The single patient record

HEALTH BILL · SINGLE PATIENT RECORD

The Health Bill creates a single patient record for everyone who receives NHS care in England. It sets out in detail how information will be compelled into that record, and how failure to comply will be punished. It says almost nothing about who may look at it, or what a patient can do about it. This page sets out our position on that gap; the two pages beneath it collect everything we have filed, in the Commons and now in the Lords.

Our position, in short

The record is a good idea. A clinician who cannot see what a patient was prescribed, treated for last year, or is allergic to makes worse decisions, faster and under more pressure than anyone would choose. Nothing we argue asks for information to be deleted, hidden from a treating clinician who needs it, or withheld where a patient’s safety depends on it being seen.

But the clause protects the wrong party. Where a financial penalty is involved, the Bill mandates a notice, a chance to make representations, a decision, a final notice and a right of appeal — every step specified and enforceable. Where a patient’s most sensitive information is involved, the only safeguard is that the Secretary of State must “have regard to the need to ensure that adequate safeguards are in place.” One party is given a procedure. The other is given a state of mind.

The person facing a fine is given a procedure. The patient facing disclosure is given a state of mind.

The gap is specific. The clause does not require role-based access, so nothing on its face limits what any professional may see to what their involvement in a patient’s care requires. It does not require an audit trail, so nothing guarantees a record is kept of who has looked, still less that a patient can see it. It gives a patient no means of restricting routine access to information they have particular reason to protect. And the words child, young person, competence and capacity do not appear anywhere in it.

Assurances are not the same as the Bill. Ministers gave assurances on several of these points as the Bill went through the Commons — role-based access with an audit trail, clinician redaction of sensitive information, proxy access set out in regulations on the patient’s consent. Every one of them is welcome. Not one of them is in the Bill. An assurance given at the despatch box binds the minister who gives it for as long as they hold office; a provision in a statute binds whoever comes next.

What we are asking for

That the core access and confidentiality safeguards be placed on the face of the Bill: access limited to what is necessary and proportionate to a person’s involvement in the patient’s care; an auditable record of access, with intelligible information from it ordinarily available to the patient; a means for a patient — including a competent young person, acting personally and confidentially — to restrict routine access to sensitive information; and access exercised on a patient’s behalf granted, scoped, reviewed and withdrawn according to stated criteria.

It preserves clinical safety absolutely — a lawful route through wherever access is necessary for safe care, safeguarding or the prevention of serious harm, and nothing touching disclosures required by law or by a court. It would not delay the record, and it would not require the Department to abandon a single stated policy. Where a safeguard is already the Government’s intention, putting it in the Bill cannot frustrate that intention — it secures it.

Why this matters now

The record is to be switched on first in the maternity and frailty pathways — among the most confidentiality-sensitive areas of care there are, taking in concealed pregnancy, termination, the disclosure of domestic abuse, safeguarding and fluctuating capacity. The design is to begin with precisely the patients for whom a confidentiality failure is most consequential, and to do so before any of these safeguards exists in law. A record that patients do not trust does not become a smaller record; it becomes an incomplete one that still looks comprehensive — which is more dangerous to the clinician reading it than an obvious gap would be.

Where it stands

We are a party to this matter, not a neutral observer. Everything we have filed rests on the Health Bill and on documents the Government has itself published.

In the House of Commons — the Bill began in the Commons. We submitted written evidence to the Public Bill Committee, published on the parliamentary record as HB130, and set out the argument in public. The safeguards gap was not resolved there; at Report stage it was not reached. The Bill left the Commons genuinely open.

In the House of Lords — the Bill received its First Reading on 9 September 2026 and comes to Second Reading on 13 October. This is the live phase. We have made a submission to the Delegated Powers and Regulatory Reform Committee, and briefed members on the amendment we are asking be moved at Committee stage.

Why we are involved, and how

Eden Openly publishes evidence reviews and appraisals in trans healthcare and dermatology. This clause is not about that subject, but it runs straight through it: the single patient record will hold information about care that patients have the strongest possible reasons to keep controlled. We hold no commercial relationship with any supplier of NHS digital systems, and everything we file rests on the Bill and the Government’s own published documents. Our full position on funding and interests is set out in our statement of independence.

Confidentiality is not a constraint on the single patient record. For some patients, it is the condition of the record working at all.

Eden Openly is an independent clinical health-education publication. It receives no funding from, and has no commercial relationship with, any provider of gender-related healthcare, any pharmaceutical company, or any supplier of NHS digital systems. Statutory text checked against the Health Bill as amended in Committee (Bill 131), new sections 250E and 250F of the National Health Service Act 2006. Corrections and queries: [email protected].