statute. In terms of the United Kingdom, I have suggested that Scotland might lead the way on this. America and France have introduced a Sunshine Act.

Open and transparent from omphalos on Vimeo.

NHS Scotland has failed (in my view, most miserably) to follow Scottish Government guidance HDL 62. This Government Circular was issued to all NHS Scotland Chief Executives over a decade ago. The Scottish Government has, since my petition which was based on my research, accepted widespread failure across NHS Scotland to follow HDL 62.


The Cabinet Secretary for Health, Wellbeing and Sport, Shona Robison MSP, wrote recently to the Convener of the Scottish Parliament Petitions Committee. Shona Robison, 24-4-2015

The Cabinet Secretary for Health, Wellbeing and Sport, asks for a “broader view” on an issue that the Scottish Government agree is “important”. The Cabinet Minister will be attending PULSE Live 2015 for the “Big Interview”:Pulse Live, Cabinet Minister for Health, May 2015

Perhaps the Cabinet Secretary for Health, Wellbeing and Sport, will look upwards to the roof of the Corn Exchange which is celebrated for its “massive single-span”. Sponsored Medical Education also celebrates a massive span across NHS Scotland. Please do not be fooled into thinking that this, like the Corn Exchange and the bartering it once housed, may be a thing of the past.Former corn exchange

So go on, if you dare, be like me and shout about this from the roof-top! If we reach for the sunshine perhaps we might all be a little healthier. Sunshine on Leith!0094638392057_600

“appropriate” and “correct” concerns in NHS Scotland

After sending an update of my petition for a Sunshine Act to the Chief Executive Officer of NHS Forth Valley I received this reply. Whilst I was employed by NHS Forth Valley I raised concerns that HDL 62, the Scottish Government Circular sent to all Chief Executives in NHS Scotland, was not being followed.


Two aspects of this letter from the Chief Executive Officer for NHS Forth Valley are worth further consideration:

(1) Transparency:

When I was an employee of NHS Forth Valley I was formally written to by Dr Rhona Morrison, Associate Medical Director. In this letter from the Associate Medical Director, which was both unsigned and undated, I was described as “unprofessional” and “offensive” for raising concerns that NHS Forth Valley was not following extant Scottish Government guidance on transparency regarding declarations of interest.

This letter confirmed that I would be “invited” to  an “informal” meeting by the Associate Medical Director’s immediate peers.

My experience of this “informal” meeting was that my character, reputation and probity were robustly questioned by the Medical Director, Dr Peter Murdoch, and the General Manager, Mrs Kathy O’Neill. This meeting was not minuted. This meeting left me distressed.

A number of weeks after this meeting I resigned from NHS Forth Valley. On my resignation I had this  feedback from those who I had cared for and worked with

(2) Freedom to Speak Up:

The Chief Executive Officer reinforces in her letter the “importance of a culture of openness and candour”. However, Jane Grant, the Chief Executive Officer for NHS Forth Valley then goes on to give qualifications: that any concerns raised should be “appropriate” and “correct”.

Whistleblowing in NHS Scotland from omphalos on Vimeo.

To conclude: it appears to me that there are still significant barriers to raising concerns in NHS Scotland. If you click on the image below you can read the full review by Sir Robert Francis. I have selected one particular recommendation which I think will require a different mindset to that suggested in the letter from Jane Grant, Chief Executive Officer for NHS Forth Valley:


Update: November 2016:
On the 22 March 2016 the following petition was lodged by 
Pete Gregson with the Scottish Parliament: PE01605: Whistleblowing 
in the NHS - a safer way to report mismanagement and bullying.

On the 24th November 2016 the Public Petitions Committee considered 
all the submissions requested as part of evidence gathering. 
This included a letter from the Chief Executive Officer for 
NHS Forth Valley. This letter was commented on in particular 
by Angus MacDonald, MSP:


A Sunshine Act for Scotland: the petitioner’s views

A pdf version of the following letter can be accessed here on the Scottish parliament website.

Sunday, 15 March 2015

To: Public Petitions Committee
The Scottish Parliament

Dear Public Petitions Committee
Scottish Parliament Public Petition PE1493 on a Sunshine Act for Scotland
Thank you for informing me that my petition is to be considered by the Public Petitions Committee at its meeting on Tuesday 31st March 2015.

