Health Bill: single patient record - equality impact assessment

Introduction

The general equality duty that is set out in the Equality Act 2010 requires public authorities, in the exercise of their functions, to have due regard to the need to:

• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the act (equality aim 1)
• advance equality of opportunity between people who share a relevant protected characteristic and those who do not (equality aim 2)
• foster good relations between people who share a protected characteristic and those who do not (equality aim 3)

The general equality duty does not specify how public authorities should analyse the effect of their existing and new policies and practices on equality but doing so is an important part of complying with the general equality duty.

In addition, the Secretary of State for Health and Social Care has a duty under the NHS Act 2006 to have regard to the need to reduce inequalities between the people of England with respect to the benefits that they can obtain from the health service.

This document therefore considers the impact of the Health Bill (‘the bill’) on people who share each of the 9 protected characteristics, as well as additional factors that have been strongly linked to inequalities related to the health service.

Summary of policy

On 21 October 2024, the Secretary of State for Health and Social Care announced an ‘analogue to digital’ shift plan to create “a single patient record, summarising patient health information, test results and letters in one place, through the NHS App”. The development of a single patient record (SPR) will be a significant step in creating a more responsive and efficient healthcare system.

The objective of this policy is to provide a single version of a patient’s health information across health and care settings. It will unify patient information from across the NHS, giving both patients and professionals secure access to a single, accurate and up-to-date record - wherever and whenever it’s needed.

The SPR will be available to every person who has visited an NHS health professional in England, and the intention is that this record will:

• develop over time
• be able to encompass their interactions with public and private health and adult social care services including a patient’s:
  • medical history from birth
  • diagnoses
  • physiological data (for example, blood pressure)
  • imaging and laboratory results
  • treatments and prescriptions
  • personal care plans

The aim is for SPRs to start with primary and secondary care and expand to services like adult social care over time.

The creation of the SPR is intended to end many of the frustrations patients shared during the Department of Health and Social Care (DHSC) and NHS England’s National public engagement on the use of health and care data. The SPR will result in fewer repeated stories and no more appointments where clinicians are unaware of what happened previously.

Legislation will provide a power to establish the SPR (that would be added to the NHS Act 2006) to address 2 problems with the current system:

• inability of patients to see their entire record
• inability of practitioners to see information provided about their patient by others

Subject to Parliamentary time, our ambition is that from 2028, patients will be able to view their SPR securely on the NHS App.

This assessment has been developed to support the proposed SPR legislation in the bill - it does not assess the wider SPR programme. Any impacts described here will not have effect until regulations are in place and may differ depending on the form the SPR regulations take. We will continue to review the equality impacts of the legislation as regulations are developed.

The definition of ‘patient’ in the bill provisions includes people who need or receive social care or whose need for such care is being assessed. References to patients in this document should be interpreted accordingly.

Intended aims

As outlined in the 10 Year Health Plan for England, DHSC’s current policy aims for the SPR are to:

• give patients visibility and control of their data
• put patients in control of their own medical history, meaning that they do not have to repeat it at every appointment and that staff have the full picture of patients’ health
• provide a single version of the ‘truth’ that can be accessed by patients and healthcare professionals from different settings such as primary and secondary care - the record will include data and interactions the patient has with different clinicians as well as alerts for actions to be shared
• lay the foundations for patient information to flow safely, securely and seamlessly between care providers benefiting clinicians and social care staff in future - this aims to:
  • improve clinical outcomes
  • make decision-making more informed
  • speed up the delivery of care

Specific legislative powers to establish the SPR, and subsequent regulations made under the legislation, will support the above.

Effect on staff

The SPR legislation seeks to improve information sharing across each professional involved in a person’s care in England. The intention is not to replace information systems, but for the legislation to set out the legal framework for health and care organisations to share information into an SPR. This will make sure an SPR can be compatible with existing information systems used by health and care professionals. The details of the SPR will be set out in future regulations.

