Cyber Security in Adult Social Care: Governance, Risk and Commissioner Assurance
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Cyber security is no longer a technical back-office issue in adult social care. It is a core governance, safeguarding and business continuity risk that commissioners, regulators and integrated care systems increasingly expect providers to understand and manage. Data breaches, ransomware attacks and system outages can directly disrupt care delivery, compromise confidentiality and undermine trust with people using services.
Commissioners now look beyond whether a provider has IT systems in place and focus instead on how cyber risks are identified, governed and controlled in day-to-day operations. Cyber security therefore sits alongside quality, safeguarding and financial resilience as a key assurance domain. This is particularly relevant when linked to digital records and data and wider business continuity planning.
Cyber Security as a Governance Responsibility
Effective cyber security starts with governance. Providers must demonstrate that responsibility for cyber risk sits at senior leadership and board level, rather than being delegated solely to external IT suppliers.
In practice, this means:
Boards and senior managers should formally include cyber risk within organisational risk registers, with defined risk owners and review cycles. Cyber risks should be reviewed alongside safeguarding, staffing and financial risks, not treated as a standalone technical issue.
Clear lines of accountability are essential. Commissioners increasingly expect providers to identify a named senior lead responsible for information security, data protection and digital resilience, even where systems are outsourced.
Cyber policies should be live governance tools, not static documents. Policies must link directly to incident reporting, escalation routes and business continuity plans, and be reviewed following incidents or system changes.
Operational Cyber Risks in Day-to-Day Care Delivery
Cyber risks in social care arise from everyday operational activity, not just external attacks. Common risk points include:
Care staff accessing digital care records on personal or shared devices without appropriate controls, creating vulnerabilities around passwords, lost devices or unauthorised access.
Use of multiple disconnected systems for care planning, rostering, medication and HR, increasing the likelihood of inconsistent permissions and weak access controls.
Reliance on email, messaging apps or informal file sharing for sensitive information, particularly during hospital discharge or crisis response.
Each of these risks can lead to breaches of confidentiality, service disruption or loss of critical information if not actively managed.
Commissioner Expectations and Assurance Requirements
Commissioners do not expect providers to eliminate cyber risk entirely, but they do expect proportionate, well-evidenced controls. Increasingly, assurance focuses on how risks are managed rather than whether systems are technically sophisticated.
Typical commissioner expectations include evidence that:
Cyber risks are assessed as part of organisational risk management and reviewed regularly.
Staff receive training on data protection, cyber awareness and secure use of digital systems, with refresher training tracked and monitored.
There are clear incident response processes for data breaches, ransomware or system failure, including communication with commissioners and regulators.
Providers can demonstrate learning from incidents, audits or near misses, rather than simply reporting compliance.
Embedding Cyber Security into Quality and Safeguarding
Cyber security directly supports safeguarding and quality of care. Loss of access to care records, medication systems or communication tools can place people at immediate risk.
Strong providers therefore integrate cyber controls into wider quality systems. For example, contingency arrangements for system outages should be tested through scenario planning and drills, in the same way as staffing or service disruption scenarios.
Incident reporting systems should capture digital and data-related incidents alongside care incidents, enabling patterns to be identified and addressed through quality improvement processes.
Review, Audit and Continuous Improvement
Cyber security is not a one-off compliance exercise. Commissioners and regulators expect evidence of ongoing review and improvement.
This may include regular internal audits of access controls, data handling practices and incident logs, supported by external reviews where proportionate. Importantly, providers should be able to explain what has changed as a result of audits or incidents, demonstrating active governance rather than passive compliance.
By treating cyber security as a core governance and operational issue, providers can strengthen digital resilience, protect people using services and meet commissioner expectations with confidence.
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