You suggested that I might like to make a written submission for the meeting of the Committee informing me that this would be published online with the other evidence that the Committee have gathered for Petition PE1493. Since my last submission to the committee I have received a letter from the Scottish Government dated 24th February 2015 [included below] which asks my views as petitioner on a number of specific matters.  With the permission of Gordon Clark, Scottish Government, I thought it would be sensible to offer my views in a single letter copied to all.

My preference has always been to keep letters to the committee to one page, but unfortunately on this occasion, given the number of questions asked by the Scottish Government, this letter requires to be longer. I will begin this letter with a current summary of my position as petitioner for a Sunshine Act and then, in the second half of my letter, do my best to answer the questions asked by the Scottish Government.

My summary position as petitioner for a Sunshine Act:
Gathering evidence and necessary research to support this petition has led me to conclude that the pharmaceutical industry has had significant control within Scotland’s health sector and that this has been met with very little opposition or even analysis.

Open and transparent from omphalos on Vimeo.


The Scottish Government has since confirmed that across Scotland its own guidance, HDL 62, has been widely ignored.


The Scottish Government position states that we should consider “existing legislation”.

The Scottish Government are of the view that we have two safeguards: (1) professional bodies and (2) “the significant progress towards voluntary registers by the pharmaceutical industry.”

Considering these in turn:

Firstly, regarding professional and regulatory bodies:
Niall Dickson, the Chief Executive Officer for the General Medical Council (GMC), the professional regulatory body for doctors, has recently stated that “Parliament has not given us powers”. This was the official GMC response to Fiona Godlee, Editor in Chief of the BMJ who stated in her recent BMJ editorial that “the profession must take the lead to protect patients and maintain public trust. The GMC should act, and a public register of UK doctors’ financial interests is long overdue.”

I have been in communication with the Royal College of Psychiatrists, the additional “regulatory body” of which I am a member. This recent communication, with the Royal College of Psychiatrists, relevant to this petition, can be read here. In summary the Royal College of Psychiatrists guidance again refers to local registers, as in HDL 62, which we know are not being maintained.

Secondly, the “significant progress towards voluntary registers by the pharmaceutical industry.”  (Scot Gov statement)
It is the case that the Association of British Pharmaceutical Industries (ABPI) have led on setting up what they have termed as a “Central Platform”. From 2016, this platform will gather individual payments and record these in an open, central, searchable database. However, it is the case that any healthcare professional can opt-out of any disclosure of any financial payments made to them on this platform.

The Scottish Government, in a letter to me dated 24th February 2015, [see annexe] asked my views as petitioner on nine separate points.  What follows are my responses as given under each Scottish Government question:

(1) Is your primary concern around ensuring appropriate prescribing?
This is my primary concern.

This is a longstanding concern based on the ethical principle primum non nocere “above all first do no harm”. My view, as petitioner, is that appropriate prescribing must try to achieve maximum benefit and minimum harm: a ratio crucial at both individual and population level.  Evidence has repeatedly revealed that harm and/or risks associated with prescribing may emerge only after the pharmaceutical industry has made its money. My view, as petitioner, is that “appropriate prescribing” in Scotland should follow evidence-based science that is free from financial conflicts of interest. Prescribing should be based upon scientific objectivity alone. Prescribing should not be determined by market forces.

One of my original motivations for raising this petition for a Sunshine Act was an appreciation that pharmaceutical companies use paid speakers, consultants and researchers to promote the off-label use of drugs in Scotland:


This is just one example of evidence that this happening. I covered a range of other examples in my original submission to the committee:

 (2) Who should have responsibility for keeping and updating information on payments (including payments in kind) received?
I would like to see an independent body that is set up to maintain a central, single, open, searchable register that is updated on a planned and scheduled basis and which is tied to professional accountability and governance. Such a register should include not just doctors, but pharmacists, academics, nurses, allied health professionals and indeed advisors to charities.

(3) What should happen in the event of non-compliance?
It is my view that any system that is developed to replace HDL 62 must include meaningful sanctions to be used in the event of non-compliance. There is always the potential for litigation following any harms caused.

From a practical point of view, enforcement would be likely to involve a number of different approaches. Failure to follow legislation may involve regulatory bodies. For example, in the case of doctors this would be with the General Medical Council.


