Security & UK GDPR for Clinic Websites (Owner Essentials Only)
Running a GP practice or healthcare clinic is demanding enough without becoming a cybersecurity or GDPR specialist. The good news is: there are a handful of website checks and fixes that owners and practice managers can understand, verify, and action – without reading legislation.
This guide focuses on practical steps you can take now to make your website safer, clearer for patients, and better aligned with UK GDPR, NHS expectations and accessibility (WCAG).
The 5 must‑haves you can check now
These are simple, “owner‑level” checks you can do in under an hour. You may need your web agency or IT provider to fix issues, but you can verify them yourself.
1. SSL (HTTPS) on every page
Your site should load securely with a padlock in the browser bar and the address starting with https://, not http://.
Why it matters for clinics:
- Patient forms may include health information (special category data under UK GDPR)
- SSL encrypts data in transit so it cannot easily be intercepted
- Browsers now warn users when a site is “Not secure” – a clear trust issue for a healthcare provider
How to check
- Visit your homepage and a few subpages.
- Confirm:
- There is a padlock icon in the address bar
- The URL begins with https://
- There are no warnings like “Not secure” What to ask your supplier if it’s wrong
- “Please ensure a valid SSL certificate is installed, auto‑renewed and enforced across the whole site, including forms and admin/login areas.”
- “Redirect all http traffic to https.”
2. Basic security headers
Security headers are technical settings that tell browsers how to handle your site more safely. You don’t need to configure them yourself, but you can check quickly.
Key headers your developer should know:
- Content-Security-Policy (CSP) – helps prevent cross‑site scripting attacks
- X-Content-Type-Options
- X-Frame-Options or
frame-ancestorsin CSP - Referrer-Policy
- Strict-Transport-Security (HSTS) – enforces HTTPS How to check (owner‑friendly)
- Use an online “security headers checker” tool.
- Enter your website address.
- Review the report: you’re looking for most of the above headers to be present.
What to ask your supplier
- “Please review and enable standard security headers appropriate for an NHS/healthcare provider site, including HSTS, X‑Content‑Type‑Options, X‑Frame‑Options or CSP, and Referrer‑Policy.”
You do not need to decide the exact settings – your role is to insist they are in place and documented.
3. Clear privacy notice (UK GDPR‑aligned)
Under UK GDPR, you must provide privacy information that is fair, transparent and easy to understand, explaining how you process patient and visitor data. For GP practices, this is usually called a Practice Privacy Notice or Privacy Policy.
Owner‑level checklist On your website, you should be able to find a page labelled something like:
- Privacy Policy
- Practice Privacy Notice
- How we use your information
That page should:
- Be linked in the footer on every page
- Explain:
- Who you are (e.g. the practice as data controller)
- What data you collect via the website (e.g. forms, cookies, online services)
- Why you collect it (purposes – e.g. direct care, appointments, queries)
- Your lawful bases (e.g. public task, legal obligation, consent where relevant)
- Who you share data with (e.g. NHS bodies, processors such as form providers)
- How long you keep data
- Patient rights and how to exercise them
- Contact details for data protection queries (and DPO, if you must appoint one)
NHS and BMA templates can help ensure you cover expected content for GP practices, as long as you adapt them to your own systems and tools.
4. Cookies & tracking information
Even if UK cookie rules are becoming more flexible for low‑risk cookies (like basic analytics), you still need to be transparent about what you’re using and why.
For a typical GP/clinic site, you might have:
- Essential cookies (needed for the site to work)
- Analytics cookies (e.g. Google Analytics or similar)
- Tools embedded by NHS or third‑party systems (eConsult, Accurx web link, appointment booking, feedback tools) Owner‑level checks
- Look for:
- A cookie banner or cookie message when you first visit the site A Cookies page or section, usually linked from:**
- The footer, or
- The privacy policy
That cookies information should:
- List the main cookies or categories used
- Explain their purpose (e.g. “helps us understand how patients use the site”)
- Clarify where consent is used and how patients can change preferences
If your site is accessible from the EU (it usually is), your consent approach needs to be compatible with both UK GDPR and EU GDPR – another point for your supplier to manage technically, but you should be aware of it.
