Mrs Joanna Fox MSc
NAPC Council & Faculty Member
Digital Health & Human Factors Lead
Digital technology is reshaping healthcare at a remarkable pace – from virtual triage and remote monitoring to the growing influence of AI in clinical decision‑making. But as the tools become more advanced, so do the questions about safety, risk, and responsibility. In this episode, NAPC Clinical Chair, Prof Andy Brooks, sits down with digital transformation expert and NAPC faculty member Jo Fox to explore the realities behind digital clinical safety.
Together, they unpack the findings of Jo’s recent research across the primary care landscape, discuss why frameworks like DCB0129 and DCB0160 matter more than ever, and consider what health professionals need to prepare for as technology becomes more embedded, and more complex, within neighbourhood care. This insightful conversation sheds light on the human factors, governance gaps, and opportunities that will shape the future of safe, digital‑enabled healthcare.
Helpful Links
As part of this discussion Jo Fox mentioned the national frameworks that are in place around digital tools. A list of those mentioned in the podcast are below;
| Item | Clear Definition | Official Link |
| DCB0129 | National clinical safety standard for manufacturers/suppliers of health IT systems. Requires hazard identification, risk assessment, safety documentation and a Clinical Safety Officer (CSO). | DCB0129: Clinical Risk Management: its Application in the Manufacture of Health IT Systems – NHS England Digital |
| DCB0160 | National clinical safety standard for NHS organisations deploying/using health IT systems. Ensures the system is implemented, configured and used safely. | DCB0160: Clinical Risk Management: its Application in the Deployment and Use of Health IT Systems – NHS England Digital |
| Digital Clinical Safety (General Guidance) | High-level NHS guidance covering how DCB0129 and DCB0160 should be applied through the lifecycle of digital systems. | NHS England » Digital clinical safety assurance |
| Clinical Safety Templates (hazard log, risk plan, safety case) | Official NHS templates for complying with DCB0129/0160 including hazard logs, clinical risk management plans and safety case templates. | Clinical Safety documentation – NHS England Digital |
| DDaT (Digital, Data and Technology) | UK Government capability framework describing skills, roles and professional standards for digital and technology teams (including NHS). | Government Digital and Data Profession Capability Framework – Government Digital and Data Profession Capability Framework |
| DPIA (Data Protection Impact Assessment) | Mandatory assessment under GDPR/Data Protection Act to evaluate and mitigate privacy risks when processing personal or special-category data. | NHS DPIA Template: Template_DPIA_Full_word_version_12.09.23.docx |
| NICE Evidence Standards for Digital Health Technologies | National guidance for evaluating clinical effectiveness, economic impact and quality of digital health tools. Required for NHS adoption. | Evidence standards framework (ESF) for digital health technologies | NICE |
| NHS Service Standard (Clinical Safety Point 16) | NHS digital service design standard requiring teams to identify clinical risks, nominate CSOs and meet DCB standards. | 16. Make your service clinically safe – NHS digital service manual |
Transcript
Introduction
Andy Brooks
Welcome to the NAPC podcast. I’m Andy Brooks and I’m really pleased to be joined today by Jo Fox, one of the NAPC faculty members and our digital transformation expert. Hi, Jo. Hi, Andy. Thanks for joining us. I was really interested in an article that you have written recently. And if it’s okay, I’d just like to read the first couple of sentences from that article.
You write, healthcare systems across the UK are riding a wave of digital innovation, from virtual triage and remote monitoring to AI driven documentation and decision support. The promise is clear. improved access, reduced administrative burden, and more proactive data-driven care. Yet, digital transformation carries A paradox. Digital and AI tools enable quality care, but do not guarantee safety. I read those First, I thought, this is a really interesting topic. You’ve clearly done some research in it. Just tell us a little bit about the research that you’ve been doing, Jo.
Jo’s Background and Research Focus
Jo Fox
Thank you, Andy. So, I’ve really, for the last few years, been sort of homing in on all of the facets of patient safety and specifically from a human factors perspective. So really looking across not just the primary care landscape, but actually all of the health ecosystem.
