NHS DSPT + agentic AI: mapping the 10 data security standards to runtime controls

The NHS Data Security and Protection Toolkit (DSPT) is a mandatory annual self-assessment for any organisation accessing NHS patient data. For AI agent vendors and the NHS organisations deploying them, the DSPT is the gating compliance asset — without a DSPT submission that includes the AI tool, the deployment doesn’t happen.

This article maps the 10 National Data Guardian (NDG) standards to specific runtime controls a compliance plane like Regulus needs to emit, plus the evidence shape for the DSPT submission portal.

The 10 standards #

The 10 NDG standards organise into three groups:

Group A: Personal confidential data (Standards 1–4) #

1. Personal confidential data. All staff ensure that personal confidential data is handled appropriately. For agents: PII redaction at runtime is the operational evidence.
2. Staff responsibilities. All staff understand their responsibilities. For agents: every action carries the Principal claim of the staff member who invoked it.
3. Training. All staff complete annual data security training. Out of scope for the runtime; training-completion data lives in your LMS.
4. IT systems. Information systems must be tested for compliance. For agents: residency, identity, cryptography are the runtime tests.

Group B: Process (Standards 5–7) #

5. Process reviews. Audit and review of data handling processes. The audit chain is the substrate.
6. Responses to data breaches. Incident-management procedure exists and is followed. Standard 7 is the runtime side; 6 is the process documentation.
7. Continuous improvement. Each cyber incident triggers process improvement. Audit chain provides input.

Group C: Technical assurance (Standards 8–10) #

8. Assured systems. Software has Cyber Essentials or equivalent. Substrate-level assurance (Vertex AI, GCP) covers this for the AI agent’s hosting environment.
9. IT protection. Operational cybersecurity. Cross-references NIS2 + DORA for dual-regulated organisations.
10. Third parties. Suppliers’ data security is assured. LLM provider, GCP, GRC tools — each is a third party.

Which Regulus plugin delivers each #

A pragmatic mapping:

NDG Standard	Plugin / mechanism	Evidence shape
1 — Personal confidential data	RegulusPrivacyPlugin	PII redaction events; NHS Number / clinical-marker patterns
2 — Staff responsibilities	Principal claim chain	Each audit event captures the staff Principal who invoked the agent
3 — Training	Out of scope	LMS-side, not runtime
4 — IT systems	Residency + identity + crypto plugins	Residency enforcement, expired-credential denials, hash-chain integrity
5 — Process reviews	RegulusAuditPlugin	Audit chain itself; aggregated weekly/quarterly views
6 — Data breach responses	Process docs + audit	Documentation side is governance; audit captures incidents
7 — Continuous improvement	Kill-switch + audit	Each engagement event triggers post-incident review
8 — Assured systems	GCP substrate	Vertex AI / Assured Workloads; vendor’s Cyber Essentials certificate
9 — IT protection	Combined plugins	Identity expiry, residency, kill switch, audit chain
10 — Third parties	RegulusModelRiskPlugin + GRC	Model Registry as third-party register; assurance status per provider

The split between “Regulus delivers” and “governance delivers” is the important distinction. Six of the ten standards have runtime evidence the audit chain produces; the other four are documentation or substrate-level.

NHS-specific PII patterns #

The Regulus privacy plugin’s NHS pattern catalogue covers:

• NHS Number — 10-digit format with the Modulus 11 check digit.
• NHS Spine identifiers — patient demographic service refs, scheduling refs.
• Clinical-data markers — diagnoses (ICD-10, SNOMED CT terms), medications (dm+d codes), procedures (OPCS-4).
• NHS staff identifiers — SDS roleProfile codes, GMC numbers, NMC numbers.
• Free-text clinical — locale-aware patterns for surnames and forenames, combined with NHS-specific tokens.

Configurable per deployment — a hospital admin agent uses a different pattern set than a clinical decision support agent.

The DSPT submission shape #

The DSPT submission portal asks one question per assertion area, with evidence references. For AI tool assertions, the Regulus DSPT export produces:

$ regulus dspt export --org "Acme NHS Foundation Trust" --period 2026-2027

✓ Standard 1: 4,128 redaction events; 0 leaks detected
✓ Standard 2: 41 staff Principals identified; chain coverage 100%
○ Standard 3: External — LMS submission
✓ Standard 4: Residency enforced (UK-only); 0 cross-border denials
✓ Standard 5: 4,128 audit events; chain verified
○ Standard 6: External — Information governance team
✓ Standard 7: 0 kill-switch engagements; 0 incidents
○ Standard 8: External — Vendor Cyber Essentials cert
✓ Standard 9: Identity expiry 0 violations; residency 100%
✓ Standard 10: 4 third parties registered; all with assurance refs

The “External” items are the ones the DPO submits manually, referencing their own evidence. The ”✓” items have Regulus runtime evidence supporting the answer.

What clinical safety adds #

For AI agents in NHS settings, DCB0129 (vendor) and DCB0160 (deploying organisation) clinical safety standards apply in addition to DSPT. The standards require:

• A Clinical Safety Officer (CSO) appointed at both vendor and deploying organisation.
• A clinical safety case for the AI tool.
• Hazard identification, risk assessment, risk control measures.
• Ongoing clinical safety monitoring.

Regulus emits evidence relevant to clinical safety — adverse event detection, outcome distribution, performance drift — but the clinical safety case itself is the CSO’s deliverable, not a runtime artefact. The clinical safety monitoring uses the audit chain as input, similarly to how Consumer Duty outcomes monitoring uses it in financial services.

What to do this quarter #

If you’re a vendor of an AI agent for NHS deployment:

1. Map your runtime evidence to the 10 standards. Regulus does this by default; if you’re hand-rolled, document the mapping.
2. Produce a DSPT-ready evidence pack. The deploying NHS organisation needs evidence references in DSPT-portal format.
3. Coordinate with your CSO and the deploying organisation’s CSO on the clinical safety case.
4. Pre-empt the typical due-diligence questions. Most NHS Trusts ask about pseudonymisation, residency, retention, and incident response. Have the audit-chain evidence ready.

For the full operational view, see the NHS DSPT profile page and the privacy plugin page.