“Non compliance” also has a dimension that may be beyond the employed individual. At least two NHS Boards in Scotland, NHS Lothian and NHS Forth Valley, have confirmed that they have zero budget to support medical education. The financial support of this education is thus solely through commercial arrangements. The details of this are covered here.

(4) Which professions and groups should be covered?
This should include not just doctors (both at primary and secondary care), but also pharmacists, nurses, academics, allied health professionals and indeed advisors to charities. It should also apply to any commissioners of healthcare services in Scotland including all those involved in improvement work.

As petitioner, part of my research confirmed in November 2013 that 44 separate Scottish Intercollegiate Guidelines (SIGN) guidelines had no records of declarations of interest. This concerns me greatly as does the limited governance of the experts involved in the Scottish Medicines Consortium.


(5) Who/what should be covered by the terms ‘industry and commerce’?
The approach taken in France to legislation appears to be a reasonable model. The USA has also introduced Sunshine legislation. As petitioner, I would suggest that there is much to be learned from the approaches taken in France and the USA.

“Industry and commerce” might include: the pharmaceutical industry; device and implement manufacturers; and commercial enterprises involved in diagnostics, nutritional supplements and digital technologies. As petitioner, I would also suggest that academics, patient groups and charities are included.  In France, disclosure of financial support to patient organisations has been a legal obligation since 2009.

(6) Should there be a threshold for providing information on payments (including payments in kind) and if so what should that be?
I think this a matter that should be open to consultation. I would suggest a similar framework to that used by this voluntary database:

who pays this doctor

(7) If registers of payments (including payments in kind) were established what should the status of these registers be?
A national register requires legislation to be put in place to make it meaningful, robust and properly transparent. Timescales for submissions would be clearly defined. This register should be open to all with a link placed obviously on each NHS Board homepage.

All medical educational conferences held in Scotland should have a homepage link to this single, open, searchable database. Thus duplication of recording would no longer be an issue.


(8) Do you have experience of concerns raised by patients about these issues that you can share?
My experience of patients is that they trust NHS staff to be acting solely in their best interests. Sadly evidence demonstrates that this is not the case:


(9) Generally, what is your view on what a robust, transparent and proportionate response would look like fit for 2015 and beyond?
I hope that I have given an indication of my perspective on this. I am most grateful to the Scottish Government for seeking my views as petitioner.  I wondered if it might be helpful to conclude this letter with a range of views of some others who have also considered this area:

004Dr McCartney, General practitioner in Glasgow, BMJ Columnist, Broadcaster and Medical Author




Closing statement:
When politicians are held to higher standards than doctors, it is my view that it is time for tighter regulation of conflicts of interest in healthcare in Scotland.

Scottish Government guidance, HDL 62, has relied on self regulation and this clearly has not worked.

Moves by the drug industry are welcome but will encounter the same issues as HDL 62.

As a scientist as well as a student of humanities, my view is that Scotland’s wellbeing, reputation and worldwide standing would all benefit from taking a leading approach in this area.

I hope this update is of some assistance to the Committee ahead of the 31st March 2015.

Yours sincerely,

 Peter signature

Full details of all evidence I have collected for this petition, including my writings, publications and films, can be accessed from this one page.

Letter to the Petitioner from Gordon Clark, The Scottish Government, Healthcare Quality and Strategy Directorate, Pharmacy and Medicines Division.

Letter from Gordon Clark, 25 Feb 2015

NHS Ayrshire and Arran: Register of Interests for staff – “discussions are ongoing”

Sent: 20 February 2015 14:01
Subject: NHS A&A response to – FOI – Compliance with HDL (2003) 62 – our ref 528/2014

Dear Dr Gordon,
Again, please accept my apologies for any inconvenience caused by the delay in responding to your enquiry. Leave commitments of the specialised staff tasked with responding to your request and other events outwith our control have lead to the delay in responding to your request timeously.

Our response in 2013 stated that the organisation was working on compiling a register of interests and register of gifts/hospitality to encompass all staff which would also include payments from pharmaceutical companies.  At the time of your request we already had a ‘declaration of interests’ register for the Area and Drugs Therapeutics Committee to ensure any conflict of interests were registered for decision making around drugs. We had advised at the time of your request that the ‘the Area and Drugs Therapeutics Committee’ were hoping to publish this register in the future. Please see our full 2013 response below:

Discussions are ongoing to create a register to encompass the whole organisation in line with the guidance – A Common Understanding 2012 working together for patients -guidance on joint working between NHSScotland and the Pharmaceutical Industry.

