Policies & Governance

Integrated Pain Services Limited (IPS) is committed to protecting the privacy and security of personal information and complying with the UK General Data Protection Regulation, the Data Protection Act 2018 and applicable NHS Information Governance requirements.

IPS provides specialist healthcare services to NHS organisations through an insourced service model. Patient records remain under the control of the relevant NHS Trust or healthcare organisation and clinical services are delivered using approved NHS information systems. IPS clinicians may access patient information where necessary for direct clinical care, but IPS does not create independent patient databases or routinely retain patient-identifiable information outside authorised NHS systems.

IPS may process limited personal information relating to employees, consultants, contractors, suppliers, referrers and business contacts for legitimate operational, contractual, regulatory and employment purposes. Appropriate technical and organisational measures are used to safeguard information, including access controls, device security, staff confidentiality obligations, secure communications and information-governance training.

IPS does not sell personal information. Information is shared only where there is a lawful basis and appropriate safeguards. Individuals have applicable rights under UK GDPR, including access, correction, restriction and objection rights, and may complain to the Information Commissioner's Office.

Approved by Dr Parag Desai, Director · 22 October 2025.

IPS is committed to protecting the privacy, confidentiality, integrity and availability of personal information. Its data-protection framework supports compliance with UK GDPR, the Data Protection Act 2018, the Common Law Duty of Confidentiality, PECR, NHS Data Security and Protection Toolkit requirements and NHS Information Governance standards.

Core principles

• Process personal data lawfully, fairly and transparently.
• Collect only information necessary for defined purposes.
• Maintain accuracy and appropriate retention.
• Protect information through proportionate technical and organisational controls.
• Respect individual rights and demonstrate accountability.

IPS applies data protection by design and default, completes Data Protection Impact Assessments where appropriate, and uses approved NHS infrastructure for clinical activity. Controls include unique user accounts, strong authentication, role-based access, device security, secure networks and secure communications. Personnel are required to maintain confidentiality, follow Caldicott principles and report suspected breaches promptly.

Subject access requests are handled within statutory timescales. Data sharing occurs only where a lawful basis exists and governance requirements are met. Third-party processors must be subject to suitable contracts and due diligence. IPS maintains breach-management, staff-training, records-management, monitoring and audit arrangements.

Policy owner: Director / Data Protection Lead · Approved by Dr Parag Desai, Director · 22 October 2025.

IPS is committed to safeguarding and promoting the welfare, safety, dignity and wellbeing of all patients, including children, young people and adults who may be at risk of abuse or neglect. Safeguarding is the responsibility of every member of staff and IPS maintains a zero-tolerance approach to abuse.

Staff receive safeguarding training appropriate to their role. Recruitment and deployment include appropriate pre-employment checks, professional-registration verification and DBS checks where required. Staff must remain alert to physical, emotional, psychological, sexual and financial abuse, neglect, self-neglect, domestic abuse, exploitation, modern slavery and other forms of harm.

Concerns, disclosures or suspected abuse must be documented and escalated without unnecessary delay through the relevant NHS organisation and local safeguarding arrangements. Where there is immediate risk of serious harm, urgent protective action must be taken, including contacting emergency services where necessary.

IPS cooperates with NHS safeguarding teams, local authorities, safeguarding partnerships, commissioners and statutory agencies. The Directors retain overall responsibility for safeguarding governance and learning.

Signed by Dr Parag R Desai, Director.

IPS is committed to responding to concerns and complaints fairly, promptly, openly and transparently. Feedback from patients, carers, NHS organisations and healthcare professionals is treated as an important source of learning and quality improvement. No person will be disadvantaged for raising a concern.

Complaints may be made verbally or in writing to IPS or, for services delivered on behalf of an NHS organisation, through the relevant NHS Trust complaints process. IPS works collaboratively with the contracting organisation to coordinate responses and avoid duplication.

Complaints are formally acknowledged and registered, allocated for review and investigation, and IPS aims to provide a full response within 30 working days. Serious matters involving patient safety, safeguarding, information governance or professional conduct are escalated through appropriate governance processes.

IPS supports openness, transparency and Duty of Candour. Final responses explain findings, apologies where appropriate, remedial action and further escalation options. Learning is monitored through clinical governance and quality-improvement arrangements.

Approved by Dr Parag Desai, Director · 22 October 2025.

IPS is committed to equality, diversity, inclusion, dignity and respect across its organisation and healthcare services. IPS will not unlawfully discriminate in its role as an employer, engager of healthcare professionals, contractor or healthcare provider.

The policy supports compliance with the Equality Act 2010 and applies across recruitment, engagement, clinical service delivery, workforce management, training, complaints handling and contract management. IPS recognises protected characteristics and seeks to identify and address barriers to healthcare access.

