Health professionals: administration

The information on this page is intended for healthcare professionals. You can find information for trans patients on our How to access medical transition page.

Updating patient records

A trans patient is able to change their name and/or title using the same routes as any other patient. There is no need for proof of a legal change to change a patient’s name on their medical record, so you do not need to ask for a deed poll.

Patients can change their sex marker on their records at any point and do not need to have accessed any transition related healthcare in order to do so. Restrictions on changing sex marker currently apply to under 18s in England (more information is available on the PCSE website).

You can find advice relating to updating a patient’s personal details, such as their name, gender, or title:

• for England, on the PCSE website. You can contact the PCSE for further advice using the PCSE enquiry form.
• for Northern Ireland, we are not aware of any published guidance on this subject.
• for Scotland, on the NHS National Services Scotland website and in this document for staff in Greater Glasgow and Clyde.
• for Wales, on the Umbrella Cymru website.

There is also detailed information about updating a patient’s record on the GMC Trans Ethical Hub.

Many non-binary people use the title Mx, rather than Mr or Ms. Ensure that you use the correct title for trans people when you send them correspondence or on electronic screens in the waiting room. If you’re not sure which title a patient uses, just ask them.

Changing sex marker will result in a new medical record with a new NHS number – work with the patient to help them understand the benefits of migrating their previous medical history into their new record. It is useful to explain to them that the NHS record system is currently very binary and it may be worth aligning their patient record with the cancer screening programmes. Make a record of the conversation and outcomes. You can read more about cancer screening tests in the next section.

You can find information for trans patients to help educate them about the implications of this change on invitations to screening programmes on our Patient information page.

Population screening

Trans patients are eligible for screening tests based on their anatomy, so for example:

• any patient with breast tissue is eligible for breast screening
• any patient with a cervix is eligible for cervical screening

However, many trans patients will not automatically be sent an invitation to the screening they are eligible for:

• in England, many trans patients will not receive an automatic invitation – more information on GOV.UK
• in Northern Ireland, many patients will not receive an automatic invitation – more information on the HSC Public Health Agency website
• in Scotland, trans patients who changed their CHI number after 14th June 2015 should be automatically be invited to the correct screening tests. Patients whose CHI number was changes before this date will not be automatically invited. More information can be found on NHS Inform.
• in Wales, many trans patients will not receive an automatic invitation – more information on the Public Health Wales website

It is good practice to maintain a list of eligible trans patients who will not routinely be invited for screening and to flag patient records when screening is due.

Be aware that trans patients are at particular risk of not attending cancer screening, due to a number of barriers. These barriers can include gender dysphoria and fear of transphobia or of being misgendered.

Cervical screening

There are administrative considerations around cervical screening for trans people:

• Patients who have a cervix: Only patients marked as ‘female’ on their medical records are automatically invited for cervical smears. Patients who do not have ‘female’ on their medical records but who have a cervix can be opted-in to automatic invitations by submitting an opt-in request to CSAS. As the ability to do opt-in was not available in the past, many trans men and non-binary people that have a cervix will not currently be receiving automatic invitations, and should be offered the opportunity to opt-in. Patients who are not currently opted-in are still eligible for screening and should be given a reminder to have a cervical smear. Use the clinical data section on the HMR101 form to notify the lab that the patient has a cervix. The lab won’t release results directly to the patient, so make sure you follow up with the patient once the result is available. Be aware that not all trans men and non-binary people will have a cervix.
• Patients without a cervix: If a patient has asked to be re-registered as female, including trans women or non-binary people who have asked to be registered as female, you may need to take additional actions related to cervical screening. Once the re-registration is complete, the cervical screening team should normally contact the practice to confirm that the patient doesn’t have a cervix. If they don’t, submit a cease request to CSAS. Be mindful that, although it is rare, trans women and non-binary people who have a prostate may be at risk of prostate cancer.

More information about opt-in and cease requests can be found on the NHS Cervical Screening Management Programme site.

Breast screening

Be aware that any patients with breasts or breast tissue should be invited for breast cancer screening if they are 50 or older. This will include trans women who have started oestrogen treatment and may include some trans men and non-binary people.

Confidentiality

The General Medical Council have detailed information about confidentiality considerations for trans patients on their Trans Healthcare Ethical Hub, in which they advise:

You should treat the gender status or history of transgender and gender diverse people with the same confidentiality as any other sensitive information. 

If you are communicating with other health professionals, you don’t need to disclose a patient’s gender history unless it’s directly relevant to their condition or likely treatment. If you are sharing this information, keep disclosures to the minimum you need for the purpose and inform your patient why it’s clinically important or necessary.

GDPR / Data Protection Act

In addition to your normal responsibilities to your patients under GDPR, you should bear in mind the following considerations:

• You have a responsibility under the principle of accuracy to ensure that patients’ information is accurate and up-to-date. This means that you need to patient’s update names, titles, and gender promptly when they have changed, particularly if you are notified by the patient, as patients have a right to rectification under GDPR. You can find information about how to handle these requests in the previous section on updating patient records.
• Information about a patient’s gender identity can involve special category data, particularly if it reveals or could be used to make inferences about specific details of their health status or medical care, such as medical treatments or diagnoses related to trans healthcare. Processing special category data has specific legal implications and under GDPR can only be done in specific circumstances.

