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The Information Commissioner’s Office (ICO) has issued a reprimand to NHS Lanarkshire, following staff’s unauthorised use of WhatsApp to share patients’ personal data over the course of two years.

Between April 2020 and April 2022, 26 staff at NHS Lanarkshire had access to a WhatsApp group where patient data was entered on more than 500 occasions, including names, phone numbers and addresses. Images, videos and screenshots, which included clinical information, were also shared.

While it was made available for communicating basic information only at the start of the pandemic, WhatsApp was not approved by NHS Lanarkshire for processing patient data and was adopted by these staff without the organisation’s knowledge.

A non-staff member was also added to the WhatsApp group in error, resulting in the inappropriate disclosure of personal information to an unauthorised individual.

Once NHS Lanarkshire became aware, it reported the incident to the ICO. The ICO’s investigation concluded that NHS Lanarkshire did not have the appropriate policies, clear guidance and processes in place when WhatsApp was made available to download. For example, there was no assessment of the potential risks relating to sharing patient data in this way.


John Edwards

“Patient data is highly sensitive information that must be handled carefully and securely. When accessing healthcare and other vital services, people need to trust that their data is in safe hands.

“We appreciate that NHS Lanarkshire, like all healthcare providers, was under huge pressure during the pandemic but there is no excuse for letting data protection standards slip.

“Every healthcare organisation should look at this case as a lesson learned and consider their own policies when it comes to both messaging apps and processing information about patients. We will be following up with NHS Lanarkshire to ensure that patient data is not compromised again.”

- John Edwards, Information Commissioner



The ICO recommended that NHS Lanarkshire should take action to ensure their compliance with data protection law, including:

  • Consider implementing a secure clinical image transfer system, as part of NHS Lanarkshire’s exploration regarding the storage of images and videos within a care setting.
  • Before deploying new apps, consider the risks relating to personal data and include the requirement to assess and mitigate these risks in any approval process.
  • Ensure explicit communications, instructions or guidance are issued to employees on their data protection responsibilities when new apps are deployed.
  • Review all organisational policies and procedures relevant to this incident and amend where appropriate.
  • Ensure all staff are aware of their responsibilities to report personal data breaches internally without delay to the relevant team.

The ICO has asked NHS Lanarkshire to provide an update of actions taken within six months of the reprimand being issued.

The ICO has a revised approach to public sector enforcement, aiming to encourage greater data protection compliance from public authorities to prevent harms before they occur.

Notes to Editors
  • The Information Commissioner’s Office (ICO) is the UK’s independent regulator for data protection and information rights law, upholding information rights in the public interest, promoting openness by public bodies and data privacy for individuals.
  • The  ICO has specific responsibilities set out in the Data Protection Act 2018 (DPA2018), the United Kingdom General Data Protection Regulation (UK GDPR), the Freedom of Information Act 2000 (FOIA), Environmental Information Regulations 2004 (EIR), Privacy and Electronic Communications Regulations 2003 (PECR) and a further five acts and regulations.
  • The ICO can take action to address and change the behaviour of organisations and individuals that collect, use and keep personal information. This includes criminal prosecution, non-criminal enforcement and audit.
  • To report a concern to the ICO telephone call our helpline on 0303 123 1113, or go to