Emma, Ellette and George Pattison

From 

Minister of State for Care  

39 Victoria Street  
London  
SW1H 0EU 

24th September 2024 

Our ref: 

Richard Travers   
HM Coroner’s Court 
Station Approach 
Woking  
GU22 7AP 

By email: 

Dear Mr Travers, 

Thank you for the Regulation 28 report of 8th August 2024 sent to the Secretary of State / 
the  Department  of  Health  and  Social  Care  about  the  death  of  Emma  Pattison,  Ellette 
Pattison,  and  George  Pattison.  I  am  replying  as  the  Minister  with  responsibility  for  NHS 
Primary Care. 

Firstly,  I  would  like  to  say  how  saddened  I  was  to  read  of  the  circumstances  of  Emma 
Pattison, Ellette Pattison, and George Pattison’s deaths and I offer my sincere condolences 
to their family and loved ones. The circumstances your report describes are very concerning 
and I am grateful to you for bringing these matters to my attention.  

The report raises concerns over: 

1.  An  applicant  for  a  shotgun  certificate  is  able  to  obtain  medication  from  an  on-line 
doctor without the knowledge of their GP, giving rise to a risk that a licensing authority 
might grant a shotgun certificate to an applicant who has a relevant previous medical 
history about which the authority is not aware.   

2.  In consulting an on-line doctor, it is possible for an applicant for a shotgun certificate 
to avoid the current safeguards relating to full disclosure of their previous and current 
medical history.  

3.  Consideration  should  be  given  as  to  how  a  licensing  authority  can  obtain  full  and 
accurate disclosure of an applicant’s history of coercive controlling behaviour towards 
another / others.  

In preparing this response, my officials have made enquiries with NHS England to ensure 
we adequately address your concerns. 

I am responding to your first two concerns regarding medical checks as part of the firearms 
application process as requested of my Department in your report.   

We have worked closely with the Home Office and the British Medical Association to ensure 
there are strong controls in place in relation to an applicant’s medical suitability which is one 

  
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 element of the application process that the police consider when deciding if an applicant can 
hold a firearms or shotgun certificate. An applicant is required to declare all relevant medical 
conditions  upon  applying  and  they  must  provide  details  of  their  GP.  A  proforma  is  then 
completed by their GP or an independent General Medical Council registered doctor. The 
doctor completing the proforma checks the GP medical record and must provide details of 
all  relevant  medical  conditions  to  the  police. This process  has  been  further strengthened 
within GP IT systems, where a GP adds a digital marker to the patient record, to note that 
the patient has a firearms certificate. This was fully rolled out to all GP IT systems in England 
by  May  2023.  If  the  patient  begins  to  experience  a  relevant  medical  condition  while  the 
certificate is valid, upon discussion with the GP, the GP will see an alert and can flag this to 
the  police  allowing  them  to  review  the  person’s  suitability,  and  if  necessary,  revoke  the 
certificate.   

In response to the issue you raise that an applicant for a shotgun certificate is able to obtain 
medication  from  an  on-line  doctor  without  the  knowledge  of  their  GP,  there  is  no  legal 
requirement for a GP to be informed about medication from a private online prescriber. This 
is  an  issue  which  the  Government  is  considering.  Third  party  (non-NHS)  doctors  or 
prescribers  cannot  share  confidential  patient  information  with  a  person’s  NHS  GP  if  that 
person objects unless they believe there is an overriding public interest justification for doing 
so (e.g. to protect a third party from serious harm). Third party prescribers are also reliant 
on the patient fully disclosing all medical conditions and existing medication to be able to 
prescribe safely. Under data protection law each healthcare provider is the ‘data controller’ 
of their patient records and the common law duty of confidentiality further protects personal 
data.   

In order to practice medicine in the UK, all doctors must meet the expected standards set 
out in the GMC’s Good medical practice and for prescribing, the GMC’s Good practice in 
prescribing and managing medicines and devices.   