The attached ‘declaration of interests’ register relates to the Area and Drugs Therapeutics Committee, its sub groups and anyone submitting a guideline. We are in the process of updating our Model Publication Scheme to include this register which will be published on our public website.

Since sending our response a decision has been taken not to publish this register.  Please accept my apologies for not fulfilling the assurance to publish the Area and Drugs Therapeutics Committee ‘declaration of interests’ register. However, this was superseded by the register of interest for all staff and the requirement under the Public Services Reform (Scotland) Act 2010.

Section C ‘Standards of Business Conduct’ within the Code of Corporate Governance paragraph. 3.3 states “Where there is an interest, hospitality or relevant outside employment is declared to a manager, they must record that declaration in the employee’s personal file together with any instructions issued to the member of staff in relation to the declaration. This information must also be provided to the Corporate Business Manager to be recorded as part of the Board’s declaration of interests and gifts.”  This register is held by the Corporate Business Manager who is responsible for keeping and maintaining it.  From November 2014 Section C is also included within any contractual paper work for new employees to the organisation. The Chief Executive has also circulated communication to ask employees to ensure they are notifying their line manager and the Corporate Business Manager of any declarations.

We are not at present planning to publish this on our website. As, under part three of the Public Services Reform (Scotland) Act 2010 (the Act), we have a duty to provide information on hospitality and entertainment. This includes any gifts, meals, parties, reception, tickets for or invitations to public, sporting, cultural or other events or other similar benefits accorded by a public body to its own members, employees or third parties for whatever reason. A threshold of £25 for “one off” gifts or benefits has been set as reasonable for this purpose, provided that the gifts or benefits in question are not regular or recurring. If a different threshold is adopted it should be set out in the statement of expenditure.

This information is routinely published as a requirement of the Act as soon as reasonably practical after the year-end. Please follow the link http://www.nhsaaa.net/publications/public-services-reform-(scotland)-act-2010.aspx. Or go to our website, http://www.nhsaaa.net/ click on the ‘publications’ button and select ‘a’ and scroll down to ‘Accounts/financial information.

I trust this response is helpful. However, under the Freedom of Information (Scotland) Act 2002 if you are dissatisfied with our response you are entitled to request a review. A request for a review must be made in writing to Mrs Jillian Neilson, Head of Information Governance, NHS Ayrshire & Arran, 14 Lister Street, University Hospital Crosshouse, Kilmarnock, KA2 0BB or email InformationGovernance@aapct.scot.nhs.uk, no later than 40 working days from 23 February 2015. You must provide your name, an address for correspondence, details of your original request and say why you want a review. If our decision is unchanged following a review and you remain dissatisfied with this, you then have the right to make a formal appeal to the Scottish Information Commissioner.

Please do not hesitate to contact me should you require any further advice or assistance.

Kind regards,

Freedom of Information Officer
Communications dept
28a Lister Street
University Hospital Crosshouse

Email: foi@aaaht.scot.nhs.uk


Previous blog posts on Ayrshire & Arran Register of Interests:



NHS Greater Glasgow – Register of Interest

As petitioner for the Sunshine Act I undertook Freedom of Information Requests to all 22 NHS Boards in Scotland to establish if Boards had  Registers of Interest for ALL staff. The findings revealed that most Boards did not.


The above guidance, HDL 62, was issued by the Scottish Government in 2003:

“Chief Executives are asked to establish a register of interest for all NHS employees and Primary Care contractors”. 

In reply (June 2013) to a Freedom of Information Request NHS Greater Glasgow provided the following Register of Interests for all staff (if you click on link, top right “download original attachment” you will get the Excel spreadsheet). There are a total of 64 entries (from 27 employees) covering a five year period (the first entry is dated 10-9-2008, and the last entry 15-5-2013).

Here is a screenshot of part of the Register for NHS Greater Glasgow:


NHS Greater Glasgow is the largest health board in the United Kingdom, serving 1.2 million people and employing 38,000 staff.

