DSPT 2026-27 · Standard 1: Personal Confidential Data

Evidence item 1.1.2MandatoryUpdated for 2026-27

Do you keep an up-to-date Information Asset Register (IAR) and Record of Processing Activities (ROPA), and review them regularly?

Why it matters for your practice

This is a list of all the personal data your practice holds, where it's stored, and who you share it with. Think patient records in EMIS or SystmOne, staff HR files, payroll data, prescriptions, referral letters, etc. You can combine the IAR and ROPA into one document. It needs to have been reviewed by your management team in the last 12 months.

Is it mandatory?

Yes. GP practices must meet 1.1.2 to reach "Standards Met" in the 2026-27 DSPT.

What changed since 2025-26

Question wording and tooltip updated. See all 2026-27 changes.

Official wording from NHS England

Assertion 1.1: The organisation has a framework in place to support Lawfulness, Fairness and Transparency

Does your organisation maintain an up to date information asset register (IAR) and a record of processing activities (ROPA) and review this regularly?

To be compliant with data protection legislation you must keep a register of all of the information your organisation stores, shares and receives. You should have an Information Asset Register (IAR) that details where and how the information is held and how you keep it safe. You should also have a list of the types of personal data that are shared with others, for example needs assessments, prescriptions, payslips, care plans. This list is called a Record of Processing Activities (ROPA) and should detail how the data is shared and how your organisation keeps it safe. You can combine these into one register, but it is fine to have two separate documents. The register should have been reviewed and approved by the management team at least once in the last twelve months. Example templates for the ROPA and IAR are available from Digital Care Hub (https://www.digitalcarehub.co.uk/data-protection-and-cyber-security/how-to-document-your-data-processing/).

Official wording © NHS England, from the DSPT 2026-27 (v9) requirements. Always check the live Data Security and Protection Toolkit before you submit.

ClinicShield templates that help

  • Information & Digital Asset Register
  • Data Flow Map

Ready-to-edit templates are included in paid plans.

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This guide covers the requirements for GP practices (Category 4). ClinicShield is a preparation and guidance tool. You still publish your submission on the official DSPT website. We're not affiliated with NHS England and can't guarantee an outcome. Guidance only, not professional advice.