In your report you raise the issue of whether an applicant can avoid full disclosure of their 
previous  and  current  medical  history.  If  an  applicant  seeks  treatment  from  a  range  of 
healthcare providers, this is possible. The Home Office is considering the concerns you have 
raised in relation to the firearms licensing process and will be responding to your report in 
due course. 

Thank you for bringing these concerns to my attention.   

Yours sincerely,

Sensitivity: Unrestricted

BMA House 
Tavistock Square 
London WC1H 9JP 

T 0300 123 1233   

Richard Travers 
HM Coroner for Surrey 

The Inquests Touching the Deaths of Emma, Ellette and George Pattison  
A Regulation 28 Report – Action to Prevent Future Deaths  

Dear Mr Travers 

We write in response to the Regulation 28 report issued by yourself following the inquest into 
the deaths of Emma, Ellette and George Pattison, and specifically in response to paragraphs 5.1 
and 5.2 in that report: 

The MATTERS OF CONCERN are as follows. – 

1. 

2. 

An applicant for a shotgun certificate is able to obtain medication from an on-
line doctor without the knowledge of their GP, giving rise to a risk that a 
licensing authority might grant a shotgun certificate to an applicant who has a 
relevant previous medical history about which the authority is not aware. 
In consulting an on-line doctor, it is possible for an applicant for a shotgun 
certificate to avoid the current safeguards relating to full disclosure of their 
previous and current medical history. 

In respect of 5.1, we note the concern raised. The GMC has clear guidance that covers the 
sharing of information between on-line doctors whom the patient may choose to consult, and 
the patients registered NHS General Practitioner. The guidance: 
About Good practice in prescribing and managing medicines and devices - GMC (gmc-uk.org) 
 provides at Paragraph [56]: 

If you are not the patient’s GP, when an episode of care is completed, you must tell the 
patient’s GP about:  

a. changes to the patient’s medicines along with reasons, including if existing 
medicines are changed or stopped, and new medicines are started  
b. length of intended treatment  
c. monitoring requirements, including who will carry this out 
d. any new allergies or adverse reactions identified. 

Co-chief executive officers: 

Registered as a Company limited by Guarantee. Registered No. 8848 England. 
Registered office: BMA House, Tavistock Square, London, WC1H 9JP. 
Listed as a Trade Union under the Trade Union and Labour Relations Act 1974. 

Sensitivity: Unrestricted

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 Sensitivity: Unrestricted

We would therefore expect online doctors to be providing information to GPs in line with the  
professional guidance available from their Regulator. If a patient does not consent to this 
sharing of information, then the same GMC guidance advises that the online doctor should 
explain the risks to the patient and to record the refusal in their medical records. (Paragraph 31) 
However, the risks that might exist in these circumstances are not further defined. A change to 
the guidance above would be a matter for the GMC to consider. BMA guidance reiterates the 
above.    

Paragraph (9) of Good Medical Practice (2024) also creates a responsibility for a doctor to 
consider whether the mode of consultation is appropriate to providing the safe care the patient 
needs. 

In respect of 5.2, we would expect an online doctor to be prescribing only after having taken an 
appropriate medical history, which would include, albeit not necessarily exhaustively, their 
current and past medical history and prescribed medications. This would underpin the clinical 
basis for deciding whether or not to prescribe. If the medical record is not available, then the 
only source of information would be from the patient. Communication with the regular GP 
would mitigate this risk, and as above, that would be the expected practice in this situation, 
unless the patient refused consent to do so.   

This report identifies a possible information gap for NHS General Practitioners when providing 
factual medical information to the police as part of the firearms licensing process.  We will 
update our own guidance to reflect that this potential gap exists if external prescribers are not  
sharing information, or have not been supplied by the patient with information that would be 
relevant.  

Yours sincerely   

Chair GPC England 

Sensitivity: Unrestricted

Page 2 of 2

Richard Travers  
HM Coroner for Surrey 
HM Coroner's Court Woking  
Woking  
GU22 7AP 

By email: 

Dear Mr Travers 

Deputy Chief Constable 

NPCC Lead for Firearms Licensing 
Force Executive Team 
Warwickshire Police 
Leek Wootton 
WARWICK 
CV35 7QA 

Tel. No.: 

3 October 2024 

The Inquests Touching the Deaths of Emma, Ellette and George Pattison  
NPCC National Lead on Firearms Licensing – Response to the Coroner’s Regulation 28 Report – 
Action to Prevent Future Deaths. 

