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Proxy access request for a child's online record

Last Updated: Thursday, 10 July 2025

This practice is committed to providing patients with access to their health information and online services in a secure and appropriate manner. This policy outlines the principles and processes for granting parents or other legal guardians (hereafter referred to as 'parents') proxy access to the online medical records of children and young people aged under 16. 

The policy is designed to respect the developing confidentiality rights of young people while acknowledging the role parents play in their healthcare. It is based on the principles of Gillick competency and Fraser guidelines, and complies with UK GDPR, the Data Protection Act 2018, and guidance from NHS England and the Royal College of General Practitioners (RCGP). 

 

 

Guiding Principles 

  • Birth up to 11th Birthday: It is presumed that a person with documented parental responsibility will have full proxy access to their child's online services, including the medical record. This access will be automatically restricted on the child's 11th birthday. 

  • 11th to 16th Birthday: This is a transitional period. Proxy access is not granted by default. Any request for new or continued access will be assessed on a case-by-case basis, considering the competency of the young person and their best interests. 

  • Gillick Competency: The central consideration is whether the young person is 'Gillick competent' – that is, they have sufficient understanding and intelligence to enable them to understand fully what is proposed. A Gillick-competent young person has the legal right to consent to or refuse proxy access to their medical record. 

  • Safeguarding: The safety and well-being of the young person is paramount. The practice will refuse or withdraw proxy access if it is believed that granting it could place the young person at risk of physical or emotional harm, or if it could inhibit them from seeking confidential medical advice. 

  • 16th Birthday: On a young person's 16th birthday, they are legally presumed to be competent. All remaining parental proxy access will be automatically switched off. The young person can then register for their own access or formally consent to a proxy of their choice. 

 

The Process for Assessing Proxy Access Requests (Aged 11-15) 

Step 1: Application 

A parent wishing to have proxy access for a child in this age group must complete the practice's "Proxy Access Request Form for a Young Person". The form requires verification of parental responsibility (e.g., birth certificate, court order). 

Step 2: Initial Assessment 

The application will be reviewed by a GP, usually the practice Safeguarding Lead or the young person's Usual GP. The initial assessment considers: 

  • The reason for the request (e.g., managing repeat prescriptions for a long-term condition). 

  • Any known safeguarding concerns or risks. 

Step 3: Competency Assessment 

A clinician (GP or appropriately trained Practice Nurse) must arrange to speak with the young person, without the parent present, to assess their capacity to consent. This conversation will be conducted in a sensitive and age-appropriate manner and will cover: 

  • What online access means and what information a proxy would see. 

  • The young person's own views on their parent having access. 

  • Whether they understand they can say no, or change their mind later. 

  • Whether they feel pressured or coerced into agreeing. 

This assessment and its outcome must be clearly documented in the young person's medical record using the EMIS document called “Parental proxy access competency assessment”. This should be printed out and completed with the young person present, then scanned into the record. 

Step 4: Decision Making 

  • If the young person is deemed Gillick-competent and consents: The practice may grant limited proxy access. Typically, this will be restricted to ordering repeat prescriptions and booking appointments. Access to the full medical record will not usually be granted unless there is a compelling clinical reason and the young person explicitly consents to this level of access. 

  • If the young person is deemed Gillick-competent and refuses consent: The request for proxy access will be denied. The practice will support the young person's decision. The refusal and the competency assessment will be documented. 

  • If the young person is not deemed Gillick-competent: The GP must make a decision in the young person's 'best interests'. This involves weighing the benefits of parental access (e.g., improved management of a complex condition) against the risks (e.g., loss of confidentiality). Access, if granted, should be at the minimum level necessary. 

Step 5: Review 

Any proxy access granted for a young person in this age group must be reviewed annually, or sooner if circumstances change. The review will involve re-assessing the young person's competency and wishes.