The SPR is designed to significantly reduce the administrative burden for clinicians. The SPR aims to support health and care professionals by providing:

• a clear, unified view of a patient’s history - wherever they’ve received care
• seamless access to be able to support care across all care settings, from primary to acute to community
• better-informed decision-making and reduced administrative burden
• safer, faster and more co-ordinated care through a more collaborative approach, as the SPR will enable patients to read, update and share joint care plans

This will free up valuable time to focus on direct care rather than administrative tasks.

Over time it will also include adult social care information and be accessible to providers of adult social care (subject to safeguards such as roles-based access) and will therefore enable a more collaborative approach to care.

Effect on patients and service users

The SPR aims to support improved information sharing across each individual involved in a person’s care in England. Legislation, and subsequent regulations, will support improved data sharing by providing a clear legal framework for the SPR system. This seeks to improve the experience and care of all patients and service users but particularly those who receive care across a range of health and care settings.

Additionally, patients and service users will be able to access their SPR through the NHS App, which, as set out in the 10 Year Health Plan, will become a “world-leading tool for patient access” and “full front door to the entire NHS”. The NHS App will provide a secure and user-friendly interface to view and interact with health information. Our ambition is that by 2028, through the NHS App, patients will be able to:

• view their full medical history and test results
• book appointments and tests
• manage medicines and vaccinations
• access support for long-term conditions
• co-ordinate care for children or dependants
• leave feedback on care received
• access a ‘health store’ with approved digital tools to manage or treat conditions

The NHS App will evolve into a comprehensive platform that uses the SPR as its foundation, enabling patients to manage all aspects of their healthcare from one place.

The SPR legislation, accompanied by positive behavioural changes, is intended to lead to:

• fewer patient safety incidents
• less need to recall medical history
• improved patient engagement with their health
• improved patient satisfaction

Engagement and involvement

As DHSC and NHS England know how important public trust is in how we use NHS data, across 2024 to 2025 we carried out a national public engagement programme. The people we engaged with were split into 3 cohorts. Each cohort discussed different questions about health and care data and went through 3 tiers of engagement. These were:

• tier 1: core deliberation - bringing together people who are reflective of the population of England to discuss and deliberate critical questions
• tier 2: inclusive engagement - engaging people from seldom-heard groups including those with health needs and in socially marginalised groups
• tier 3: deliberative survey - sending out an online survey to a nationally representative sample of people

Cohort 2 focused on the approach to creating an SPR and the use of GP data beyond individual care around the question “How should a single patient record be designed in a way that maximises the potential benefits and is trusted by the public?”.

Approximately 2,200 people participated, including individuals with specific health needs and those from socially marginalised communities. 

As recorded in the national engagement on data: cohort 2 report, there was support for an SPR across the tiers. The report of the engagement identified overall support for an SPR among tier 1 participants and that it was widely considered a “long overdue and necessary step towards better care”. In addition, over three-quarters of the 2,000 respondents to the deliberative survey (tier 3) were in favour of an SPR with under 10% against, 13% neither supporting nor opposing the concept and the remaining respondents ticking the ‘I don’t know’ box.

Tier 2 engaged with 76 people from seldom-heard groups including older people with long-term health conditions, people from ethnic minorities, those with a disability including a learning disability or sensory impairment and LGBT+ individuals. Tier 2 participants were “largely supportive of the move to a single patient record and echoed the same benefits [as tier 1 participants]”. In particular, the report identified that:

Those who frequently interact with health services (i.e. those with long-term and/or mental health conditions) spontaneously thought that the single patient record could improve the continuity of their care.

Feedback also made it clear that trust in the SPR was critical. The public made several policy recommendations, which were:

• proceed at pace
• demonstrate high levels of data security
• be transparent during implementation, as well as in day-to-day operation
• include a record of access
• constrained access is essential, so that not all health and care professionals have open access to all patients’ data
• ensure rigorous data use and data security training
• patient access is a must

These recommendations are integral to our planning and will inform our decision-making throughout the programme.

Analysis of impacts

Disability

The Office for National Statistics (ONS) Disability, England and Wales: Census 2021 publication showed that 17.7% of people in England were disabled. As of February 2026, the NHS Practitioner Health’s publication Disability, Health and Wellbeing reported that people with physical and mental disabilities are more likely to need health and care services than people without disabilities but may face greater barriers in accessing them.

