DSPT 2026-27 · Standard 1: Personal Confidential Data

Evidence item 1.3.8Optional

Does your data protection policy cover how you assess risks when starting new projects that involve personal data (DPIA process)?

Why it matters for your practice

When you introduce something new that involves personal data — like a new clinical system, CCTV, online consultations, or a research project — you should assess the data protection risks first. This is called a Data Protection Impact Assessment (DPIA). Your data protection policy should describe when and how you'd do this.

Is it mandatory?

No. 1.3.8 is optional for GP practices in the 2026-27 DSPT, but answering it shows good practice.

Official wording from NHS England

Assertion 1.3: Accountability and Governance in place for data protection and data security

Does your organisation's data protection policy describe how you identify and minimise risks to personal data when introducing, or changing, a process or starting a new project involving personal data?

Your policy should describe the process that your organisation has in place to make sure that it systematically identifies and minimises the data protection risks of any new project or plan that involves processing personal data. For example, when you introduce a new care recording system; if you install CCTV; if you use new remote care or monitoring technology; if you share data for research or marketing purposes. This type of risk assessment is called a Data Protection Impact Assessment (DPIA). Your organisation should consider whether it needs to carry out a DPIA at the early stages of any new project if it plans to process personal data. A DPIA should follow relevant guidance from the Information Commissioner's Office (ICO) (https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/accountability-and-governance/data-protection-impact-assessments).

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

  • DPIA Template
  • 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.