Data Security and Protection Toolkit (DSPT) Compliance

Completing the DSPT is not a one-time task—it requires ongoing updates, evidence collection, and engagement across multiple departments. Many organisations underestimate the time and resources needed to gather the required evidence, implement necessary policies, and submit their compliance report before the annual deadline.

• Evidence Collection: Gathering supporting documents, policies, and risk assessments can take weeks or even months.
• Coordination: Input is required from various teams, including IT, clinical staff, compliance officers, and senior leadership, making coordination difficult.
• Regular Updates: Compliance requirements evolve, meaning organisations must continuously review and update their policies to remain compliant.

The DSPT is designed to ensure compliance with multiple overlapping regulations and frameworks, including:

• GDPR (General Data Protection Regulation) – Covers data privacy and individuals' rights over their personal information.
• DSPT (Data Security and Protection Toolkit) – Specific to NHS Digital security standards, ensuring protection of patient data.
• ISO 27001 – The international standard for information security management, which many healthcare organisations strive to align with.

Many organisations struggle to interpret how these different regulations interconnect and ensure that their policies and procedures meet all compliance requirements. The need for technical expertise, legal understanding, and operational alignment makes completing the DSPT a challenge for organisations without dedicated compliance teams.

DSPT compliance is not just about ticking boxes—it requires organisations to provide structured and verifiable evidence to demonstrate adherence to security standards. Organisations must ensure that:

• Data Protection Policies are Up to Date: Policies must be reviewed regularly and aligned with evolving security risks.
• Clear Records of Risk Management are Maintained: Risk assessments, hazard logs, and mitigation plans should be documented thoroughly.
• Access Controls & Cybersecurity Measures are Evidenced: Organisations must prove they have robust access control, cyber-attack prevention, and incident response procedures in place.
• Incident Response Plans & Breach Reporting Procedures are Documented: Any previous security incidents or breaches must be logged with clear corrective actions taken.

For Category 1 and 2 organisations, independent audits are required, adding further complexity to the compliance process. Failing an audit due to poor documentation or inadequate security policies can result in serious reputational and contractual risks.

 Many healthcare organisations, especially smaller providers, GP practices, and care homes, lack the dedicated resources to complete the DSPT effectively. This includes:

• Limited Compliance Expertise – Many organisations do not have an in-house Data Protection Officer (DPO) or Clinical Safety Officer (CSO) to oversee DSPT compliance.
• Insufficient IT & Security Knowledge – Understanding cybersecurity requirements (such as firewalls, encryption, and access controls) can be challenging for non-technical staff.
• Budget Constraints – Smaller organisations often lack funding to invest in data security training, risk assessments, or IT upgrades required for full compliance.

Without specialist support, many organisations struggle to meet DSPT requirements, leading to last-minute submissions, incomplete assessments, or non-compliance penalties.