NHS Practitioner Health also suggested that depending on the group and setting, people with disabilities may experience greater vulnerability to secondary conditions and co-morbid conditions, which typically require health and care services across a range of health and care settings.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the person. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all people, with patients who require health and care services across a range of health and care settings expected to disproportionately experience the benefits.

However, those who interact more with health services are likely to have more information held on records and will therefore feel the impact of cyber breaches more. Secure by design is one of the critical principles of the SPR and security will be at the centre of its design.

People with disabilities are more likely to be digitally excluded. In its report, Internet users, UK: 2020, ONS estimated that 15% of people disabled within the definition of the Equality Act had never used the internet in 2020, compared with 3% among non-disabled people.

While people who are digitally excluded should still benefit from health and care professionals having access to more complete and up-to-date information, they are less likely to immediately experience the benefits of personal access to the SPR through the NHS App. NHS England has published a digital inclusion framework to support NHS organisations to consider and address digital exclusion so that those who may find it harder to access NHS services digitally are not disadvantaged.

In addition, patients will access their SPR through the NHS App. As set out in its Managing health services for others guidance, since February 2026, the NHS has had a process to allow proxy access to the NHS App. This may help support those who are digitally excluded to enjoy the benefits of access to their record.

Sex

Women are generally more likely to use healthcare services, particularly women between the ages of 20 to 39 due to the use of maternity services. In addition, NHS England’s Health survey for England, 2021 part 2 showed that women are also more likely than men to report one or more longstanding health condition, which typically require services across a range of health and care settings.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans, do not always follow the person. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

Those who interact more with health services are likely to have more information held on records and will therefore feel the impact of cyber breaches more. ‘Secure by design’ is one of the critical principles of the SPR and security will be at the centre of its design.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all patients, with people who require health and care services across a range of health and care settings expected to disproportionately experience the benefits. Being able to access their own health data may also make it easier for patients to take active steps to understand and improve their health.

ONS’s publication Domestic abuse victim characteristics, England and Wales: year ending March 2024, shows that women are also far more likely to experience domestic abuse - they account for 72.5% of victims. People who experience domestic violence could face challenges in accessing their SPR through the NHS App, especially if they are being coerced or controlled - for example, if the abuser has control over their phone.

NHS England acknowledges this issue and it has published guidance on Safeguarding and the NHS App, which provides advice on minimising risk. As set out in the guidance, this may include restricting some or all of a person’s access to their clinical record through the NHS App. This could mean that people who experience domestic violence may be less likely to benefit from personal access to their record. Conversely, clinicians being able to access information kept on their records may still result in better, more sensitive care.

There are also persistent and emerging health inequalities that affect boys and men in England. A House of Commons Library research briefing on suicide statistics published in 2025 shows that suicide remains the leading cause of death among men under 50 in the UK and is 3 times more common among men than women. A Samaritans report on supporting less well-off, middle-aged men published in 2020 suggested that men, particularly those who are living in the most deprived areas of the UK, are significantly less likely to seek help for mental health issues due to stigma and societal expectations around masculinity.

Men are also more likely to engage in risky health behaviours such as smoking, excessive alcohol use and poor diet, and make fewer general practice appointments than women, including the NHS Health Check[footnote 1]. Being able to see their SPR through the NHS App may encourage them to engage more with their health and care.

The Ministry of Justice’s Offender accommodation outcomes, update to March 2024 reports that around 95% of people leaving prison are men, many of whom already face significant barriers to accessing healthcare and are more likely to experience multiple forms of exclusion, such as homelessness.

Stigma and discrimination play a major role, as negative experiences in healthcare settings can make prison leavers reluctant to engage with services. Fears of data systems by prison leavers (linked to fears of surveillance or misuse of data) could lead to further disengagement from the SPR and reduced benefits from the SPR. There are national schemes that seek to support individuals involved in the criminal justice system. These include the NHS England commissioned liaison and diversion services, which identify people who have mental health, learning disability, substance misuse or other vulnerabilities when they first come into contact with the criminal justice system as suspects, defendants or offenders.

