Early warning signs of a GDC investigation
- Rachel Barrow

- Jan 5
- 4 min read

What the GDC does
The GDC sets standards for the dental team and expects registrants to meet those standards in clinical practice, record keeping, communication, consent, safeguarding, and professionalism.
The GDC also investigates fitness to practise concerns when information suggests that a dental professional’s conduct, performance, health, or integrity might compromise patient safety or public confidence.
The GDC’s purpose is to decide whether regulatory action is required to protect the public, which may range from taking no further action, to issuing advice or warnings, to imposing conditions, suspension, or removal from the register in the most serious cases.
Why an associate may be investigated
An associate may be investigated because a concern has been raised by a patient, a colleague, a practice, an NHS body, another regulator, or the police. Clinical concerns are a common trigger, particularly where there is alleged failure to diagnose, inappropriate treatment planning, poor outcomes, repeated remedial work, or a pattern of similar adverse outcomes.
Consent and record keeping issues also feature frequently, because inadequate records and poorly documented consent can make otherwise defensible clinical decisions appear unsafe or unjustified.
The GDC can investigate issues of probity, including dishonesty, misleading advertising, or problematic financial arrangements, because integrity is treated as fundamental to trust in the profession.
Health concerns and police action may also lead to investigation when a condition, stress, or substance misuse is alleged to be affecting safe practice.
Early signs that there may be a GDC referral
An early sign is often a pattern of dissatisfaction rather than just a single complaint. An associate may notice repeated themes in patient feedback, such as unexpected fees, dissatisfaction with explanations, or claims that risks were not discussed.
Another early sign is the accumulation of “small” issues that suggest a gap in clinical governance, such as incomplete records, templated notes that do not reflect the individual patient’s circumstances, missing radiographic justification or reporting, or treatment plans that are not clearly recorded.
It is also an indicator of rising risk when the associate is frequently required to notify indemnity providers, or when the practice is repeatedly involved in drafting complaint responses for the same clinician.
An associate who is consistently running late, rushing appointments, or working beyond their current competence or support network is more exposed to errors and misunderstandings. The risk is higher when advanced procedures are undertaken without clear evidence of training, mentoring, case selection discipline, and consent documentation that properly reflects the risks.
How associates can prevent concerns escalating to the GDC
Prevention is primarily achieved through high standards of documentation, robust consent, effective communication, and appropriate escalation.
Associates reduce regulatory risk when records are complete, accurate, and written in a way that demonstrates clinical reasoning. Notes should also confirm the agreed treatment plan, the patient’s decisions, and the follow-up and safety-netting advice.
Associates reduce risk when consent is treated as a process rather than a form. Consent conversations should be tailored to the patient and the proposed treatment, and the record should reflect the questions the patient raised, and the answers given. It is particularly important to ensure that elective and cosmetic treatments involve unpressurised decision-making and a clear record of risks, limitations, and realistic outcomes.
Associates also reduce risk when they work within their competence and refer appropriately. A referral should be made early when complexity increases due to anatomy, medical history, behavioural challenges, patient expectations, or previous treatment failures. The record should explain why referral was advised, what alternatives were discussed, and what the patient decided.
Complaint handling is another critical prevention tool. Concerns escalate to regulators more often when patients feel ignored than when they feel heard. A complaint response should be calm, factual, empathetic, and timely. The response should explain what will happen next, offer appropriate review or remedial options where clinically indicated, and avoid speculation or blame. Associates should avoid informal messages that could be misinterpreted and should ensure that communications with patients are professional and appropriately documented.
Wellbeing and fitness to practise are also part of prevention. Associates who are overtired, stressed, or unwell are more likely to make mistakes and less likely to communicate well. Associates should ensure they are fit to practice and take time to rest when needed.
What to do when a referral seems likely
When an incident is serious or a complaint is escalating, it is important to act promptly and professionally.
Records should be completed accurately and contemporaneously, and any later additions should be clearly dated and explained rather than silently altered. Relevant documents should be retained, including radiographs, referral letters, treatment plans, consent documentation, and correspondence.
Indemnity providers should be notified in accordance with the relevant policy terms, because early notification often improves the quality and consistency of responses to complaints and regulators.
Self-Referral to the GDC
The GDC’s standards require registrants to act to protect patients and to be open and honest where things go wrong. Self-referring to the GDC can demonstrate early candour and insight, allowing a dental professional to present an accurate account and evidence remediation at the outset. This may reduce the risk of aggravated regulatory findings if the issue later comes to light through a third-party complaint.
Contact us on 0330 088 2275 if you feel an action you have taken may lead to a GDC investigation.
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