5. ICO registration visible in the footer
Almost all GP practices and UK healthcare providers must register with the Information Commissioner’s Office (ICO) and pay the data protection fee. What you should see on your website In the footer (bottom of every page), you should ideally display:
- Your organisation name
- “Registered with the Information Commissioner’s Office”
- Your ICO registration number (e.g. Z1234567)
Example (footer line):
“Data controller: Example Medical Practice. Registered with the Information Commissioner’s Office (ICO), registration number Z1234567.”
How to check
- Ask your practice manager or business manager for your ICO number, or
- Search the ICO’s public register using your practice name or postcode.
If you are not registered and you handle personal data electronically (which almost all practices do), that is a red flag – you should address registration immediately.
Safer forms & routing
Most real risk on a clinic website sits in contact, registration and clinical forms. These can inadvertently collect too much data or be used inappropriately (e.g. for emergencies).
Make every form “data‑minimised”
UK GDPR requires you to collect only the minimum data necessary for the purpose. What owners can verify Open each form on your site and ask:
- Is every question clearly necessary for the task?
- Are we asking for clinical detail when we only need a basic query?
- Are we asking for more identifiers (e.g. date of birth, NHS number) than needed?
Examples
- Contact us (non‑clinical) form
- Reasonable fields: name, contact details, simple message
- Usually not appropriate: full medical history, detailed symptoms
- New patient registration / clinical forms Can be more detailed, but:
- Make clear they are not for urgent or emergency care
- Ensure they are transmitted securely and integrated into clinical systems safely
Where forms are powered by third‑party platforms (e.g. Accurx, online triage tools), ensure:
- Your privacy notice explains this
- You have appropriate contracts/Data Processing Agreements in place
- Links from your site make clear you are sending patients to a trusted NHS‑aligned service
Clear “not for emergencies” wording
A critical patient‑safety and legal risk is patients using web forms for urgent or emergency issues.
Owner‑level actions On every form that can receive patient queries or clinical information:
- Add a very clear statement such as:
- “This form is not monitored 24/7 and must not be used for urgent medical problems or emergencies.”
- “If you need urgent medical help, please contact NHS 111, or dial 999 in an emergency.”
- Place this wording:
- Above the form
- Near the submit button
- In plain language, large enough to notice
This protects both patients and the practice by setting realistic expectations about response times and routes for urgent care.
Routing forms to the right mailbox or system
Security is not just about encryption; it is also about who receives the information.
Checks you can make
- Where do form submissions go?
- A secure NHSmail account (e.g. nhs.net)
- An internal, role‑based mailbox (e.g. admin@practice.nhs.uk rather than a personal inbox)
- Direct into a clinical system via a secure, approved integration
- Are auto‑responses clear on response times?
- “We aim to respond within X working days”
- Reiterate that it is not for emergencies
If your site is sending form data to generic cloud email accounts (e.g. Gmail, Outlook.com, Hotmail) outside of agreed NHS or clinical systems, you should treat that as a priority to review and improve.
Policies hub page in the footer
Patients and regulators expect to find all “legal and information” pages easily. The simple way to do this is a Policies or Information Governance hub, reachable via the footer.
What your footer should include
At a minimum, your footer should link to:
- Privacy Policy / Practice Privacy Notice
- Cookies information
- Terms of use or Website disclaimer
- Accessibility statement (aligned with WCAG and public sector accessibility regulations)
- Complaints information / feedback process
- ICO registration wording and number
For GP practices, you might also add:
- Patient charter or “How we use your data”
- Online consultation tools information (e.g. Accurx, eConsult, Klinik)
- Data sharing & opt‑out information
How to structure a simple “Policies” hub page
Create a dedicated page (e.g. “Policies & Information”) and link to it from the footer.
On that page, provide:
- A short introduction in plain English:
- What the page is for
- Who to contact for questions
- A clearly labelled list of key policies, for example: Core policies
- Practice Privacy Notice (how we use your information)
- Cookies and tracking
- Website terms of use
- Accessibility statement
Data and confidentiality
- How we share your information (NHS data sharing, local pathways, research where applicable)
- National data opt‑out information
- ICO registration details Feedback and complaints
- Complaints procedure
- How to raise concerns about data protection
This structure supports your UK GDPR transparency duties and makes it easier for patients, carers and inspectors to find what they need.