The above Register of Interest supplied by NHS Greater Glasgow covers 5 years and has entries for just 27 separate employees. One has to wonder how comprehensive and  how representative this register of Interests actually is?

The former, Cabinet Minister for Health and Wellbeing has confirmed in writing what HDL 62 “made clear” of all Scottish Health Boards:


The Sunday Herald, published in Glasgow, gave this recent Editorial:





NHS Lothian – Register for all staff

As petitioner for the Sunshine Act I undertook Freedom of Information Requests to all 22 NHS Boards in Scotland to establish if Boards had  Registers of Interest for ALL staff. The findings revealed that most Boards did not.


The above guidance, HDL 62, was issued by the Scottish Government in 2003:

“Chief Executives are asked to establish a register of interest for all NHS employees and Primary Care contractors”. 

NHS Lothian has  NO Register of Interests for all staff. This was confirmed in this Freedom of Information reply dated 6th May 2013:


The former Cabinet Minister for Health & Wellbeing, Alex Neil, referring to HDL 62 “made it clear” the responsibilities enshrined in it to all Health Boards since it was issued in 2003 (this in the letter below, dated 31st October 2013):


This week Professor David Taylor is giving an “educational” talk to NHS Lothian. The Continuing Professional Development (“CPD”) talk he gave earlier this year to NHS Forth Valley was on the basis of a paid honorarium. It was sponsored by the Pharmaceutical Company Janssen. As NHS Lothian have NO Register of Interests this financially sponsored education will have no formal record. It is important to note that Professor David Taylor may be talking about his “prescribing guidelines”.

The British Medical Journal have recently covered this issue (19th July 2014):


The Editor of the Sunday Herald shares the concerns of the British Medical Journal:



NHS Lanarkshire – Register of Interest for all staff

As petitioner for the Sunshine Act I undertook Freedom of Information Requests to all 22 NHS Boards in Scotland to establish if Boards had  Registers of Interest for ALL staff. The findings revealed that most Boards did not.


The above guidance, HDL 62, was issued by the Scottish Government in 2003:

“Chief Executives are asked to establish a register of interest for all NHS employees and Primary Care contractors”. 

The former Cabinet Minister for Health & Wellbeing, Alex Neil, confirmed this in a letter dated 31st October 2013:


The British Medical Journal have recently covered this issue (19th July 2014):


The Editor of the Sunday Herald shares the concerns of the British Medical Journal:


The Medical Director for NHS Lanarkshire, Dr Iain Wallace, stated in writing on the 15th May 2014:

 “I can advise that it is not the intention of NHS Lanarkshire to publish a register of interests for all staff”


NHS Forth Valley – Hospitality Register 2013/2014

As petitioner for the Sunshine Act I undertook Freedom of Information Requests to all 22 NHS Boards in Scotland to establish if Boards had  Registers of Interest for ALL staff. The findings revealed that most Boards did not.

NHS Forth Valley has kept Registers of Interest from 2010 to current date. Following persistent enquiries by myself regarding public transparency these have recently been made available on-line.

This accords with the guidance in HDL 62, issued 2003: “Chief Executives are asked to establish a register of interest for all NHS employees and Primary Care contractors”. For this, and for taking the extra step of ensuring public access to the registers, NHS Forth Valley are to be congratulated.

This blog post encourages you to consider the contents of NHS Forth Valley’s Hospitality Register for 2013 to 2014 as an illustration of the involvement of sponsorship of Continuing Professional Development (“CPD”).

There is now robust research evidence that sponsorship influences clinical practice, no matter how much individual healthcare workers claim to be immune from such influence.


We are all aware of straightened public sector budgets and so it is perhaps not surprising that external sources of finance are welcomed. In fact it would appear that:

“Yes, you’re correct – there is no NHS Forth Valley budget that pays for educational meetings held in the Centre.” Director of Medical Education for NHS Forth Valley, 25th February 2014

I would argue that this is a false economy adding to the risk of over-medicalisation and subsequent harm.

(the following is an example, showing just one page out of seven, from NHS Forth Valley’s Hospitality Register 2013-2014)

*Note, as of last time of checking, 10 December 2014, the current Register has not been updated since I left employment with NHS Forth Valley. This means that there has had no entries in 4 months.