NHS England » Transformation Check and Challenge Group

Organisation

National Voices
Patient Public Voices
Department of Health and Social Care
Understanding Patient Data
NHS England
Office of the National Data Guardian
FDP Programme Team (NHS England)
Information Commissioner’s Office
British Medical Association

Apologies received

Open actions

Meeting minutes

Welcome and introductions

The Chair, Jacob Lant, opened the meeting. Apologies were noted. The Chair welcomed two new Patient and Public Voices representatives to the meeting, noting that their participation reflects the groups commitment to strengthening direct patient and public input, supporting constructive challenge, and ensuring that data transformation initiatives were developed and scrutinised with public confidence and trust at their core.

Minutes and actions from previous meeting

The group ratified and approved the minutes of the meeting held on Friday 19 January 2026.

Action log

There was no current confirmed return date for action CAC-113; however, the Chair emphasised the importance of returning the item to the group as soon as possible given the level of interest.

Action: share an updated timeline for when the AI assisted discharge summary DPIA. In relation to action CAC-115, the Chair noted that MHRA representation had been addressed in principle during the AI update and agreed that the action could now be closed. The group further noted that formal MHRA attendance would follow post completion of the AI Airlock work.

FDP Communications and engagement update

The FDP Lead Senior Communications and Engagement Manager provided an update on recent communications and engagement activity aimed at building public trust, responding to media interest, and strengthening transparency around the Federated Data Platform.

A representative from the BMA highlighted ongoing public concern and media scrutiny regarding whether immigration status data is collected, held, or shared through the NHS FDP. NHS England advised that the FDP FAQs had been updated to clarify that NHS England owns and controls the data within the platform, and that immigration status was not collected or held within FDP products. This update was made proactively in response to recent media coverage and public discussion.

During the discussion, group members sought assurance that the wording was sufficiently clear in the FAQ, including whether residency status might be processed. NHS England confirmed that residency status was also not processed within FDP products, and that all products are subject to data specification and information governance review. It was further clarified that any limited data collected elsewhere in the NHS for charging purposes was governed separately and sits outside the scope of FDP. The Chair agreed that, whilst the clarification had been helpful, strengthening the FAQs further to explicitly reference both immigration and residency status would provide clearer public assurance.

Action: update the NHS England FAQ to explicitly clarify that residency status is not processed within FDP products, in addition to the current statement on immigration status.

The group discussed the development of a number of FDP case studies, which were currently progressing through internal approval processes ahead of publication. A representative from the National Data Guardian’s office suggested that communications updates could be more closely aligned with programme updates, to help the group better understand the relationship between communications activity and programme delivery, including the impact of media coverage, negative press, and social media on adoption and overall progress.

PPV representatives highlighted that authentic, real world case studies were critical to building public trust and responding to recurring concerns regarding data use, privacy and demonstrable value. The communications

team advised that, once cleared through appropriate governance processes, approved case studies would support wider external communications activity, including proactive media engagement and public-facing materials.

The Chair and group representatives encouraged a shift from primarily reactive communications towards more proactive “headline FAQs” to help address recurring public concerns.

The group also highlighted the value of clearly outlining how concerns and complaints would be managed should they arise, and of ensuring the timely publication of minutes, particularly given external interest and scrutiny.

The group received and noted the update.

Single Patient Record (SPR) update

The SPR team joined the meeting and provided an update on the development of the full business case, progress within the test and learn phase, and ongoing public and clinical engagement activity.

A PPV representative emphasised the importance of SPR meaningfully addressing fragmentation in access to patient records, carefully managing expectations around the concept of a “single” record, and clearly demonstrating tangible benefits for patients and clinicians over time. In addition, a representative from the NDG observed that the term “Single Patient Record” may be misleading, noting that “single” could imply a fully unified record, and “record” may suggest a consolidated dataset rather than a view or access mechanism. It was emphasised that language shapes expectations and highlighted the importance of careful, transparent communication while the programme design continues to evolve.

The Chair highlighted the importance of establishing a clear baseline of patient and public experience early in the SPR programme, noting that whilst qualitative evidence exists on issues such as repeated storytelling and record inaccuracies, there was no single NHS owned baseline capturing the scale of the problem. The Chair advised that establishing a baseline now would be essential to demonstrate whether SPR delivers meaningful improvements in patient and clinician experience over time, and to support credible evaluation of benefits, recognising that progress may otherwise be difficult to evidence without a clear reference point. The group received and noted the update.

Artificial intelligence update

The Deputy Director AI and Head of the Regulatory team at NHS England joined the meeting.

The group received an update on the AI Platform (AIP) within the FDP, including its features, governance arrangements, and the evolving regulatory landscape for AI medical devices, with ongoing collaboration with the Medicines Healthcare Regulatory Authority (MHRA).

A representative from the BMA raised questions regarding the use of live patient data in the development and deployment of AI tools, particularly in relation to the AI assisted discharge summary tool (AADS). There was also a query to whether patients would reasonably understand that their live data may be used to develop, test or operate AI products, and whether this had been fully considered from a transparency and public trust perspective. In response, the Head of the Regulatory team explained that AI products were subject to extensive information governance, data protection and clinical safety processes, with ongoing work to ensure regulatory compliance as MHRA classifications evolved.

The Chair emphasised the importance of ensuring absolute clarity on whether live patient data had been used at any stage of the product’s development, alongside appropriate regulatory and transparency considerations.

Action: invite a representative from Chelsea and Westminster Hospitals Trust to the next meeting for an in-depth discussion on the AI discharge summary tool and its use of live data.