Patient data
Special category data, handled properly
UK GDPR classes health information as special category data, and the ICO says it needs to be treated with greater care than other personal data. Article 32 requires security appropriate to the risk, including the ability to restore access to personal data in a timely manner after a physical or technical incident.
In practice that means multi-factor authentication on every account, encrypted laptops, staff able to open only the records their role needs, and a named login for everyone rather than one shared reception account. It also means knowing what to do when something goes wrong: a personal data breach must be reported to the ICO within 72 hours of becoming aware of it, where feasible, unless it’s unlikely to put anyone at risk.
We look after the security. Your practice stays the data controller and decides how patient information is used.
NHS contracts
The Data Security and Protection Toolkit
If your practice holds NHS contracts in England, you’ll need the NHS Data Security and Protection Toolkit (DSPT): any organisation that can access NHS patient data and systems has to use it. It’s a contractual requirement under NHS England’s standard conditions, at least one assessment must be published by 30 June every year, and it’s needed for national systems such as NHSmail. Dentists and opticians answer a smaller assessment than NHS trusts.
The toolkit measures you against the National Data Guardian’s ten data security standards, and several are about IT: access only for staff who need it, a continuity plan tested at least once a year, no unsupported operating systems or software, and IT suppliers, which includes us, held to account for protecting the data they handle. We can help with the IT questions and fix the gaps they reveal.
Wales has its own Welsh Information Governance Toolkit, run by Digital Health and Care Wales, which lists health boards, trusts, GP practices and community pharmacies as the organisations that complete it. If you hold NHS contracts, check the toolkit or equivalent your health board requires.