Moderator Guidelines & Code of Conduct

All Clinical Exchange moderators must read, understand, and agree to these guidelines. They incorporate GDPR obligations, professional standards, and community expectations.

Purpose & Scope

The Clinical Exchange is a peer-to-peer forum for verified clinicians. Moderators are trusted clinicians who volunteer (or are appointed) to help maintain the quality, safety, and legal compliance of the community. This includes GDPR compliance, patient confidentiality protection, and professional standards enforcement.

These guidelines apply to all wiki moderators regardless of appointment method (application, nomination, or internal appointment). They are reviewed every 6 months by the DPO and updated as needed.

Code of Conduct

Protect Patient Confidentiality

Critical

Never allow posts containing patient identifiers (names, dates of birth, MRN numbers, specific dates). Flag immediately for redaction. This is non-negotiable.

Review Flagged Content Within 48 Hours

Required

All flagged posts, reported content, and user complaints must be reviewed within 48 hours. If you will be unavailable, notify the DPO or another moderator.

Welcome New Members

Required

Greet newly verified clinicians. Help them understand community guidelines, direct them to the DPO page for their rights, and encourage quality contributions.

Curate Clinical Bulletins

Required

Review and approve community-submitted bulletins (guidelines, advisories, updates). Verify sources before approval. Only peer-reviewed or authoritative sources.

Enforce Professional Standards

Critical

Remove or edit content that is unprofessional, discriminatory, or promotes unsafe practices. Issue warnings before escalation. Document all actions.

Maintain Neutrality

Critical

Do not use moderator powers to advantage your own posts, suppress competing viewpoints, or promote commercial interests. Disclose conflicts of interest.

Handle Personal Data Minimally

Critical

As a moderator, you may see verification documents during review. You must never download, screenshot, or share these. View-only access, logged and audited.

Be Fair and Consistent

Required

Apply the same standards to all members regardless of their reputation, specialty, or seniority. Document the rationale for all moderation decisions.

Report Data Breaches Immediately

Critical

If you suspect any data breach (unauthorised access, accidental disclosure, lost device with moderator access), report to the DPO within 1 hour.

Annual Re-confirmation

Required

Confirm your clinical license is still valid annually. Step down gracefully if you become too busy — there is no shame in prioritising patient care.

GDPR Obligations for Moderators

Moderators are data processors under GDPR when handling verification documents or user data. You must complete the annual GDPR training module before receiving moderator access.

Lawful Basis Understanding

Understand that different wiki activities have different lawful bases (consent, legitimate interest, legal obligation). Do not process data beyond the stated purpose.

Data Minimisation

Only access the minimum data needed for your moderation task. If reviewing a flagged post, you do not need to view the user's verification documents.

User Rights Facilitation

If a user contacts you exercising their GDPR rights (erasure, rectification), direct them to the Data Rights dashboard immediately. Do not handle these requests yourself.

Breach Reporting

You are legally required to report any suspected data breach to the DPO within 1 hour. This includes: accidental disclosure, unauthorised access, lost/stolen device, or phishing attempts.

Documentation

All moderation actions are logged automatically. Never attempt to bypass logging or use unapproved tools to access wiki data.

Professional Secrecy & Confidentiality Agreement

Required for Article 9(2)(h) compliance: GDPR Article 9(3) requires that health data processed under the health care exemption must be processed by or under the responsibility of a professional bound by professional secrecy. The following measures satisfy this requirement.

Moderator Confidentiality Agreement

All moderators sign a binding confidentiality agreement before receiving access. Covers: no downloading of verification documents, no screenshotting, no sharing outside the platform, immediate breach reporting to DPO within 1 hour.

Terms of Service — Professional Secrecy Clause

All wiki users are bound by a professional secrecy clause in the ToS. By participating, clinicians agree to maintain confidentiality standards equivalent to their professional regulatory body (IMC, GMC, state medical board, etc.).

Role-Based Access Controls

Moderators can only access data necessary for their specific task. Verification documents are view-only. No bulk export. No admin override without DPO approval logged.

Audit Trail for All Access

Every view of sensitive data is logged (who, when, what, why). Logs retained for 6 years. Moderators can see their own audit trail. All actions attributable.

Annual Secrecy Training

All moderators complete annual training on professional secrecy obligations under GDPR Article 9(3) and their national medical council rules on social media and online conduct.

By applying to become a moderator, you acknowledge that you are a licensed healthcare professional bound by professional secrecy rules in your jurisdiction. You agree to process all wiki data under the responsibility of ChartScribe and its DPO (Wells Electronics), and you will maintain the same standards of confidentiality that apply to your clinical practice. Violations may result in immediate removal, reporting to your regulatory body, and legal action where appropriate.

Enforcement Framework

Moderation actions are applied proportionately. Critical violations (patient confidentiality, harassment, fraud) skip straight to Level 3 or 4.

1

1. Informal Warning

Private message to member explaining the issue. No public action.

Examples: Minor formatting issues, borderline off-topic

2

2. Formal Warning

Logged warning in member record. Content edited or removed with explanation.

Examples: Patient identifier in post, disrespectful language

3

3. Temporary Restriction

Posting rights suspended for 7–30 days. Member can still read and message DPO.

Examples: Repeated warnings, spam, unprofessional conduct

4

4. Permanent Removal

Account banned from wiki. All posts anonymised. Reported to DPO.

Examples: Serious PHI breach, harassment, fraud, illegal content

Annual Training Requirements

GDPR refresher (30 min online module) — mandatory annually
Patient confidentiality & PHI handling (20 min) — mandatory annually
Moderator tools & dashboard walkthrough (15 min) — on appointment + annual
Conflict of interest disclosure — updated annually
Breach response drill — bi-annual simulation

Report a Moderator Concern

If you believe a moderator has acted inappropriately or violated these guidelines, contact the DPO confidentially.

Report to DPO

All reports are confidential and investigated by the DPO independently.

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