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    Jill Tomlinson

    Dr Flynn’s response unfortunately fails to acknowledge or address the issues that I raised in my letter to the Medical Board. Dr Flynn’s response refers to the AHPRA social media policy. My letter refers to the AHPRA advertising guidelines. These are two separate documents.

    The proposed AHPRA advertising guidelines do set new requirements and do change Board expectations of medical practitioners. From March 17, for the first time anywhere in the world, AHPRA and the Australian Medical Board will hold health practitioners responsible for comments that are posted by an independent individual on a platform that the health practitioner has no control over.

    If the Board’s core role and focus is to protect the public and manage risk to patients, then why attempt to censor patient communication?

    Dr Flynn states that the social media policy prompted lively debate. Indeed it did in 2012, when AHPRA proposed a draft policy that appeared to suggest that even a Facebook Like would be considered a testimonial. This draft was completely reworked following highly negative community feedback and thankfully the new 2014 social media policy looks nothing like the 2012 version.

    In 2014 it is the proposed AHPRA advertising guidelines that do not make sense, and which have received highly negative feedback from health practitioners. My open letter appears to have been misunderstood and dismissed, but I am certainly not alone in expressing that the proposed advertising guidelines need to be reconsidered – as the Australian Doctor comments that I reproduce below demonstrate.

    Dr Jill Tomlinson
    MBBS(Hons), PG Dip Surg Anat, FRACS(Plast), GAICD

    The comments reproduced below were made by health practitioners this week on the Australian Doctor website regarding the new AHPRA guidelines. The comments can be viewed by registered users at

    “AHPRA has no clue about the reality of social media. Time for AHPRA to be accredited on its knowledge of the 21st century.”

    “I’m concerned that in obeying APHRA I might be trampling on the human right ICCPR Article 19.”

    “I know, come March, let’s get all our friends to post awesome things about all the Doctors on the board of AHPRA.”

    “In my view AHPRA is restricting valuable information available to patients to make informed decisions about their care. In my opinion that is not protecting the public, that is hindering the public.”

    “Does AHPRA really think they can tell the tech savvy generations that they’re not allowed to share such info in the format easiest and most comfortable for them?”

    “AHPRA are not just a hugely overpriced monopoly, they are off with the fairies. “

    “Previously, it only related to what a Doctor posted themselves or made available to their patients or the public. Now it relates to what other people say on their own media platform external and independent to the practitioner. This is where AHPRA have lost the plot.”

    “There is an implied freedom of speech in Australia, and we as practitioners have no power over the operation of websites. Unsolicited testimonials should be removed by APHRA not the practitioner, cos what’s it got to do with moi?”

    “There is some logic to the ruling in that on Faecesbook it is quite possible for a doctor to create a bogus account and write glowing testimonials to themselves, however the rather clumsy response by AHPRA is also a serious blunder into the terrain of free speech.”

    “I received this response from Doctoralia (who clearly do not care a bit!): Thank you for contacting us. We are aware of the law. Many other countries where we are present have a similar rule. We do not consider our reviews as testimonials, as they are not under the Professionals control. Patients are free to leave a review if they want. Besides this, any professional or centre has the right to switch off the review service from the profile, anytime. Best regards,”

    “The plot has officially been lost ladies and gentlemen….”


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