Patient care and accessibility

Patients are treated according to clinical need and without unlawful discrimination. IPS works with NHS partners to provide reasonable adjustments, accessible communication, interpretation support and practical arrangements for disability, sensory, communication, language, cultural, religious and other needs where appropriate.

Workforce and dignity

Recruitment and workforce decisions are based on objective requirements including qualifications, competence, experience, registration and patient-safety considerations. Bullying, harassment, intimidation, discriminatory language, offensive behaviour and victimisation are not tolerated.

Equality-related complaints and incidents are investigated and monitored. Lessons from feedback, complaints, incidents, audits and legislative change inform continuous improvement.

Approved by Dr Parag Desai, Director · 1 October 2025.

The Quality Assurance System defines how IPS aims to ensure clinical services meet high standards of care, patient safety and regulatory compliance while supporting continuous improvement.

Objectives include alignment with clinical guidelines and national standards, monitoring quality and safety, improving patient experience, supporting staff development, managing patient-safety risk and using audit and performance measurement to improve services.

Senior management retains responsibility for quality assurance. IPS supports evidence-based clinical practice, staff induction and CPD, incident reporting and investigation, performance monitoring, internal audit and patient feedback. Quality-improvement planning is informed by audit results, incidents and feedback.

All quality-assurance activities, including audits, training records, incident reports and feedback, are documented and reviewed. The policy is reviewed annually or when changes in regulation, clinical practice or performance require it.

Signed by Dr Parag R Desai and Dr Kaushal K Mishra, Directors.

IPS maintains governance arrangements designed to support legal, regulatory and quality compliance, effective leadership, staff competence and transparent service delivery.

Clinical teams are led by experienced professionals with clear communication and access to clinical guidance. Staff competence is supported by credential verification, performance review, training and continuing professional development. Audit, service evaluation, patient feedback and performance metrics are used to identify improvement opportunities.

Governance arrangements cover DBS and other employment checks, regulatory compliance, secure patient-data handling, statutory requirements for consultants, HMRC and off-payroll compliance, and responsive handling of patient enquiries and complaints.

IPS aims to operate with integrity, accountability and a commitment to continuous improvement across all operational and clinical areas.

Signed by Dr Parag R Desai and Dr Kaushal K Mishra, Directors · Reviewed 12 January 2026.

IPS's Business Continuity Plan is designed to maintain essential services and minimise disruption during significant incidents or emergencies. It covers the safety of staff and patients, continuity of critical functions, timely recovery and regulatory compliance.

Planning includes risk assessment, business-impact analysis, preventive controls, contingency arrangements, recovery strategies and communication protocols. Potential disruptions include IT failures, workforce absence, pandemics, natural events and other operational emergencies.

The plan includes emergency response, IT disaster recovery, alternative working arrangements, stakeholder communications and staff training. Drills and exercises are used to test arrangements and identify improvements. The plan is reviewed annually and following significant changes or incidents.

Business Continuity Lead: Dr Parag R Desai · Signed by the Directors · Reviewed 12 January 2026.

IPS is committed to transparency, integrity and accountability. The Whistleblowing Policy provides a confidential route for employees, contractors, suppliers and other stakeholders to raise concerns about unethical, illegal or unsafe practices without fear of retaliation.

Concerns may include financial irregularities, fraud, breaches of legal or regulatory obligations, health and safety risks, environmental damage, unethical or unprofessional conduct, or other actions that could harm patients, the public or the organisation.

Concerns may be raised with a line manager or directly with the designated Whistleblowing Officer. Reports are assessed promptly and may lead to formal investigation or referral. Investigations are conducted fairly and objectively, with confidentiality protected as far as reasonably possible.

Good-faith whistleblowers are protected from retaliation or victimisation. Deliberately false or malicious allegations may be subject to appropriate action.

Whistleblowing contact: integratedpainservices@outlook.com · Signed by the Directors.

IPS provides UK-based specialist healthcare services and does not manufacture goods, import products or operate a traditional supply chain. Its assessed exposure to modern-slavery risks through supply chains is therefore limited, while the organisation remains vigilant to risks in its own operations and professional-service relationships.

Due diligence focuses on lawful right-to-work checks, fair and transparent recruitment, voluntary employment, written contracts, lawful pay and access to whistleblowing procedures. External professional service providers and contractors are expected to comply with applicable employment and human-rights legislation.

IPS monitors concerns raised through safeguarding and whistleblowing arrangements, reviews relevant policies and procedures, and includes awareness of human-rights abuse and reporting routes within staff training.

Signed by Dr Parag R Desai and Dr Kaushal K Mishra, Directors · 12 February 2026.