And we’re in modern times, all of our colleagues, whether you’re technical, you’re clinical, you turn up to do it, you know, to do a good job. You want to deliver like the best patient care. And one of the enablers for that, you interact with in everyday life, and in fact, multiple types of enablers are the tools and the technology, and I suppose the sort of the digital evolutionary that we’re on at the moment.
As part of the research, I suppose, became transparent. How much around technology do we really understand? How much are we looking at? How easy is it to badge a fault or an error that’s arisen? What exists by way of national standards and frameworks and guidance? What actually exists How familiar is it? And if it’s technical and clinical colleagues across the system are familiar with these standards, how well applied are they and what impact are they actually having at the other end?
I wanted to sort of say, okay, let’s take the microscope in a slightly differing direction. in that the same national standards apply, but how well known and utilised are they, which is why I wanted to focus on the use of it across the primary care landscape.
Digital Technology and Human Interaction
Andy Brooks
Thanks. Jo, you’re right, aren’t they? The core of care is about personal interaction, and yet the digital technology we’re using more and more and more. Take, for example, the way we’re doing this podcast. We’re not in the same room, we’re using technology, and yet this is a very human to human interaction, and that same potential exists, as you said, for care.
It’s mentioned a lot in the 10-year plan, isn’t it, this kind of to digital, so we’re starting to embrace it. And you mentioned a few things there about how well known is it, the sort of safety element of it and some of the standards. Tell me a little bit more about what did you find? How well known is it?
Understanding Frameworks and Standards (e.g., DCB0160)
Jo Fox
Is a regulatory requirement to, for example, when you’re deploying digital health technologies, when you’re deploying them into a healthcare system, you know, it sits under the Health and Social Care Act that one should follow certain frameworks. for example, the DCB0129 and the DCB0160. So, my specific question was around the DCB0160, because that focuses more on providers of care and not the suppliers of a product.
Diving into that, I suppose, looking at that COG specifically, 41% of our respondents across the primary care landscape, so the primary care networks that we worked with, 41% of them had the assigned specific role that is mandated that they should have. So, you know, not considerably high numbers, have assigned a role, so a level of responsibility, somebody who’s going to dive into what the framework is about, translate that into layman’s terms, what does that look and feel like, you know, in our real world, in our setting, and you know, what colleagues do we need to bring to the table?
As well as that, interestingly enough, there’s a plethora of training resources out there and available. But again, 58% of those that we worked with on this piece of research confirmed that they felt they had any formal training in digital clinical safety. So again, begs the question, are we aligning the right roles? Are we upskilling the people to use and understand all of the functionality of a tool and technology in order to enable it to be as safe as possible. And interestingly, relatively low numbers, like a third of those that participated in the research highlighted the level of sort of confidence that they had in managing digital clinical risk.
It feels at the moment almost like we haven’t quite got the human systems in place or running simultaneously to the technology itself. There are gaps in capability, there’s gaps in, you know, the governance. Is it a bit patchy around culture? Quite possibly. And anybody can be a leader with digital.
It doesn’t have to be assigned to one person specifically on top of or aside from their day job. Thought leadership piece that you quoted just then. I wrote that because I believe that there’s strength that we can take from looking at the wider, that wider human system around not sort of compromising, patient care and around better management of the risks in the way in which we deploy technology. But also, it’s prevalent at the moment, as you’ve cited, the direction of travel with, you know, with the forwards plan, it’s, we want to increase capacity, we want to drive efficiency. We can’t do that unless we start asking these types of questions.
Andy Brooks
Thanks, Jo. There’s just one very specific thing that you mentioned there, just to check up on. You mentioned about the DCB 0160, which I guess is something very technical. What does the DCB bit stand for? And if people are thinking about these guidelines, where could they go to find out about what they need to be putting in place?
Jo Fox
Yeah, great question. And actually, I think what we could do and should do as part of the podcast is share some direct links to the, it was historically the NHS digital page, but all of the links do exist actually to the regulatory framework itself, if you like, supporting documentation. So, the resources are there, but I sense you’re right, that a bit like, I suppose, sort of no pun intended, but a bit like digital front door.
