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Internet First policy and guidance consultation outcome report

Release date: January 2020

The purpose of this report is to provide a summary of the consultation with industry and the health and social care sector on implementing the principle of Internet First.

Background to the consultation

To support the government strategy of moving to a wholly internet-based provision and the architecture principles in the Secretary of State’s vision for data and technology in health and care (October 2018), NHS Digital has established a team to: 

  1. publish the Internet First policy for the health and social care sector and signpost to industry-based standards and guidance
  2. develop an optimal roadmap for NHS Digital’s digital services
  3. develop and publish the future Internet First future operating model
  4. provide advice/support to third party digital service owners (as required)
  5. maintain oversight of progress, risks and issues and quarterly updates to the Secretary of State

Following the publication of the Internet First policy and guidance in May 2019, NHS Digital sought views from industry and health and social care digital leaders. The primary aim of the consultation was to gain an understanding of the impact of delivering the Internet First policy to the Secretary of State aspirational timeline of March 2021. Views were also elicited on the content of the policy and guidance in order to inform any changes or additional content that would be needed.

To gather views, we ran consultation through a series of webinars, an online survey and a number of workshops:

Engagement activities used
Channels Target audience Purpose

Online survey

(24 May 2019 to 14 June 2019)

  • Health and social care digital leaders

Views on the Internet First policy and guidance

41 people responded to the survey


(7 June 2019, 11 June 2019, 14 June 2019)

  • Industry
  • Health and social care digital leaders

Raise awareness of the Internet First policy and guidance; and ask questions

285 people registered. Approximately of 55% dialled in. Slides sent to all registered


(18 September 2019)

  • Industry, including network and digital service providers
  • Innopsis
  • techUK

Ask for industry views to help shape the Target Operating Model

396 people registered

Approximately 74% dialled in

Some non-attenders requested the slides and webinar recording

53 people volunteered to participate in the industry workshop and 31 people interested but wanted more information

83 people requested to be added to the Internet First mailing list

Discovery Workshops

  • Health and social digital leaders covering the North, South, East and West regions. Participants included Acute Trusts, CCGs, local authorities and social enterprise organisations providing NHS funded care services.

To understand the appetite, impact, risks, issues and mitigating actions.

Digital service consumer and supplier meetings

  • Industry
  • Health and social digital leaders

To understand implementation plans to move to Internet First

Expert meetings

  • Future Network for Government (FN4G)
  • National Cyber Security Centre (NCSC)
  • NHS Digital’s experts: commercial, security, service management, Cloud, HSCN, technical architecture and networking
  • Innopsis
  • techUK

To understand legislation, specialist issues and industry views related to moving to Internet First

Social media:

LinkedIn, Twitter

  • Industry
  • Health and social digital leaders

Raise awareness of the Internet First policy and guidance

Online survey questions

Internet First Policy and Guidance consultation


The Internet First Policy and Guidance supports the UK government strategic direction and the Internet First architecture principles. The Secretary of State described these in his ‘vision for digital, data and technology for health and care’ in October 2018, for digital services to be accessible over the internet.

The purpose of this guidance is to assist health and social care organisations, digital service suppliers and network providers to adopt the Internet First principles and to start planning to make digital services available over the public internet.

Please complete this survey on behalf of your organisation. We expect this survey will take no more than 15 minutes to complete but will vary depending on the level of detail in your response.

It is essential that you read the Internet First Policy and Guidance document prior to completing the survey. A PDF version of the document can be found at the bottom of this page.

Why we are consulting

We are consulting with health and care organisations to understand the potential impact the Internet First Policy and Guidance could have and to find out what further support is required.

Organisation Information

  1. What is your organisation name? (Required)
  2. What is your organisation’s Organisation Data Service (ODS) code?

You can find your ODS code using the ODS portal

  1. What type of organisation do you work for? (Required)

Please select only one item:

  • Ambulance Trust
  • Clinical Commissioning Group
  • Private sector provider of health and social care services
  • NHS Trust
  • GP Practice
  • Local authority
  • Pharmacy
  • Dentist
  • Opticians
  • Other - please specify
  • If "Other" please specify the type of organisation
  1. What is your area of expertise? (Required)

Please select only one item:

  • Technical
  • Clinical
  • Business services
  • Leadership, director or chief officer
  • Other – please specify
  • If "Other" please specify your area of expertise below.

Policy documents

How aware are you of the following policy documents? (Required)

  1. Please select an option for each document from the table below:

1 – not heard of

2 – heard of but not read

3 – heard of and read but taking no action

4 - heard of and read and planning delivery

5 – heard of and read and in delivery/completed delivery

UK Government Cloud First policy (2013)


Government Transformation Strategy (2017)


Vision for digital, data and technology in health and social care (2018)


NHS Long Term Plan (2019)


System Readiness

Questions on the systems you currently use.

  1. How do you currently use N3/TN/HSCN?

N3 is the name for the private network for health care which was used up to 2018. HSCN is its successor, the Health and Social Care Network. However, there is an intermediate state between the two called the Transition Network (TN).