I have very recently taken over as NPCC Lead for Firearms Licensing upon the retirement of former Chief 
Constable 
 last week.  I have carefully considered the content of the Regulation 28 Report 
from the Coroner in the above Inquest and have liaised with colleagues in both the College of Policing 
(CoP) and the Home Office (HO) who are responsible for legislation and guidance in this critically important 
area of policing. 

I note that, as NPCC Lead, I am asked to consider the following specific matters of concern: 

1.  An applicant for a shotgun certificate is able to obtain medication from an on-line doctor without 
the knowledge of their GP, giving rise to a risk that a licensing authority might grant a shotgun 
certificate to an applicant who has a relevant previous medical history about which the authority 
is not aware.  

2.  In consulting an on-line doctor, it is possible for an applicant for a shotgun certificate to avoid 
the current safeguards relating to full disclosure of their previous and current medical history.  

3.  Consideration  should  be  given  as  to  how  a  licensing  authority  can  obtain  full  and  accurate 
disclosure of an applicant’s history of coercive controlling behaviour towards another / others. 

Following  the  shootings  in  Keyham,  Plymouth  in  2021,  the  NPCC,  CoP  and  HO  have  worked  to 
significantly revise and reform the statutory guidance around firearms licensing and the nature and extent 
of checks which are made on both applications for a grant or renewal of a firearms licence.  In particular; 

  Firearms Enquiry Officers 

Substantial changes are being introduced around training and accreditation of Firearms Enquiry 
Officers  (FEOs)  (who,  in  most  cases  provide  the  report  to  decision  makers  assessing  the 
applicant’s  circumstances  and  comment  on  suitability  following  appropriate  conversations  and 
visits). 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 A new National Firearms Enquiry Officer’s Course has now been designed and developed and will 
commence its first delivery in November 2024 to forces in Northeast England.  This is an intensive 
programme consisting of pre-learn reading package, and which includes a variety of new training 
videos. FEOs will then attend a five day ‘in person’ course, which has formal testing scenarios to 
cross check knowledge and understanding.  Following this the FEOs will attend mandatory online 
training  sessions  where  certain  subjects  will  be  discussed  in  more  detail  especially  around 
domestic abuse and family turmoil together with mental health and wellbeing. FEOs will then be 
required to complete a portfolio involving internal assessments, CoP and external moderation to 
ensure that learning and best practice are embedded in their day-to-day activities and enquiries. 

We  are  also  introducing  a  new  FEO  Report  Form  for  national  use  which  will  require  more 
comprehensive detailing of enquiries undertaken, information received (from in person interviews, 
police systems and wider investigations deemed appropriate on each individual application) and 
the rationale for their view on suitability.  It is intended that this will act both as a prompt to FEOs 
to ensure all aspects of suitability are properly considered and also build on the increasing focus 
in  more  recent  versions  of  the  HO  guidance  around  the  importance  of  exercising  professional 
curiosity in all cases. 

  Medical Declaration and GP Report 

Changes  have  been  made  to  the  medical  declaration  required  from  an  applicant  and  the 
requirement for a specific GP report has been introduced – no licence is now considered without 
the opinion of the applicant’s GP as to any relevant medical concerns or other medical issues which 
could affect an applicant’s suitability to possess a licence. 

Where an application or their GP disclose any instances of anxiety or depression (or similar) we 
would expect Firearms Licensing teams to exercise professional curiosity and interview applicants, 
family and friends and to follow up with the GP or other medical professional/specialist to enable 
any risks to their suitability to hold a licence to be properly assessed.  It is also possible within the 
licensing  framework  to  accommodate  bespoke  conditions  to  address  an  applicant’s  medical 
pathway if required. 

