All feedback is an opportunity to improve, and we will of course pay close attention to the PSA's report as we continue to implement improvements throughout the GDC. However, given the significant progress we have made, the finding that we did not meet fitness to practise standards 6 and 10 in 2017/18 is clearly disappointing.
Fitness to practise standard 10
With regards to standard 10, we have undertaken significant work to develop and implement a robust information governance framework and ensure a high level of compliance with the requirements of the new General Data Protection Regulation.
While we note the PSA's findings about the increase in the number of referrals to the Information Commissioner (the ICO), we disagree that this means our performance against this standard has declined. Indeed, the openness that is sensibly encouraged by the ICO in terms of reporting appears to have become reason for censure within the PSA's framework and this unhelpful conflict needs to be resolved as a matter of urgency.
It is also concerning that the PSA should have concluded that external validation is essential, as such a view is also at odds with that of the ICO.
In the face of this conflict I am very clear that we will continue to comply with our statutory obligations to the ICO first and foremost. That should in itself provide confidence to the PSA that we are fulfilling our data-handling responsibilities. We hope our responses to the PSA's conclusions in this area will provide a basis for a more constructive discussion about the GDC's management of data going forward.
Fitness to practice standard 6
The GDC's failure to retain standard 6 is obviously disappointing, but not surprising. As in the previous year, the PSA made clear that the decision was finely balanced.
Our strategy is to ensure that progress is sustainable, so we make lasting improvements rather than expensive quick fixes. This takes time but it is the right thing to do. Regrettably, I don't think we were able to predict the degree to which the necessary long-term changes would impact on, and hold back, our timeliness improvements.
Some of those improvements already made include significant reductions in timescales in the early stages of an investigation. Furthermore, we have focused great effort on resolving older fitness to practise cases. This affects short term performance, but we are confident that we have already made significant long term and sustained improvements as a result of this strategy.
Whilst we recognise that the PSA's findings in its review of 2017/18 still fell short of what we, or our stakeholders, wanted to see, we are confident of the significant progress that has been made since this reporting period. We look forward to building on this as we continue to fulfil our statutory objectives.