You can read about GP surgery data controller responsibilities under GDPR on the BMA website.

Gender Recognition Act

In addition to these considerations, you should also bear in mind your responsibilities under the Gender Recognition Act 2004.

Section 22 of the GRA makes it a criminal offence to disclose information acquired in a official capacity about ‘protected information’, except under certain conditions.

Protected information includes information about a person’s gender before they received a Gender Recognition Certificate, or about an application for a GRC.

The conditions under which you are able to disclose this information to others include:

• the person has agreed to disclosure of the information
• the disclosure is to a health professional where the disclosure is necessary for medical purposes AND the person making the disclosure reasonably believes that the subject has given consent to the disclosure or cannot give such consent (article 5)
• the disclosure is for the purpose of preventing or investigating crime

While the confidentiality protections of the GRA only apply to people who have been awarded a Gender Recognition Certificate (or who have applied for one), in many circumstances you will not know whether your patient has received a GRC, so will need to treat them as if they are protected.

Monitoring questions

Information about someone’s gender identity, trans status, or medical history related to transitioning can be important information to record and can be useful information for clinicians. However, it is important to ensure that this information is asked for sensitively and is stored in accordance with your legal requirements under the Data Protection Act and the Gender Recognition Act.

You can find more information about how to ask monitoring questions and manage this information in these resources.

• Equality and Human Rights Commission: Collecting information on gender identity
• Gendered Intelligence: Monitoring and Data Capture: Gender Related Options
• HSC Northern Ireland: Sample Questions for Monitoring Forms
• LGBT Foundation: If we’re not counted, we don’t count: Good practice guide to monitoring sexual orientation and trans status 2021
• NHS England: Gender identity and why it is important to ask about
• NHS England: Guidance on collecting and submitting data for the data items on gender within the Mental Health Services Data Set (MHSDS)
• Scottish Government: Sex, gender identity, trans status – data collection and publication: guidance for public bodies on the collection of data on sex and gender.
• Scottish Trans and Stonewall Scotland: Getting Equalities Monitoring Right
• The Scottish Government: Records Management Health and Social Care Code of Practice

Registering new patients

To provide trans-inclusive care, your new patient registration process should:

• Provide Mx as an option for a person’s title. If your practice uses the NHS “Register with a GP Surgery” system, or the paper “Register with a GP Surgery” form, patients will be offered this title. Remember that there is no legal proof required to use a title or to change title.
• Offer people the option to indicate that they’re non-binary rather than male or female, and provide an ‘other’ box to ensure that culturally-specific terms (such as hijra or two-spirit) can be used too.
• Ask about how to address the patient – for example, by asking the patient how they would like you to refer to them. In particular, ask if they would like to be addressed using a name other than the one on their medical records, and which pronouns they’d like to be referred to with.
• Gather information about trans status so that you understand the demographic makeup of your patient base and their needs. You can find further guidance on how to appropriately gather this information in the Monitoring questions section.

When you are registering a new patient, you may wish to specifically bear in mind these points:

• Identity documents, proof of address, and proof of immigration status are not required for registration with a GP surgery. Trans patients may not have access to these documents, or may not have them in the correct name, gender, or title. BMA guidance on patient registration states that you should not refuse registration on the grounds that a patient is unable to produce such documents.
• Deed polls showing a change of name do not need to be ‘enrolled’ to be valid and do not need any official stamps or seals in order to be accepted as evidence of a change of name.
• Out-of-area registration may be particularly important to trans patients, as they may need to access GPs who have specialist expertise and training, or to find alternative options to surgeries elsewhere where they have experienced discrimination or refusal of care.
• Temporary registrations may be important to some trans patients. Situations in which patients may benefit from temporary registrations include:
  • patients who are staying with family or friends who are caring for them while they are recovering from a surgery
  • patients who have previously been referred to a gender clinic funded in another UK nation as registering permanently in a new nation may invalidate their referral. Trans patients registering with you may be unaware that they are able to make a temporary registration if they are only temporarily resident in the area (for example, if they are a student) to avoid this.
• Questions on your practice policies may be common for trans patients, and they may wish to ask questions before registering about whether the practice has policies that allow bridging prescriptions or shared care.

Requests for letters

Patients are likely to ask for letters from their GP for:

• updating a passport: to update the gender marker on a UK passport, a letter from a medical professional is required. This letter does not need to contain more than your patient’s name and a statement that your patient has made a change of gender role which is ‘intended to be permanent’ (those four words should be included verbatim). You do not need to make your own assessment or diagnosis of the patient in order to write this letter – this is your account of the patient’s stated intentions. As with other medical letters which are not specifically an NHS service, you are allowed to charge a fee for producing this letter.
• applying for a Gender Recognition Certificate: as part of the application process for a Gender Recognition Certificate, applicants are required to provide two medical reports, the first written by a specialist, and the second which can be written by a non-specialist, which is most commonly their GP. The information required in this report is a factual account of what medical interventions the patient has undertaken as part of the gender transition, using the specific names of any surgical procedures or medications prescribed, and does not require any specialist knowledge in trans health. The report should also specifically state that the patient is transgender and has received a diagnosis related to this. To make providing this report simple, you can find a proforma version of this report on the Gender Recognition Panel website. You can read further guidance on writing the report on the GOV.UK website.