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General Dental Council v Savery [2011] EWHC 3011 (Admin)

Regulatory – confidentiality – disclosure – human rights

It was not necessary for the General Dental Council to seek a declaration from the court that it could pass patient information to its investigation committee and its fitness to practice panel, even where the patients had not consented to such a use.  
28 November 2011
Administrative Court
Sales J
(i) The General Dental Council (GDC) sought a declaration that it could pass patient information to its investigation committee. An insurance company (C) had told the GDC that it suspected that claims by a number of patients in relation to a single dentist (D) were made fraudulently. C passed the relevant patient records to the GDC in varying forms of anonymity. The GDC requested consent from the patients involved but most refused whilst some did not respond. D objected to the GDC’s proposed passing of the patient’s information to the GDC’s investigation committee.   

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