These services can then support people through the early stages of the criminal system pathway and refer them for appropriate health or social care. The services could even enable them to be diverted away from the criminal justice system into a more appropriate setting, if required. Another NHS England commissioned service, RECONNECT, aims to improve the wellbeing of people leaving prison, reduce inequalities and address health-related drivers of offending behaviours.

Women are more likely to experience digital exclusion. The ONS report ‘Internet users, UK: 2020’ estimated that 7.3% of women in the UK had never used the internet in 2020, compared with 5.3% of men. This discrepancy was more pronounced in older people with 43.3% of women aged 75 years and above never having used the internet compared with 33.1% of men in the same age group.

While people who are digitally excluded should still benefit from health and care professionals having access to more complete and up-to-date information, they are less likely to immediately experience the benefits of personal access to the SPR through the NHS App. NHS England has published a digital inclusion framework to support NHS organisations to consider and address digital exclusion so that those who may find it harder to access NHS services digitally are not disadvantaged.

In addition, patients will access their SPR through the NHS App. As set out in its ‘Managing health services for others’ guidance, since February 2026, the NHS has had a process to allow proxy access to the NHS App. This may help support those who are digitally excluded to enjoy the benefits of access to their record.

Sexual orientation

Analysis in 2021 of English GP Patient Survey data found that adults from sexual minority groups are more likely than others to have long-term mental and physical conditions, adjusted for deprivation, ethnic group, region and age[footnote 2]. Long-term conditions typically require health and care services across a range of health and care settings.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all patients, with people who require health and care services across a range of health and care settings expected to disproportionately experience the benefits.

Those who interact more with health services are likely to have more information held on records and will therefore feel the impact of cyber breaches more. ‘Secure by design’ is one of the critical principles of the SPR and security will be at the centre of its design.

We could not find evidence to suggest that this group experiences differential digital exclusion.

Race

In England, there are health inequalities between ethnic minority and White groups, and between different ethnic minority groups. As reported in the ONS publication Ethnic group differences in health, employment, education and housing shown in England and Wales’ Census 2021, people from some ethnic minority groups are more likely to report being in poorer health.

A systematic review of the safety of healthcare for ethnic minority patients published in 2020 reported that evidence from across Organisation for Economic Co-operation and Development (OECD) countries points to an increased risk of patient safety incidents for ethnic minorities[footnote 3].

There is indicative evidence suggesting that minoritised ethnic groups have a higher risk of developing multiple long-term conditions and do so earlier than the White majority population[footnote 4], which typically require health and care services across a range of health and care settings.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all patients, with people who require health and care services across a range of health and care settings expected to disproportionately experience the benefits.

Those who interact more with health services are likely to have more information held on records and will therefore feel the impact of cyber breaches more. ‘Secure by design’ is one of the critical principles of the SPR and security will be at the centre of its design.

In 2018, a report published by Friends, Families and Travellers suggested that gypsies and travellers are more likely to suffer digital exclusion. In addition, vulnerable migrants face challenges when trying to access healthcare and often have poorer health outcomes or experiences with services. Language barriers make it difficult to understand information, navigate the health system and use the NHS App.

Recording of sensitive data on immigration status (or the fear of it) can also raise fears of surveillance or misuse, leading to disengagement from health services.

While people who are digitally excluded should still benefit from health and care professionals having access to more complete and up-to-date information, they are less likely to immediately experience the benefits of personal access to the SPR through the NHS App. NHS England has published a digital inclusion framework to support NHS organisations to consider and address digital exclusion so that those who may find it harder to access NHS services digitally are not disadvantaged.

In addition, patients will access their SPR through the NHS App. As set out in its ‘Managing health services for others’ guidance, since February 2026, the NHS has had a process to allow proxy access to the NHS App. This may help support those who are digitally excluded to enjoy the benefits of access to their record.

Age

The DHSC Adult social care activity report, England: 2024 to 2025 indicated that older people are more likely to use health and social care services. This finding is reinforced by NHS England’s Hospital outpatient activity 2024 to 2025, which reported that 59% of people receiving long-term support were aged 65 or over. The same report stated that patients aged 60 years and over accounted for 45.2% of all hospital outpatient attendances (50.8 million).

