Tribunal orders cancellation of registration of nurse after criminal convictions

28 Jun 2022

A tribunal has ordered the cancellation of a registered nurse’s registration following his breach of professional boundaries and criminal convictions.

Trigger warning: Some readers may find this article distressing. If you are experiencing distress, please visit the NM Support website or contact Lifeline on 13 11 14 for help.

In January 2019, Mr Sean Maxwell Farrow was found to have placed concealed surveillance devices in a female staff toilet cubicle and in the female staff change rooms of Monash House Private Hospital. After the devices were discovered, Mr Farrow admitted to Victoria Police that he had installed them and his employment was immediately terminated. 

It was also found that Mr Farrow used other surveillance devices to film patients in the recovery ward during his employment at Monash House. The devices captured images of both Mr Farrows colleagues and patients in various stages of undress and/or under the effects of anesthesia post-surgery. 

A nursing colleague of Mr Farrow also reported inappropriate sexual misconduct, as a result of him making sexualized comments and touching her breasts over her clothing. It was found that Mr Farrow also breached professional boundaries with a patient by deliberately exposing the patient’s breast and making inappropriate comments.  

The Nursing and Midwifery Board of Australia (NMBA) was notified of Mr Farrow’s conduct in February 2019. He gave the NMBA an undertaking not to practice as a registered nurse (RN) in March, 2019. After more details of his conduct were known, in June, 2019 the NMBA suspended his registration and he has not worked as a RN since.

In November 2019, in the Magistrates’ Court of Victoria, Mr Farrow pleaded guilty and was convicted of five criminal offences under the Surveillance Devices Act 1999 (Vic). He was sentenced to six months’ imprisonment and to serve a community corrections order on his release. Mr Farrow was then referred to the Victorian Civil and Administrative Tribunal (tribunal). 

Mr Farrow made no admissions and did not participate in the tribunal proceedings heard in December 2021.

The tribunal found that Mr Farrow had engaged in professional misconduct and ordered that Mr Farrow: 

• be reprimanded
• have is registration cancelled
• is disqualified from applying for registration for 10 years, and
• is prohibited from providing any health service for 10 years.

The tribunal stated that Mr. Farrow’s conduct was utterly disgraceful. The tribunal noted that Mr. Farrow had objectified women who regarded him as a friend and other women who depended on him to provide care in a manner which maintained their privacy and dignity. The breach of trust was egregious as was his breach of professional responsibility to treat patients with respect, compassion and to act with integrity.

The tribunal’s decision was published on 14 December 2021 with reasons updated on 14 January 2022. The decision is available on the Austlii website.