DSPT 2026-27 · Standard 10: Accountable Suppliers

Evidence item 10.2.7OptionalNew for 2026-27

If you or your suppliers process patient data outside the UK, have you risk-assessed it and put the right governance in place?

Why it matters for your practice

This includes suppliers whose systems or support teams are based overseas, such as some cloud, transcription or AI tools. If that applies, you should have a Data Protection Impact Assessment (DPIA) covering the international transfer, an appropriate transfer mechanism in your contract, and your privacy notice should tell patients if data goes outside the UK. Ask suppliers where data is stored and accessed from. If no patient data is processed outside the UK, answer 'Yes' and note 'Not applicable'.

Is it mandatory?

No. 10.2.7 is optional for GP practices in the 2026-27 DSPT, but answering it shows good practice.

What changed since 2025-26

New evidence item for cat 4. See all 2026-27 changes.

Official wording from NHS England

Assertion 10.2: Basic due diligence has been undertaken against each supplier that handles personal information

If you or your suppliers process identifiable patient/ service user information outside the UK, have you appropriately risk-assessed the processing, and put relevant governance in place?

If identifiable patient/ service user information is not processed, outside the UK, then tick and write "Not applicable" in the comments box. If you have selected yes or no, you must consider how clear governance has been followed for example: By completing a data protection impact assessment (DPIA) for the processing which reflects that data is being transferred internationally. If the data processing is happening outside the European Union, you have updated your privacy information to inform your patients and service users. Your international data processing adheres to the relevant contractual agreements such as HSCN/SPINE agreement Being covered by an appropriate transfer mechanism as stipulated within appropriate transfer mechanisms. If your organisation/suppliers do not process identifiable patient/service user information outside of the UK, then tick and write "Not applicable" in the comments box.

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

  • Supplier Register
  • DPIA Template
  • Privacy Notice

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

Track 10.2.7 and every other DSPT item

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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.