Information Governance and Data Sharing in NHS-Commissioned Services

Information governance is no longer a back-office function. Within NHS-commissioned services, it is a core assurance area that underpins safety, trust and effective system working.

Commissioners increasingly expect providers to demonstrate not just compliance, but confidence and clarity in how information is shared across organisational boundaries.

This aligns closely with risk management and compliance and regulation and oversight.

Why information governance matters in integrated systems

NHS pathways rely on timely, accurate information moving between providers. Poor governance can lead to:

  • Delayed or unsafe decision-making
  • Breakdowns in continuity of care
  • Loss of commissioner confidence

As systems integrate, governance failures carry wider consequences.

What commissioners expect providers to understand

Commissioners expect providers to be clear on:

  • Lawful bases for processing and sharing data
  • Role-based access and data minimisation
  • Responsibilities within multi-agency pathways

Generic policies without operational understanding are not sufficient.

Day-to-day data sharing in practice

Effective information governance is visible in routine operations, such as:

  • Clear referral information standards
  • Secure transfer of discharge and care updates
  • Controlled access to shared systems

Staff understand what they can share, when and why.

Managing consent and transparency

Providers are expected to:

  • Explain data use clearly to people and families
  • Record consent and objections accurately
  • Respond appropriately to subject access requests

This supports both legal compliance and trust.

Assurance and oversight mechanisms

Commissioners look for evidence of:

  • Named IG leadership
  • Routine audits and checks
  • Learning from data incidents

Information governance is actively monitored, not assumed.

What good looks like to commissioners

High-performing providers can demonstrate:

  • Confident, lawful data sharing
  • Clear accountability structures
  • Proportionate, well-understood controls

Strong information governance enables safer, faster integrated care.


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Written by Impact Guru, editorial oversight by Mike Harrison, Founder of Impact Guru Ltd β€” bringing extensive experience in health and social care tenders, commissioning and strategy.

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