Compliance with the Data Security and Protection (DSP) Toolkit becomes mandatory if your organization handles NHS data. However, passing the assessment, especially in regulated environments, is often more challenging than expected.
One of the most common reasons organisations fail? Incomplete or inconsistent encryption practices.
While the toolkit outlines clear requirements for encryption and access control, many IT and security teams struggle to enforce them consistently across departments, systems, and file types. And under scrutiny, vague policies or partial protections simply won’t cut it.
The DSP Toolkit is technically a self-assessment, completed online through the NHS portal. But this doesn’t mean reduced scrutiny.
Organisations handling sensitive data or flagged during the assessment process may face spot checks or external audits from NHS Digital, ICBs, or other third-party assessors. That’s why your encryption, access controls, and audit trails need to be ready for physical inspection.
So, whether you're approaching your first assessment or tightening your posture ahead of renewal, we’ll cover the following to help you avoid the most preventable compliance risks.
- Why encryption is a critical part of DSP Toolkit compliance
- Common gaps and oversights flagged during audits
- Actionable ways to close those gaps using file-level controls and automation
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Why Encryption is Critical for DSP Toolkit Compliance
The DSP Toolkit requires sensitive data to be encrypted at-rest and in-transit, but passing this control means more than turning on BitLocker or VPNs.
You need to show that:
- File-level encryption policies are in place and enforced across the organisation
- Access controls are assigned based on roles, not just device-level protections
- Audit trails exist for sensitive file access, movement, and sharing
- Encryption continues to apply even when files leave secure environments
Without these, you risk failing key evidence checks under Data Security Standards 1 and 9, both of which are central to the toolkit.

Where Most Organisations Fall Short
These examples aren’t rare cases; they are common issues flagged in DSP Toolkit assessments and follow-up audits every year. And with NHS digital frameworks under increasing scrutiny, assessors are more focused than ever on evidence, not intention.
Even mature IT and security teams often fall into one or more of these traps:
- Relying solely on device-level encryption instead of securing data at the file level
- Assuming cloud storage providers are handling compliance for them
- Not having a clear inventory of where sensitive data lives or how it’s being accessed
- Lacking real-time visibility into whether encryption policies are consistently enforced
Best Practices to Strengthen Encryption Compliance
To pass your assessment and protect day-to-day sensitive data, your encryption strategy needs to be practical, provable, and persistent.
Here’s what that looks like:
- Secure Files at the Source
Apply encryption at the file level so that data stays protected whether it's stored locally, moved to a USB, shared via email, or uploaded to the cloud. - Enforce Access Controls
Role-based access policies that restrict files based on user type, department, or data classification. This reduces human error and ensures consistent policy enforcement. - Create an Audit-Ready Evidence Trail
Collect logs that show when sensitive data is accessed, by whom, and under what conditions. Even if you're not audited immediately, you'll need to retain these records for future proof or spot checks. - Monitor for Policy Drift
Regularly verify that encryption policies are still being followed, especially when files move between systems, locations, or users.
Proactive Compliance Is the Real Advantage
The organisations that pass DSP Toolkit assessments with confidence are those who have embedded controls into their infrastructure to ensure:
- Ongoing encryption coverage across departments
- Minimal manual intervention or oversight
- Clear, audit-ready records that can be exported instantly
These capabilities don’t just help you complete the DSP Toolkit; they prepare you for unexpected scrutiny, partnership reviews, or cyber resilience assessments down the line.
As a result, they don’t just mitigate compliance risks; they build trust with NHS partners and patients alike.
Turn Encryption from a Risk into a Compliance Strength
You don’t need to overhaul your entire security infrastructure to meet DSP Toolkit compliance; you just need encryption and access controls that actually work in real-world conditions. That means going beyond policy documentation to put provable protections in place, especially around files that contain NHS patient data or sensitive internal records.
If you can’t see who’s accessing data, where it’s going, or whether it’s still encrypted, you can’t prove compliance.
🚀 Encryption Gaps = Compliance Risk
Stay audit-ready all year-round with consistent, per-file-level protection.
FAQs: NHS DSP Toolkit Assessment
Is Cyber Essentials a requirement for the DSP?
For most NHS contractors and larger organizations, holding a valid Cyber Essentials (or Cyber Essentials Plus) certificate is a mandatory "evidence item" within the toolkit. Even where not strictly mandatory, having Cyber Essentials covers a significant portion of the technical requirements needed to meet the "Standards Met" grade.
How often do we need to submit the DSP assessment?
The assessment must be completed and submitted annually. The deadline is typically the end of June each year, but organizations must ensure they are maintaining the standards year-round, as the toolkit reflects your security posture at the time of submission.
What is the most common technical reason for failing a DSP assessment?
Common technical gaps include unsupported operating systems (End-of-Life software), a lack of Multi-Factor Authentication (MFA) on remote access systems, and insufficient evidence of regular staff security awareness training.
How does encryption play into the DSPT requirements?
The DSP requires all portable devices (laptops, tablets, phones) and removable media containing personal data to be encrypted to industry standards (e.g., BitLocker or FileVault). Furthermore, any patient data sent over public networks must be encrypted in-transit, typically using TLS 1.2 or higher.