We need to actually open the digital front door to some of these resources that our colleagues need access to. And again, saving them the time having to actually go and search and Google what is the DCB0160. They’ve been updated and they’re currently both the frameworks actually are going through consultation at the moment, Andy. And it’s been about 10 years since they were first introduced in their infancy when we did start to evolve, if you like, layering technology in the health ecosystem.
Alongside that, there’s tools and resources around DPIAs. There’s NICE guidelines around digital, the use of digital technology now. It can almost feel like there’s overwhelm with, you know, where do I go? Which one do I follow? Which order do I actually work through these tools and resources in? And actually, as part of the research, that was one of the recommendations that we made is actually They could be a lot more succinct and sort of removal, if you like, of duplication of work in some of these processes. So, they feel less like a tick box and more like, oh, it’s meaningful. It’s actually making an impact in what we’re doing and how we’re doing it.
Andy Brooks
Thanks, Jo. So good suggestion. We can make sure that on our website there’s some signposting for where people can find these resources. You mentioned something else there, the DPIA. What does DPIA stand for?
Jo Fox
It’s the basically it’s an impact assessment. When you deploy a technology, the framework such as the DPIA, so essentially, it’s the management of the data flow. So, you know, data protection impact assessment. And it’s about understanding, you know, are there any risks? So, looking at the back end, looking at the front end, looking at the interdependencies. Are we reliant on, the human computer interaction? Are we reliant on interoperability between two systems? In some respects, the risk management of that is to be deployed through the whole digital life cycle.
So not just utilising it and going through a process that almost like formalities, okay, going to implement something, let’s utilise this resource. It’s about actually retaining that resource and having it as a living, breathing document, as it were, through the whole, post-adoption and continually going back and assessing, what is the data telling us? Where is it moving? Where are the single points of failure? And really analysing all facets.
Simplifying Digital Design and Workflow
Andy Brooks
I was wondering, Jo, if you came across people as part of your research, people in primary care that may say, oh, this is great, this technology stuff, but I’ve got to fill out this, I need this role, I’ve got to… comply with this guidance.
Come on, welcome to the real world, where we’ve got all these pressures that come from other guidance from elsewhere. How really do we have the time to do this? And what are the benefits of doing this? Surely, I just need to open the box, turn it on and press go, because that’s what I do with my phone or my TV. Why is this a different world?
Jo Fox
Yeah, it’s. Unfortunately, I mean, we, as we know, we are in the 4th most complex system in the world, right? So, and if we think about the application of human factors here, I mean, I sort of chuckle at Andy. I mean, all of us will resonate with this every time we go to take a plane on a holiday. I look at a plane, I look at how well they’ve labelled instructions across an entire aeroplane, right? Because, you know, they can’t afford to get things wrong X number of 1000 feet up in the sky.
And You’re right, we design things quite poorly generally because we procure products, we pick them off the shelf. It’s not about collaborative actually design. It’s got to be in its rawest form co-design. So, within the system, we’ve got to challenge suppliers to get it as basic and simple as you say, where you don’t need to read a 40-page document or, a standard operating procedure. And you don’t need a table to translate what the terminology even means that sits within these documents.
There is something around simplifying the design process of the technology. We don’t want people thinking, oh, it’s another box to tick. And invariably, they’ll feel like that when it doesn’t fit their way of working. And so, there is something around. Looking at the roles, looking at each role needs a different hook as to where they come in.
Where is there into play in an entire process, an end-to-end process of purchasing and choosing a technology, purchasing the right technology, linking with the supplier, challenging them, getting the iterations made. What does the testing phase look like? How long will we do that? What does the iterative review look and feel like? Are we testing it off-site or are we actually bringing this stuff into our working environment really analyse and assess. We’ve got to be able to allow professionals to leverage their expertise better when we’re deploying technology so that it doesn’t feel like, oh, there’s another tick box, there’s another sort of formality that I go through without anybody seeking my version of it or my view of it.