There has already been a significant improvement in the medical information available to Firearms 
Licensing teams through the introduction of the mandatory GP report or medical report from a third 
party  medical  provider  on  application.    However,  it  remains  the  case  that  where  an  applicant 
deliberately withholds relevant information – not only from the Firearms Licensing team but from 
their  own  GP  –  there  is  little  that  police  forces  can  do  in  many  cases  to  address  deliberate 
dishonesty, save for revoking a licence (which is made clear on the application form and within the 
HO guidance).  

 
 
 
 
 
 
 
 
 
 
 Dealing specifically with the Matters of Concern raised in the PFD Report: 

1 & 2 – Online GPs 

It is, of course, outside the role and remit of policing to regulate or manage the health sector; this 
would be a matter for the Department of Health and Social Care and we understand that our HO 
colleagues are working with their counterparts in the DHSC to progress this issue.  As the NPCC 
Lead, I would welcome any positive moves that are possible to regulate online GPs/prescriptions 
and require any relevant information to be passed to the GP with whom the individual is registered, 
so that it is accessible to Firearms Licensing Units when required, to enable a fuller picture to be 
available  to  support  risk  assessments  and  suitability  assessments  on  applications  for  grant  or 
renewal of firearms licensing.  Exactly the same concerns arise where applicants use private GPs 
or  consultants  (outside  of  a  GP  referral)  which  may  also  remain  unknown  to  firearms  licensing 
teams. 

I understand that the HO is intending to amend the firearms application form so that the applicant 
must provide details if they have consulted an online or third party/private doctor, enabling further 
enquiries to be made. It is hoped that there will be provisions for the police to require the applicant 
to provide a completed medical proforma from this doctor regarding any relevant conditions.  Again, 
this is a step which the NPCC would support. 

3 – Applicant’s history of coercive controlling behaviour 

On both initial grant applications and on renewal, checks are already required to be made on Police 
National Computer (PNC), the Police National Database (PND) and local policing records.  This 
would  disclose  to  Firearms  Licensing  teams  any  convictions,  cautions,  intelligence  or  pending 
matters/investigations.   

The Statutory Guidance for Chief Officers of Police on Firearms Licensing (2023) at paragraph 2.4 
states (our emphasis added) –  

“All applicants should be checked against the widest relevant databases to gather conviction, 
intelligence and counter terrorism data.” 

Guidance sets out detailed considerations for suitability assessments including, at paragraph 2.52 
and onwards: 

Additional checks 

2.52 Chief officers should carry out additional, non-routine, checks if, following the initial enquiries 
above, they believe them to be necessary to assess suitability fully. 

2.53 These checks may include, but are not limited to: 

(i) checks with other agencies, such as health professionals other than the GP, social services, 
probation services or multi-agency groups; 

(ii) checks with other licensing or regulatory bodies or Government enforcement agencies; 

(iii) a drug or alcohol test; 

(iv) credit or other financial checks; 

(v) information obtained from open source social media; 

 
 
 (v) interviews with individuals other than the applicant or their referees, for example, partners or 
representatives of shooting clubs attended by the applicant; 

(vi) background checks on partners or other individuals living at, or with unsupervised access to, 
the applicant’s address; and 

(vii) checks where there is an indication of domestic abuse, as set out in paragraphs 2.54 – 2.59. 

It is expected that FEOs speak with the applicant and, where relevant, family members and friends 
and others.  In cases of suspected controlling and coercive behaviour, additional safeguards are 
found in the Controlling or coercive behaviour Statutory Guidance Framework at paragraph 51:  

“In all domestic abuse cases, if firearms are held by the perpetrator or are in the home, the local 
police Firearms Licensing Team should be notified so that they can consider seizing the firearms 
or revoking any licence that the perpetrator holds. It is also important in terms of risk mitigation and 
intelligence to ensure officers attending future calls have this information. The Firearms Licensing 
Statutory  Guidance for  police  was  published  in  February  2023  and  contains  further  information 
about firearms licensing in respect of cases involving domestic abuse”. 