A whole population study in England found a higher prevalence of multiple long-term conditions in older people[footnote 5], which typically require health and care services across a range of health and care settings.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all patients, with people who require health and care services across a range of health and care settings expected to disproportionately experience the benefits.

However, those who interact more with health services are likely to have more information held on records and will therefore feel the impact of cyber breaches more. ‘Secure by design’ is one of the critical principles of the SPR and security will be at the centre of its design.

Older people are more likely to experience digital exclusion. In its report ‘Internet users, UK: 2020’, ONS estimated that, while almost all adults aged 16 to 64 years in the UK in 2020 had used the internet in the last 3 months (95 to 99%), this dropped to 86% in adults aged 65 to 74 and 54% in adults aged 75 years and over. This means that older people are less likely to benefit from personal access to the SPR through the NHS App.

While people who are digitally excluded should still benefit from health and care professionals having access to more complete and up-to-date information, they are less likely to immediately experience the benefits of personal access to the SPR through the NHS App. NHS England has published a digital inclusion framework to support NHS organisations to consider and address digital exclusion so that those who may find it harder to access NHS services digitally are not disadvantaged.

In addition, patients will access their SPR through the NHS App. As set out in its ‘Managing health services for others’ guidance, since February 2026, the NHS has had a process to allow proxy access to the NHS App. This may help support those who are digitally excluded to enjoy the benefits of access to their record.

Gender reassignment

Analysis in 2023 of NHS England’s 2021 GP Patient Survey, which had 840,691 respondents including 6,333 trans and non-binary adults, found that trans and non-binary adults are more likely to have certain chronic conditions including autism, dementia, learning disabilities and mental health conditions than the general population[footnote 6]. Chronic conditions typically require health and care services across a range of health and care settings. Not all trans and non-binary people will have the protected characteristic of gender reassignment, so this is not perfect data.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all patients, with people who require health and care services across a range of health and care settings expected to disproportionately experience the benefits.

However, those who interact more with health services are likely to have more information held on records and will therefore feel the impact of cyber breaches more. ‘Secure by design’ is one of the critical principles of the SPR and security will be at the centre of its design.

We could not find evidence to suggest that this group experiences differential digital exclusion.

Religion or belief

We could not find evidence to suggest any differential impacts based on religion or belief, as a result of the SPR legislation.

Pregnancy and maternity

Communication is particularly important in maternity services where there may be multiple handovers depending on:

• the duration of labour
• transfers between home settings and hospital - often in an emergency
• referrals between midwives and obstetricians

In the Care Quality Commission’s (CQC) report State of Care 2022 to 2023, poor communication was identified as an emerging theme affecting the quality of care for pregnant women.

Fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all patients, with people who require health and care services across a range of health and care settings expected to disproportionately experience the benefits.

Pregnant women are likely to interact more with health services and so are likely to have more information held on records and will therefore feel the impact of cyber breaches more. ‘Secure by design’ is one of the critical principles of the SPR and security will be at the centre of its design.

We could not find evidence to suggest that this group experiences differential digital exclusion.

Marriage and civil partnership

We could not find evidence to suggest differential impacts on those married or in a civil partnership as a result of the SPR legislation.

Other identified groups

These are not covered by the Equality Act 2010.

Socioeconomic background and geography are routinely included in considerations on health and social care policy. This is due to health inequalities, which are differences in health outcomes that are unfair and avoidable and which are rooted in socioeconomic background and geography.

Poor mental health is considered to be closely linked to health inequalities and is therefore also routinely included in considerations of health and care policy.

Socioeconomic background and geography

A 2023 review by Alvarez-Galvez and others on the social determinants of multi-morbidity patterns showed there is evidence for associations between multiple conditions and factors linked to socioeconomic disadvantage - such as low educational attainment, living in a deprived area and unhealthy lifestyles[footnote 7]. Multiple conditions typically require health and care services across a range of health and care settings.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across each individual involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is expected to have an indirectly positive impact on all patients, with people from lower socioeconomic backgrounds likely to disproportionately experience the benefits.

Ofcom’s Communications Affordability Tracker updated in 2026, provides evidence that low-income households are more likely to struggle to afford broadband and data.

