Densura broadly welcomes the General Dental Council’s (GDC) consultation on the proposed guidance for decision makers at the Initial Assessment and Assessment stages of the Fitness to Practise (FtP) process, alongside the wider development of the proposed Framework for Professionalism.
As a specialist dental indemnity provider supporting dental professionals across the UK, Densura has extensive experience assisting policyholders through complaints, claims, regulatory investigations and other professional challenges. This experience provides a valuable perspective on the factors that contribute to patient safety, professional risk and public confidence, as well as the impact that regulatory processes can have on the wellbeing of dental professionals.
Our Response to the GDC Consultation
We welcome the GDC’s commitment to improving transparency, consistency and proportionality within the Fitness to Practise process. The publication of guidance for the Initial Assessment and Assessment stages should provide greater clarity for registrants, complainants and other stakeholders regarding how decisions are reached and the thresholds applied when determining whether concerns should progress through the regulatory process.
We are also encouraged by the GDC’s recognition that Fitness to Practise investigations can be experienced as lengthy, complex and stressful. Whilst public protection must remain paramount, it is important to acknowledge that the process itself can have significant professional, personal and psychological consequences for registrants, regardless of the eventual outcome.
In our experience, many dental professionals subject to regulatory scrutiny experience considerable anxiety, loss of confidence and wider impacts on their personal and family lives. We therefore welcome initiatives aimed at reducing unnecessary fear of regulation whilst maintaining effective public protection.
Support for a Proportionate Regulatory Approach
Densura supports regulatory processes that are:
- Transparent and understandable.
- Consistent in application.
- Evidence-based.
- Proportionate to the level of risk presented.
- Focused on public protection.
- Supportive of insight, reflection and remediation where appropriate and consistent with patient safety.
We believe it is important that decision makers continue to distinguish between concerns that genuinely raise questions about impaired fitness to practise and those which may be more appropriately addressed through local complaint procedures, employment processes, education, supervision or remediation.
Timely and proportionate decision-making benefits patients, registrants and the regulatory system as a whole.
The Proposed Framework for Professionalism
Densura supports the GDC’s intention to modernise professional standards through the proposed Framework for Professionalism.
The current Standards for the Dental Team have served the profession well. However, modern dental practice increasingly requires professionals to exercise judgement in complex clinical, ethical and professional situations. We therefore welcome the proposed move towards a framework based on Principles and Expectations, supported by more specific Professional Guidance where required.
We agree that professionalism is demonstrated not only through compliance with standards, but through the application of sound judgement, integrity and ethical decision-making in a wide range of circumstances.
We welcome the proposed Professional Guidance covering:
- Scope of Practice.
- Professional Indemnity and Insurance.
- Reporting Matters to the GDC.
- Advertising.
- Social Media.
- Consent and Shared Decision Making.
In particular, we support the development of dedicated guidance on consent and shared decision-making, given the frequency with which complaints and regulatory concerns arise from misunderstandings regarding communication, expectations and patient involvement in treatment decisions.
Maintaining Clarity in Key Risk Areas
Whilst supporting a more principles-based approach, Densura agrees that sufficient clarity must remain in areas associated with higher levels of professional and regulatory risk.
A successful principles-based framework should empower professional judgement whilst maintaining clear expectations of professional behaviour and public protection.
Understanding the Human Impact of Regulation
One area where Densura believes it can make a unique contribution to this consultation is through our direct experience supporting dental professionals during regulatory investigations.
Densura is distinguished from many indemnity providers by the breadth of support available to policyholders. Whilst expert legal and regulatory advice remains a fundamental component of our protection, our support extends beyond legal representation alone. We recognise that regulatory investigations frequently affect registrants both professionally and personally. The emotional burden of an investigation can be significant and should not be underestimated. As a result, Densura values the importance of pastoral support throughout the regulatory process. Our approach seeks to support individuals holistically, recognising that wellbeing plays an important role in professional resilience and effective engagement with regulatory proceedings.
Importantly, Densura’s regulatory protection extends beyond matters arising solely from clinical treatment. We carry both the privilege and responsibility of professionalism wherever we go. Regulatory concerns do not arise solely from clinical treatment and can stem from a wide range of professional and personal behaviours. We recognise that modern regulatory matters may involve communication, discrimination, sexual misconduct, harassment, social media activity, health concerns, and other non-clinical issues. Densura’s protection has been designed with this reality in mind and, subject to policy terms and conditions, supports members facing a broad spectrum of regulatory challenges. This breadth of protection reflects our understanding that professionalism extends beyond the surgery and into all aspects of professional life.
The dental profession is lucky to benefit from a wide array of professional counselling and support services. In addition, in line with policy terms and conditions, Densura policyholders and their immediate family members have access to a confidential counselling and wellbeing helpline. This service recognises the significant emotional impact that complaints, investigations and regulatory proceedings can have, not only on the professional concerned but also on those closest to them. Our experience demonstrates that early access to appropriate emotional support can help professionals manage the stresses associated with regulatory scrutiny and maintain their wellbeing throughout what can often be a prolonged process.
Conclusion
Densura supports the overall direction of both the proposed Fitness to Practise guidance and the Framework for Professionalism.
We welcome the GDC’s commitment to improving transparency, consistency and proportionality whilst maintaining public protection. We also support the move towards an approach which encourages professional judgement whilst retaining clear expectations and appropriate guidance in higher-risk areas.
Through our experience supporting dental professionals in both clinical and non-clinical regulatory matters, we see first-hand the importance of balancing robust regulation with fairness, compassion and proportionality.
We encourage the GDC to continue developing a regulatory framework that protects patients, supports professionalism, recognises insight and learning, and acknowledges the very real human impact of regulatory investigations.
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