Conclusion 

It is my view that improvements have definitely been made over the past couple of years in respect of 
the extent of enquiries and evidence gathering to fully inform suitability assessments in applications for 
firearms licensing.  There is, in my opinion, much better joint working between NPCC, CoP and HO to  
expand the requirements around suitability assessments, medical disclosures, the expectation for 
professional curiosity to be displayed by all those involved in the licensing process and the introduction 
of a thorough and accredited national training programme for FEOs. 

However, as the NPCC (working with the College of Policing) we remain of the view that there is more to 
do and that changes are still necessary to further improve the ability of the police to properly risk assess 
an applicant’s suitability to hold a firearms licence: 

  Mandatory mental health markers on GP files to prompt pro-active disclosures by GPs for licence 

holders where matters of potential concerns to public safety/suitability are raised. 

  Neurodiversity must be added to the medical declaration on application for a firearms licence, to 

enable the police to seek specific medical opinion of the impact of that upon the particular 
applicant. 

  Regulation of Online GP services and the introduction of a requirement upon those GPs working 
online to report to the registered GP any relevant information/disclosures/medications prescribed 
for inclusion on medical records. 

  HO to proceed with implementation of the outcomes from their August 23 consultation, in 

particular we would welcome early implementation of  

o  Mandatory requirements for GPs to support the licensing process and complete the 

medical proformas on every application, 

o  Police being granted powers to enter properties to seize firearms for the purpose of 

reassessing suitability of licence holders, 

o  A statutory prohibition on applying for a licence for 5 years for anyone who has been 

sentenced to serve 0-3 years in prison, including suspended sentences. 

  More serious potential sanctions upon applicants who deliberately withhold relevant information 

or are deliberately dishonest on application 

 
 
 
 There is already expectation that deliberate failure to disclose criminal history or relevant medical 
evidence should lead to a refusal.  The Statutory Guidance sets out that in the case of 
deliberately withholding relevant information, applicants should expect to be refused a licence: 

3.30 In addition to the most serious factors above, evidence, on the balance of probabilities, of 
any of the following, although not exhaustive, will tend to demonstrate a potential danger to public 
safety or to the peace: 

……. (iii) deliberate failure to declare relevant convictions or medical conditions, regardless of 
whether the certificate would have been refused if the appropriate declaration had been made; 

However, given the potential consequences of dishonesty leading to firearms being held (lawfully) by those 
who are not safe to do so without causing a potential danger to public safety – as in this case – it must be 
arguable that stronger sanctions should be available for those who act in this manner and seek to obtain 
a licence when they are fully aware that, due to current health conditions, they should not be permitted to 
do so. 

The difficulties posed by this case however appear difficult to legislate against;  

  There  were  no  records  held  of  the  licence  holder’s  more  recent  mental  health  difficulties  as  he 
appears  to  have  taken  steps  to  deliberately  by-pass  his  own  GP,  presumably  recognising  that 
obtaining medication via an online doctor would result in there be no traceable record of his illness. 
  He has then lied on his application and medical declaration and failed to disclose relevant medical 

information. 

  There do not appear to be any record of previous complaints or concerns being raised with police 
in  respect  of  controlling  or  coercive  behaviour.    The  licence  holder’s  wife  was  apparently 
interviewed in respect of the licence application and raised no concerns.  Systems checks did not 
disclose any prior reporting – save for a single incident prior to the previous renewal process, where 
the licence holder was the complainant.   

Moving forward, national FEO training will further encourage positive engagement with the applicant and 
their  family/others  in  their  household.    FEOs  will  be  expected  to  ascertain  the  “domestic  health  and 
wellbeing” of the applicant on both initial grant and any renewal.  We are hopeful that revised statutory 
guidance will require interviews and wider engagement with families and FEOs will be required to cover 
these matters on the new FEO report on suitability.  We are also looking to introduce the right to draw 
adverse inference if an applicant is evasive about family/previous partners and so on. 

As a police service, we will continue to engage with partners to improve upon partnership working and 
inter-agency  information-sharing  to  ensure  that  those  charged  with  determining  firearms  licensing 
applications have as much relevant information as possible to assess an applicant’s suitability to hold a 
firearms licence in the context of ensuring public safety. 