While people who are digitally excluded should still benefit from health and care professionals having access to more complete and up-to-date information, they are less likely to immediately experience the benefits of personal access to the SPR through the NHS App. NHS England has published a digital inclusion framework to support NHS organisations to consider and address digital exclusion so that those who may find it harder to access NHS services digitally are not disadvantaged.

Social exclusion

Socially excluded individuals are either born into or pushed to the margins of society, which limits their ability to participate in social, cultural, economic and political life. Groups that are considered socially excluded include people experiencing homelessness, sex workers, prison leavers, care leavers, victims of domestic abuse, vulnerable migrants, victims of modern slavery and victims of modern trafficking. Healthwatch has previously carried out targeted outreach and research to understand the needs and experiences of these groups.

In 2021, the Ministry of Housing, Communities and Local Government (MHCLG) estimated in its Changing Futures prospectus that 363,000 adults (less than 1% of the general population) were experiencing multiple disadvantages across England. This includes a combination of homelessness, substance misuse, mental ill health, domestic abuse and contact with the criminal justice system.

Socially excluded groups intersect with protected characteristics. For example,

• women are overrepresented among sex workers, with male and transgender sex workers representing a smaller but significant minority[footnote 8]
• men make up the majority of the prison population and therefore also make up the majority of prison leavers
• those who are homeless are more likely to live with long-term physical or mental health conditions[footnote 9] [footnote 10], indicating a strong intersection between homelessness and disability. Older adults experiencing homelessness often display accelerated age-related health vulnerabilities[footnote 11]
• care leavers are predominantly young adults navigating the transition out of statutory support[footnote 12], representing a young cohort of socially excluded people

Socially excluded groups often experience poorer outcomes in health than the general population and have many similar undiagnosed and untreated long-term conditions arising from mental health, substance dependence, tuberculosis and sexually transmitted infections.

Socially excluded groups are more likely to face barriers when accessing healthcare services, leading to negative experiences and a greater risk of avoiding health services in the future. Common barriers include stigma and discrimination, low health literacy, digital exclusion, transport and logistics, a lack of trust in services and language barriers. As a result of poor access to services, evidence shows that socially excluded groups underuse some services, such as primary and preventative care, and often rely on emergency services such as A&E when their health needs become acute. For example, people experiencing homelessness use on average 4 times more acute hospital services than the general population. They have higher emergency and inpatient admissions, longer inpatient stays, delayed discharge and more frequent re-admittance to care.

Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across each individual involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings.

It is likely that people from socially excluded groups are more likely to experience digital exclusion. While people who are digitally excluded should still benefit from health and care professionals having access to more complete and up-to-date information, they are less likely to immediately experience the benefits of personal access to the SPR through the NHS App. NHS England has published a digital inclusion framework to support NHS organisations to consider and address digital exclusion so that those who may find it harder to access NHS services digitally are not disadvantaged.

Mental health

Effective mental health care requires collaboration between a range of health and care services. Currently, fragmented systems mean that vital information such as diagnoses, lab results, treatments, prescriptions and care plans do not always follow the patient. This can lead to repeated history taking, duplicate tests, delays in discharge and increased risk of patient safety incidents.

The SPR legislation aims to support improved information sharing across all individuals involved in a person’s care in England. This is especially important for people who are more likely to require health and care services across a range of health and care settings. The SPR legislation is therefore expected to have an indirectly positive impact on all patients, with people who require health and care services across a range of health and care settings expected to disproportionately experience the benefits.

In 2022, the National Institute for Health and Care Research (NIHR) published a national survey of people with a severe mental illness which found that around 4 in 10 (42%) lacked basic digital skills, such as changing passwords or connecting to wifi [footnote 13]. It also found that 46% of people with a severe mental illness lacked digital foundational skills or ‘skills for life’, which is twice as many as in the general population (22%). This means that people with severe mental illness may be less likely to benefit from personal access to the SPR through the NHS App. NHS England has published a digital inclusion framework to support NHS organisations to consider and address digital exclusion so that those who may find it harder to access NHS services digitally are not disadvantaged.

