DSPT 2026-27 · Standard 1: Personal Confidential Data

Evidence item 1.1.5Mandatory

Who is responsible for data security in your practice, and how has this been formally assigned?

Why it matters for your practice

You need a named senior person who is formally responsible for data security — usually your practice manager or someone from the partners. This should be documented — for example, in their job description, meeting minutes, or a formal letter. Many GP practices also have a Caldicott Guardian (usually a senior clinician) and may have a Data Protection Officer.

Is it mandatory?

Yes. GP practices must meet 1.1.5 to reach "Standards Met" in the 2026-27 DSPT.

Official wording from NHS England

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

Your organisation's approach to security is owned and directed by senior responsible individuals, with regular discussions driven by individuals who have overall accountability for security.

Whilst data security and data protection is everybody's business, there must be a named person within your organisation who takes overall senior responsibility for data security and protection issues. Their responsibility is to provide senior level leadership and guidance. In the text box, name the person or people within your organisation with overall responsibility for data security and protection, along with their roles. Then, for each person, describe how this responsibility has been formally assigned to them. For instance, this responsibility could form part of their job description, or be noted in the minutes of a management meeting, or be in an email from the appropriate director in your organisation. Your organisation may also have additional specialised roles, for example a Data Protection Officer (https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/accountability-and-governance/data-protection-officers/#:~:text=The%20DPO%20must%20be%20independent,a%20single%20DPO%20between%20them) or a Caldicott Guardian (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1013756/Caldicott_Guardian_guidance_v1.0_27.08.21.pdf). You can read more about data security and protection responsibilities and specialised roles on the Digital Care Hub (https://www.digitalcarehub.co.uk/resource/data-security-and-protection-responsibilities/)

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

  • Data Protection Policy

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.