Yours sincerely 

Deputy Chief Constable 
NPCC LEAD FOR FIREARMS LICENSING

Chief Constable
9 October 2024

Dear Mr Travers,

| write in response to your Regulation 28 report dated 8"" August 2024, relating to the inquests
touching the deaths of Emma, Ellette and George Pattison.

| share your concern that any certificate holder or applicant can, it would appear, hide certain
medical treatment by using an online facility. The national application form asks, “Are there
any periods in the past 10 years when you have not been registered with a UK GP or have
consulted medical practitioners other than at your GP practice?” In this case, Mr Pattison
answered “no” in both his 2016 and 2022 renewals. Surrey Police acknowledge that, although
the force re-asks all other questions on the medical form during the Firearms Enquiry Officer
(FEO) visit, Surrey Police did not ask about the use of other medical services in this visit. Surrey
Police has, because of this case, revised our practice, and FEOs now do cover this in their visits
to try and elicit the information from an applicant. Surrey Police acknowledges that an
applicant could still withhold this information, and there is currently no method for the police
to find out if it is being so witheld.

The College of Policing and the NPCC have made recommendations that this national set of
questions is re-written to be more explicit. Whilst most applicants understand what is being
asked, there is still room for non-disclosure or deception. Additionally, the request for
disclosure is limited to information from the previous 10 years only. Surrey Police would also
like to relocate the question to a more prominent position within the medical section to
ensure its importance and relevance is clear and noted.

| recognise that the wider regulation of online GPs is being explored as part of your
recommendations and would welcome change to make this a more robust process.

Surrey Police, PO Box 101, Guildford, Surrey, GU1 9PE | surrey.police.uk

Surrey Police licensing officers take a negative view of applicants who fail to disclose relevant
information. However, there seems to be little within legislation to require a holder to
disclose a change in personal circumstances during each 5-year period. Therefore, | am
consulting with the College of Policing and the NPCC lead on the potential to add a condition
to holder certificates, reminding them of their obligations to inform the police of any changes
in domestic and health situation. | believe this would allow more robust oversight between
renewals.

Controlling and coercive behaviour became an offence in 2016. Since then, there has been a
continued learning programme deigned to equip responders to recognise this behaviour.
Surrey Police has a dedicated Domestic Abuse Team and continue to work with our partners
in the identification and support of victims of domestic abuse. Officers asked Mrs Pattison
about her relationship. However, she did not make any disclosures of abuse. Mrs Pattison
was also spoken with independently by the FEO when conducting the suitability review. No
risk factors were identified at that stage and Mrs Pattison stated that she had no concerns
regarding the firearms possession.

Surrey Police is aware of the Project Titanium trial being conducted by Gwent Police to
explore domestic abuse concerns further and are supportive of the aim and objective of this
project. We look forward to understanding the finding of this project post review. In the
meantime, Surrey Police processes ensure that current partners are independently engaged
with and, on a case-by-case basis, previous partners or family members can be spoken to.

As a licensing authority Surrey Police thoroughly reviews the investigative paperwork
completed by police officers. This includes body worn video and Domestic Abuse, Stalking and
Harassment & Honour Based Violence risk assessment forms in order to make licensing
decisions based on all the information available to us.

This work is being progressed nationally by Chief Constable Debbie Tedds, the NPCC lead for
firearms licensing. She is supported by her staff officer Chief Superintendent Adrian Davies
who is also the College of Policing contact for this area of work. Both proposed changes above
must be agreed at a national level and there cannot be local differences to the form or
process. This work is already underway and the proposed changes will be presented at the
National Firearms, Explosive working group by Adrian and, once ratified, will be implemented.
| expect this to take 6 — 12 months.

For assurance, | have asked our Assistant Chief Constable with responsibility for Firearms
Licensing to report formally to me on progress against your recommendations in 3 months.