Summary of analysis

Overall impact

The SPR aims to:

• support improved information sharing across each individual involved in a person’s care in England
• empower individuals to take control of their health and care through secure online access to their health and care records and care plans

Those who are more likely to require health and care services across a range of health and care settings are most likely to benefit from the joined-up care that the SPR legislation will enable, including people with disabilities, older people and pregnant women. However, the benefits will be felt by any person who accesses health or care services.

Those who interact more with health services are likely to have more information held on records and will therefore feel the impact of cyber breaches more. ‘Secure by design’ is one of the critical principles of the SPR and security will be at the centre of its design.

Those groups that are more likely to experience digital exclusion, such as those with disabilities and the elderly, may not immediately benefit from the SPR. However, the NHS is seeking to address this through its digital inclusion framework. While people who are digitally excluded may not benefit from SPR from a patient access point, they should still benefit from health and care professionals having access to more complete and up-to-date information.

On balance, the SPR legislation is expected to have an indirectly positive impact on all patients, with groups more likely to access services or have complex health needs expected to disproportionately experience the benefits.

Addressing the impact on equalities

Digital exclusion is a significant challenge in several groups with particular protected characteristics and other characteristics as considered above.

The NHS digital inclusion framework supports delivery of the 10 Year Health Plan by providing a structured approach to addressing digital barriers across connectivity, skills, confidence and accessibility. It ensures digital transformation is inclusive and aligned with the plan’s ambition to personalise care, reduce inequalities and create a health system that works for everyone.

Digital inclusion initiatives include:

• the Digital Health Champions network was developed (in partnership with Digital Unite) specifically for people supporting others to manage their health online - it is now used by organisations ranging from integrated care boards (ICBs) to GPs, wellness groups and charities
• NHS England supporting public libraries to signpost and support their service users to use library computers and the internet to navigate the NHS website, create a log in and use the NHS App. This is especially important for individuals who:
  • do not have internet access at home
  • lack access to a device compatible with the NHS App
  • need a safe and supportive space to use digital health services

NHS England is planning further partnerships and collaborations to reach members of the public who need additional help and support to use the NHS website and NHS App.

Mitigating the risk of digital exclusion is one of 5 main priorities that NHS England has asked integrated care systems to address in their work to reduce healthcare inequalities. Consideration of the digitally excluded is embedded in the development of the SPR programme.

In addition, patients will access their SPR through the NHS App. As set out in its ‘Managing health services for others’ guidance, since February 2026, the NHS has had a process to allow proxy access to the NHS App. This may help support those who are digitally excluded to enjoy the benefits of access to their record.

Mitigating the risk of cyber attack or inappropriate access to the SPR is also a main aim of the design programme. ‘Secure by design’ is one of the critical principles of the SPR ensuring that security will be at the centre of its design.

We will consider further mitigations alongside the development of the SPR programme.

Monitoring and evaluation

Our approach to monitoring and evaluating the equalities impact of the SPR legislation will remain proportionate and iterative. As the SPR programme continues through discovery and the subsequent development of regulations, we will keep the potential impacts on different groups under review.

At this stage, high-level monitoring and evaluation plans have been developed to understand how the impact of the SPR legislation could be tracked over time. This identifies potential indicators that would allow government to understand whether:

• the legislation is being implemented as intended
• health and care providers comply with new duties
• patients and service users are able to exercise their new rights

Part of that monitoring will look at the specific impact on equalities.

Monitoring will depend on the availability and quality of data. Some indicators, such as patient and clinician engagement, may require new surveys or data collections. Many of the longer-term outcomes - such as reduced waiting times and improved clinical outcomes - will also depend on the effective technical delivery of the SPR and broader NHS reform initiatives. In practice, it may be difficult to isolate the specific effects of the legislation from other concurrent reforms. Monitoring data would therefore provide useful assurance and directional evidence, but not definitive attribution.

The effectiveness of the legislation will also depend on external factors beyond its direct control, including:

• provider and supplier capacity to comply
• the interoperability and quality of underlying data systems and the data held in them
• levels of patient trust
• digital inclusion and delivery of the wider NHS digital agenda

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