Preparing for Future Technology and Neighbourhood Care
Andy Brooks
Jo, I was wondering for our members that are listening to this, did you have any thoughts of things they need to be getting ready for in terms of technology that’s coming down the line that you’re aware of or changes or as we move into sort of neighbourhood care, if you have things that you could say, listen, you need to get ready for this, what would those things be?
Jo Fox
When we think about neighbourhood working. We’re now changing the landscape. And if we think about this just from an environment point of view, so we are now delivering care from all sorts of places and spaces. and actually, being almost guided in a differing fashion to what historically we’re used to. You’re poorly, historically, you go to the GP, you wait your turn, you go in the room, you’re treated, you go again, and you know, hopefully there’s improvements in your care. And actually, that in itself, you know, organically is changing at the moment in terms of we’ve now got a much wider breadth of professionals, healthcare professionals with differing skill sets that aren’t even themselves entering into that environment.
So, we need to make sure that the technology is quite possibly fit for a multitude of workspaces and workplaces would be the first thing that I say. Interestingly enough, the clinical safety side of it, the digital clinical safety has to be weaved into every role. you could be a community health and wellbeing worker; you could be a social prescriber. Every role has to feel like they are part of it and that it’s not a side or it’s not something that this part of the neighbourhood does, and I don’t need to focus on that.
Everybody needs to be almost brought into the circle and a level of, I suppose, familiarity whereby they feel psychologically safe enough to challenge whether it’s the technology they’re using, whether it’s the way the technology has been deployed, whether it’s the training that they’ve received, we could unpack this all day. And there are different layers, I feel, when you start to look at aligning the workload, aligning the technology with the roles, alongside the safety and the quality improvement piece that should come with it.
Challenges with Technology Change
Andy Brooks
I was wondering, this is maybe my kind of bias, but I would sometimes think it’s much harder to change a technological process because it’s a distant company versus a human HR process within a practice that’s probably much easier to change. And so, do you think people just actually put up with things because they feel it’s really hard to change?
Jo Fox
Yeah, and ordinarily. I suppose whether it’s design flaws from a technology provider or the governance that’s in place alongside the technology, Either, either. It’s not translating into practice. That’s the bottom line. And so, you know, yes, the organisations, regardless of scale, whether it’s, you know, GP surgery scale, whether we’re out there in our, you know, in the neighbourhoods utilising technology for wider interactive, you know, and meaningful interactions with our population, it can’t be solely reliant on, well, the product says do this or the policy says, this is the standard approach that we should be adopting.
There’s something around asking the questions on, something was designed 12 months ago. The system’s evolved since then. So, the work, as imagined back then, how do we ensure there’s a feedback loop? It’s really important that there isn’t an us and them between, your example, between a practice and a supplier. The supplier should want that feedback loop because I can guarantee you if one surgery has unearthed it, then the likelihood is the other 6,000, 7,000 across the country are probably experiencing the same thing and creating and duplicating those same workarounds.
And my challenge back is that we’ve got to be disruptive in the right way. We don’t want to challenge a supplier and strain relationships, but at the same time, we need to be able to say, is this fit for the purpose? Does it function and give us form in what we need it to do today, tomorrow and the next day and not continue to work on, it was great a year ago. But actually, now it slows us down. Now we don’t even use it and we’re still funding it. We’re not using it and we use X, Y and Z and that actually feels more comfortable. Might take us longer. It might not drive the efficiencies.
There’s something around how technology is deployed. And where we see suppliers getting that right, we see less U-turns from the end user about going back to the good old ways that they used to work. They go back to the good old ways because they quite quickly recognise that sometimes the new tech, it hasn’t quite understood, you know, in its entirety how they work. So, usability issues need to be, you know, you have to check in on it. We have to challenge it.
And also, we have to know that it’s not always a software failing. You mentioned it yourself. Humans can fail, but we also need to recognise that, okay, so why are they failing? Do we need to give more prompts in the technology and more nudges to help, you know, to bump the thought process and all? Do we need to, has the training failed them? We’ve got such a diverse workforce nowadays that actually are we just going right, kick the button, bit of online training, you’re whiz through that in, you know, 5 to 10 minutes and it isn’t serving, you know, fully serving the need of how we want them to utilise the technology to its best form.