When to escalate a review
You do not need a lawyer every time you tweak your website. But you do need to escalate when you spot higher‑risk issues.
Escalate to your DPO / data protection lead if:
- Your site has no privacy policy or an obviously outdated one (e.g. references EU‑only law, old contact details, or missing online services you now use).
- You discover you are not registered with the ICO, or the register shows incorrect details.
- Forms are collecting detailed health information and sending it:
- To non‑NHS personal email accounts, or
- To tools not covered by an existing agreement or DPIA.
- You plan to introduce:
- Online triage/consultation tools
- New third‑party platforms that will store or process patient data
- AI‑driven tools for screening, triage or decision‑support
These situations usually require:
- A Data Protection Impact Assessment (DPIA)
- Contract checks and potentially updates to your privacy notice
- Input from your DPO or external data protection advisor
Escalate urgently if you suspect a breach
If you become aware of:
- Form submissions going to the wrong recipient
- Website access or admin passwords compromised
- Unexpected data appearing in public (e.g. cached forms in search results)
- A misconfiguration that may have exposed patient data
Treat this as a potential personal data breach. Immediately:
- Inform your DPO or data protection lead
- Involve your IT supplier
- Follow your practice’s incident reporting procedure
They will decide whether the ICO and/or affected individuals need to be notified, and within what timeframe.
Add your ICO number (where and how)
Displaying your ICO registration is a small but powerful trust signal.
Where to show your ICO registration
In the footer (every page) Include a line such as:
- “Registered with the Information Commissioner’s Office (ICO): Z1234567”
On your Policies hub or Privacy page Add a short section:
- Name of the data controller (practice name)
- Contact details
- ICO registration number and, if useful, a brief note explaining that the ICO is the UK’s data protection regulator In your privacy notice When you describe who you are and how to raise concerns, add:
- “We are registered with the Information Commissioner’s Office (ICO), registration number Z1234567.”
This demonstrates you take data protection seriously and makes it easier for patients to check your details if they wish.
Key takeaways
For busy GP partners and clinic owners, focus on what you can see and control: Technical basics
- SSL (HTTPS) on every page
- Security headers implemented by your web/IT supplier
Transparency
- Clear, up‑to‑date Privacy Notice tailored to your actual tools and data flows
- Cookie information that accurately reflects the tracking you use
- A Policies hub page, clearly linked in the footer Forms and patient safety
- Data‑minimised forms: only ask for what you really need
- Prominent “not for emergencies” wording on all query or clinical forms
- Forms routed to secure, appropriate inboxes or clinical systems
Governance
- ICO registration in place and clearly displayed (especially in the footer and privacy documentation)
- Escalate to your DPO or specialist whenever:
- You introduce new digital tools that handle patient data
- You suspect a data breach
- Core documentation (privacy notice, accessibility, complaints) is clearly out of date
Conclusion & Next Steps
You do not need to be a GDPR expert to spot the most common website risks. As an owner or practice manager, your role is to:
- Insist on visible safeguards (HTTPS, clear policies, emergency wording)
- Ask the right simple questions of your suppliers (security headers, secure routing, DPIAs)
- Make sure your website clearly explains how you use data and where patients should go in an emergency
Suggested next‑week action plan
- Review your site for the 5 must‑haves:
- HTTPS, security headers (via a simple checker), privacy policy, cookies info, ICO number in the footer.
- Audit all forms:
- Check questions are necessary, add/confirm “not for emergencies” wording, verify where submissions go.
- Create or update your Policies hub page and footer links:
- Privacy, cookies, accessibility, complaints, ICO details.
- Book a short meeting with:
- Your DPO or data protection lead, and
- Your website/IT supplier to review your findings and agree any fixes, DPIAs or policy updates.
By tightening these essentials, you substantially reduce legal and reputational risk, improve patient trust, and demonstrate that your practice treats data protection as a core part of safe, high‑quality care.
 for Clinic Websites (Owner Essentials Only)](/images/blog/24.webp)