Private Healthcare CSRB Compliance Guide
Complete guide to Cyber Security and Resilience Bill compliance for private healthcare providers. Understand essential service obligations under Bill 329.
Sector Overview
Private healthcare providers play an increasingly vital role in the UK's overall healthcare delivery - supporting elective care, diagnostics, and specialist treatments. Many integrate with NHS systems, access sensitive patient data, or deliver services essential to public health. Under the Cyber Security and Resilience Bill (Bill 329), private healthcare providers may be regulated in multiple ways depending on their activities.
Why Private Healthcare Providers Are In Scope
Healthcare services are listed as essential services in Schedule 2 of the NIS Regulations. Private healthcare providers that meet threshold requirements are directly in scope as Operators of Essential Services (OES). Additionally, private healthcare providers may be in scope in other ways:
You may fall in scope if your organisation:
- Is an operator of essential services (OES) in the health subsector under Schedule 2 (meeting threshold requirements)
- Delivers care that integrates with or complements NHS services and relies on network and information systems
- Accesses or shares patient health records and clinical data through digital systems
- Manages critical medical IT systems or digital health platforms that support patient care
- Provides cloud computing services for healthcare (regulated as RDSP under Part 2, Section 7)
- Provides managed IT services for healthcare organisations (regulated as RMSP under Part 2, Section 9)
- Is designated as critical supplier under Section 12, Regulation 14H if supplying to NHS or essential healthcare services
- Carries on essential activities or provides activity-critical supplies (subject to Part 3 regulations)
- May be subject to directions for national security purposes (Part 4)
As Operators of Essential Services (OES)
Private healthcare providers providing essential services in the health sector are listed as operators of essential services (OES) in Schedule 2, subject to threshold requirements.
As an OES in the health sector, you must:
- Comply with security duties under Regulation 10
- Report incidents within 24 hours (initial) and 72 hours (full) under Regulation 11
- Send a copy of incident notifications to CSIRT
- Comply with information requests and inspections under Regulations 15 and 16
- Have regard to guidance from your designated competent authority
As Relevant Digital Service Providers (RDSP)
Under Part 2, Section 7 of Bill 329, private healthcare providers offering cloud computing services for healthcare may be regulated as Relevant Digital Service Providers (RDSPs):
- Register with the Information Commission within 3 months (Regulation 14)
- Comply with security duties under Regulation 12
- Report incidents within 24 hours (initial) and 72 hours (full) under Regulation 12A
- Notify affected customers as soon as reasonably practicable under Regulation 12C
- Comply with information requests and inspections
As Relevant Managed Service Providers (RMSP)
Under Part 2, Section 9 of Bill 329, private healthcare providers offering managed IT services for healthcare organisations may be regulated as Relevant Managed Service Providers (RMSPs):
- Register with the Information Commission within 3 months (Regulation 14C)
- Comply with security duties under Regulation 14B
- Report incidents within 24 hours (initial) and 72 hours (full) under Regulation 14E
- Notify affected customers as soon as reasonably practicable under Regulation 14G
- Comply with information requests and inspections
As Critical Suppliers
Under Part 2, Section 12 of Bill 329, Regulation 14H, private healthcare providers may be designated as critical suppliers if they supply goods or services directly to NHS organisations or other OES, and their failure could disrupt essential services:
- You supply goods or services directly to an OES (e.g., NHS Trust)
- You rely on network and information systems for the purposes of that supply
- An incident affecting your systems has the potential to cause disruption to essential services
- Any such disruption is likely to have a significant impact on the economy or day-to-day functioning of society
- You must comply with information requests, inspections, and enforcement notices
- You may be subject to financial penalties for non-compliance
— Bill 329, Part 2, Section 12, Regulation 14H
Patient Safety & Continuity
For private healthcare providers, cyber resilience is patient safety. CSRB compliance strengthens the digital backbone of UK healthcare:
- Improves clinical and operational continuity
- Protects sensitive health data from compromise
- Builds public confidence in digital health systems
- Supports integration with NHS systems
- Reduces cyber risk and incident costs
- Strengthens supply chain security
Penalties for Non-Compliance
Private healthcare providers face penalties depending on how they're regulated:
Part 2 Penalties (OES/RDSP/RMSP):
Higher Maximum: £17,000,000 or 4% of turnover for serious failures
Standard Maximum: £10,000,000 or 2% of turnover for administrative failures
Part 3 Penalties (Essential Activities):
Maximum: £17,000,000 or 10% of turnover
— Bill 329, Part 2, Section 21; Part 3, Section 32
Benefits of CSRB Compliance
Patient Safety
- Improves clinical and operational continuity
- Protects sensitive health data from compromise
- Builds public confidence in digital health systems
Business Benefits
- Supports integration with NHS systems
- Reduces cyber risk and incident costs
- Strengthens supply chain security
Direct References from Bill 329
Schedule 2 - Health Subsector
Healthcare services are listed as essential services in Schedule 2, meaning private healthcare providers that meet threshold requirements are operators of essential services (OES).
Bill 329, Schedule 2
Part 2, Section 12 - Critical Suppliers
Regulation 14H allows designated competent authorities to designate suppliers to NHS organisations or other OES as critical suppliers if their failure could disrupt essential services and have significant impact.
Bill 329, Part 2, Section 12, Regulation 14H
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