Yours sincerely

Chief Constable

Minister of State for Policing, Fire 
and Crime Prevention 
2 Marsham Street 
London SW1P 4DF 
www.gov.uk/home-office 

Richard Travers 
HM Coroner for Surrey 

Dear Mr Travers, 

Thank you for your report of 8 August about the deaths of Emma, Ellette and George 
Pattison, made under paragraph 7(1) of Schedule 5, of the Coroners and Justice Act 2009.  
I offer my sincere condolences to the family and loved ones of those who have been 
affected. The safety of the firearms licensing system is paramount and I have carefully 
considered the matters you raise regarding firearms licensing controls in relation to this 
most tragic case. 

In your report you raise concerns that an applicant for a firearm certificate is able to obtain 
medication from an online doctor without the knowledge of their GP, giving rise to a risk 
that a certificate could be granted without the police being aware that the applicant has a 
relevant medical history, and that this enables an applicant to avoid providing full 
disclosure of their medical history to the police. 

There are already strong controls in place in relation to an applicant’s medical suitability. 
Every applicant is required to declare all relevant medical conditions when they complete 
their firearm or shotgun application form and they must also provide details of their GP. A 
proforma is completed by the applicant’s doctor who checks the GP medical record, and 
details of all relevant medical conditions must be provided to the police before a firearm 
certificate can be issued. The GP also places a firearms marker on the patient record so 
that they can alert the police if the certificate holder begins to experience a relevant 
medical condition while the certificate is valid, so that the police can review the person’s 
suitability and, if necessary, revoke the certificate. 

I have taken careful note of the issue you raise in relation to the medical checks, that there 
is no requirement for an online or third-party doctor to inform a patient’s GP about 
medication they have prescribed for them. This is an issue which the Government is 
considering. In the meantime, in order to further strengthen the firearms licensing process I 
intend to make arrangements to amend the firearms and shotgun licence application form 
so that in future applicants are required to provide details if they have consulted an online 
or third party prescriber who is not their GP.  This will enable further enquiries to be made 
with the online or third-party prescriber, and the police may require the applicant to provide 
a completed medical proforma from this prescriber in relation to any relevant medical 
conditions. I also intend to amend the firearm certificate to include a new condition 
requiring the holder to inform the police if they consult an online or third-party doctor about 
a relevant medical condition during the five years the licence is valid. These changes will 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 be implemented by statutory instrument and are planned to take effect in the course of 
2025.  

In your report you have also proposed that consideration is given to how the police can 
obtain full and accurate disclosure of an applicant’s history of coercive controlling 
behaviour. The Home Office publishes Statutory Firearms Guidance for Chief Officers of 
Police which sets out the processes and criteria for assessing an applicant’s suitability to 
possess firearms. This assists the police in their firearms licensing functions and promotes 
high standards and consistency between forces.  We are intending to issue a refreshed 
version of the Statutory Guidance early in 2025 which will include additional guidance for 
the police to help ensure that those who are the perpetrators of domestic abuse, coercive 
or controlling behaviour, do not have access to firearms. In particular, we will strengthen 
the guidance so that it is clear and emphasises the need to interview partners, relatives 
and possibly former partners if there are allegations or suspicions of domestic abuse, 
coercive or controlling behaviour in the household. The Statutory Guidance for Firearms 
will make clear that such interviews need to be conducted with sensitivity, taking into 
account that a victim of domestic abuse may be unwilling to speak openly with the police 
for fear of further violence or reprisals, and that information provided during interview must 
be treated as confidential. We will also ensure that the Statutory Guidance is sufficiently 
clear in relation to other allegations of violence and the need for the police to investigate 
such allegations and take this information into account when making their assessment of 
suitability.  

There is a further safeguard contained in the separate Statutory Guidance framework in 
relation to controlling or coercive behaviour, published by the Department and which was 
updated in July 2023 and applies to those investigating offences in relation to controlling or 
coercive behaviour. This states at paragraph 51 that in domestic abuse cases, if firearms 
are held by the perpetrator or are in the home, the local police firearms licensing team 
should be notified. The guidance also advises that for intelligence purposes and to mitigate 
risk officers attending future calls must have this information. 

Thank you again for your report. We will review firearms licensing to ensure that the 
strongest possible safeguards are in place.   

Yours sincerely,