GOC consultation on maintaining appropriate sexual boundaries and care of patients in vulnerable circumstances

Published in July 2025, running till October, the GOC consultation was seeking views on newly developed guidance for:

• Caring for patients in vulnerable circumstances
• Maintaining appropriate sexual boundaries.

The consultation inquired about the effectiveness of the guidance documents in terms of clarity and how helpful they would be in supporting registrants to interpret the changes made to the standards.

Our response

Following substantial engagement with the AOP policy committee and the legal team, we submitted a comprehensive response to the GOC. A number of areas of concern were recognised that needed to be addressed for clarity, practical implementation, alignment with legal requirements/legislations and the realities for registrants working in optometric practice.

1. Unclear definitions for key concepts

Key concepts (such as the concept of “vulnerability”) and terms (relating to sexual boundaries), were insufficiently defined or overly broad diluting their meaning and not giving adequate attention to certain demographics requiring additional safeguards.

We recommended that both guidance documents contain a glossary of key terms and that the definitions are legally defined. Where there is no legal definition, care must be taken to ensure that the definition is compliant and compatible with relevant legal concepts.

2. Lack of reference to existing legislation

We also identified that the guidance documents do not consistently reference relevant established legal frameworks such as the Equality Act 2010; the Accessible Information Standards; legislation around harassment and discrimination and vicarious liability. These all extend protection to those who are considered vulnerable and those with protected characteristics. We suggested that the guidance document on the care of vulnerable people should acknowledge and reference these to ensure that it complements existing frameworks, bringing sufficient clarity on both the employees and employers' duties.

3. The use of an interpreter in the care of vulnerable people

It is important that the guidance on the care of vulnerable people is clarified on the use of an interpreter. The Equality Act 2010 does not state that language barriers are a protected characteristic and thus extending the duties of optometrists to organise an interpreter for patients with language barriers could cause financial and practical burdens on practices.

We recommend that the suggestion of using an interpreter align with the existing legislation, ie, a clearly defined criteria be established when an interpreter is required and what type of interpreter is required (eg language translation, sign language, cultural mediation).

4. Suggested improvements in guidance document on maintain sexual boundaries

We also recognised that a number of the problems with the draft guidance on maintaining sexual boundaries are because it focuses on sexual relationships/”boundaries” rather than on relationships more generally. We believe that this could be solved if the title and focus were changed from “sexual boundaries” to “appropriate relationships at work” as this is a more readily understood phrase and considered a range of workplace relationships (platonic, familial or sexual/romantic).

Next steps

• We will continue to monitor the implementation of the revised indicative sanctions guidance to minimise any negative impact on members
• Alongside this, we will continue to provide training and advice to members to ensure that they are aware of what these changes may mean in day-to-day practice.