Please select all that apply:

  • To consume digital services
  • Provide digital services to others
  • Don’t currently use N3/TN/HSCN

Please note that you only need to answer questions 7 and 8 if you selected 'Provide digital services to others' to this question. If not, move to question 9. (Required)

  1. How many health and social care digital services, provided by your organisation, do you consider to be in scope of the Internet First Policy and Guidance and need remediating to become available over the public internet? (Required)

Please select only one item:

  • 0
  • Between 1 and 10
  • Between 11 and 50
  • Between 51 and 100
  • Between 101 and 199
  • Equal to or greater than 200
  • Don’t know or not applicable
  1. The aspiration of the Secretary of State is for all health and social care digital services to be accessible over the public internet by March 2021. When do you foresee your organisations digital services that are reliant on the HSCN being available over the public internet? Please enter a number in each of the boxes below for each digital service.

    By digital services we mean systems and applications and services that are used by health care professionals whose requirements are to be externally accessible beyond being an on-premise service only accessible on a local area network.

    The public internet is that part of the internet that is open access to all consumers (for example, clinicians and citizens) regardless of the provider or location.  However, user registration or password is usually required for the consumer to gain access.

    For example, if you have 100 digital services and 50 are available on the internet now, put 50 in the 'available now' box.  You should then add the remainder in the other boxes, ensuring the total adds up to 100.

Available now (Required)


Between now and March 2021 (Required)


After March 2021 (Required)


Not yet planned/don’t know (Required)


Based on your response above, please provide supporting comments to explain your response in the space below.

  1. Are there areas not covered by the Internet First Policy and Guidance where further support is required to assist you in implementing the Internet First principles? Please put your comments in the space below.
  2. If you would you like to be added to NHS Digital’s Internet First programme mailing list to receive information and further updates, please enter your email in the space below.

Consultation feedback

There are a number of key findings from NHS Digital’s engagement activities to date which can be categorised under the following four themes:

1. Principle

In principle consumers and suppliers of digital services recognise and support the Government and Secretary of State for Health’s vision to move to Internet First.

2. Time

Many organisations have built their digital services and architecture on the provision of a centrally provided national private network and will have to initiate a significant change programme to move away from this reliance.

A significant proportion of legacy systems were not designed to operate outside the boundary of the national private network, N3/Health and Social Care Network (HSCN) or secured to be accessible over the internet and any ‘rush’ to make this happen adds risk and costs.

A number of organisations are planning to move to cloud services but see this as a five year plus plan.

Information is needed on the health and social care’s strategic direction for Internet Protocol (IP) Addressing, in order to deal with the issue that the availability of IPv4 address will be exhausted in the next few years.

The wider health and social care sector have a dependency on the NHS Digital roadmap in order to remove their reliance on the centrally managed private network.

3. Capability

Concerns were raised on the local capability to define, negotiate and manage contract terms. A central body (NHS Digital presently) is able to utilise economies of scale to leverage control over suppliers to ensure best value, financially, contractually and for quality of service.

Concerns were raised around the capability to rearchitect products that had accumulated significant technical debt and knowledge of how systems operate has been lost over time.

There is a general misconception that private networks, are secure and some applications were developed on the basis that the risk of attack on the private network did not exist.

Organisations also raised concerns that under Agenda for Change pay restrictions they are unable to resource locally at the higher level of subject matter expertise. Leaving a reliance on central bodies for access to this expertise, for example security/cyber.

There was a lack of awareness on the full service offering of HSCN and the knowledge that it had been designed to support transition to Internet First providing both private and bidirectional public connectivity.

Further advice and support on how to implement the Internet First policy is required for the less digitally mature organisations.

4. Cost

Additional costs will be incurred to update digital services and infrastructure. This will be exacerbated if carried outside of planned ‘technology’ re-fresh points.

Replicating the oversight and support provided by the central body (NHS Digital) at a local level will increase the overall cost to the health and social care sector as well as at a local level (removing the economy of scale).

Actions arising from consultation

Based on the key findings, the following actions have been identified:

  1. the policy and guidance have been separated into independent documents, with some new sections added and updates to provide further clarity
  2. further implementation guidance and support will be provided by NHS Digital to assist organisations in the remediation of digital services to be compliant with the Internet First policy and industry standards and guidance
  3. NHS Digital has prioritised the remediation of the Spine core services, NHS identity (strategic authentication) and the Application Programming Interface Management Tool as the key enabling digital services for the wider health and social care sector
  4. NHS Digital included within the Secretary of State’s HSCN July 2019 briefing a summary of the key findings from consultation, including the feedback that the move to Internet First is seen as a five year plus roadmap
  5. NHS Digital’s HSCN team participated in the consultation and have taken actions to increase the awareness of the HSCN hybrid network service offering

Next steps

NHS Digital is working with industry and health and social care digital leaders to shape the Internet First future operating model.

Further information

internal Internet First Policy

In line with the government strategic direction, this is the Internet First policy defined by NHS Digital.

Last edited: 10 March 2020 9:22 am