Top Safety Risks in Digital Primary Care
Andy Brooks
Thanks. I was wondering from your experience and your research, what may be the top three or so biggest safety risks with technology in primary care? Things that you think our members should have in the back of their mind if they’re considering matters about risk.
Jo Fox
Yeah, I’d say the top safety risks is to really ask yourself the question, do we have a risk management process in place, I suppose. And there are processes that exist. we’ve shared them. I believe we shared them in the thought process around looking at techniques that don’t recreate the will. We’ve got hazard.
So, an example of hazard identification process. We’ve got the some may be familiar with this, but the functional failure analysis is a process that one can go through. We’ve got another approach, which is like the structured what if technique. So again, how much foresight can we have, knowing what we know about the way we work, knowing what we know about the environment and the complexity of the need of the individuals that we’re interacting with. Can we actually better utilise
First thing, the risk management tools that might exist. And again, we can certainly add links for those resources. We want, as part of this, we want to engage with our colleagues in the system, but where possible, if we can educate them and signpost them, we’ll add the links, Andy, that go out with this podcast. The other tip that I would have is that Walking the walk mustn’t be underestimated.
So, when we’re deploying technology, walking the pathway that we’ve actually mapped out and designed, and I always say that there’s patient flow, there’s data flow, there’s workflow. And, you know, if we’ve got all of those and we’ve drawn them out, we’ve got beautiful one pages, let’s actually physically walk through that. What does that look like? What do I think about it? How does it make me feel? And what do I believe might be the, whether it’s the sort of the positives or the challenges that I’m likely to encounter.
So, clinicians know this as part of training, the best form of training that you can get is secondary to the real-world stuff is simulation. And with the technology deployment, better managing and mitigating risk, we need to simulate more. We need to have scenarios and actually practice and explore and tease out all of those potential challenges. challenges before we go out there into the real world and deploy the technology on the, with the wider workforce, but also with potentially some of the patients we know utilise and interact with some of this technology as well.
If we’re deploying technology that our population are using, we should not be doing so without that patient voice at the table. That’s something that I haven’t seen enough of that I definitely would recommend more is that if you’ve got patients in any way, shape or form that are interacting with the technology as part of that co-design. Don’t just think multidisciplinary teams and healthcare professionals, think patient voice.
The direction of travel with AI, as you know, AI-based tools, we know that they’re fast becoming routine part of care, whether it’s, use for triage, use for clinical decision making, use for sort of supporting documentation flow. And I guess it’s also important to note at this point that the technology is only going to get more complex in itself. And so, you know, I believe that the level and depth of risk that we’ve spoken about thus far needs to extend and be somewhat amplified, actually, as we start to enter into the realms of, utilising AI and large language models as part of our delivery of care and supporting patients, to be more proactive in their health care management.
So perhaps considerations around, an over-reliance on the use of AI. Does that challenge our level of resilience? Where’s that line of upskilling and de-skilling sit? So, you know, they would be sort of future questions and challenges that I would say, you know, to consider.
Learning from Digital Incidents
Andy Brooks
Jo, in terms of clinical incidents, there are some well-set out, tried and tested methods about learning from clinical incidents. How do you think primary care does or needs to learn from digital incidents?
Jo Fox
Yeah, great question. I mean, at present, digital issues, digital challenges, if you like, they often sit in a separate bucket, separate reporting channels. So, you know, historically, one would assume digital, oh, IT, okay, put a request into an IT service desk. And immediately, we’re thinking about the digital being, you know, the tool or the technology being the root cause of the issue.
And actually, there’s something around linking it directly back to clinical risk management and therefore linking it back to how do we report, how do we currently escalate within our system? So, do we have a set taxonomy for it? Are we classifying it in terms of it’s digital? Okay, so but what is it digital? Is it the technology failing? Is it a human interaction with the technology? Is it, a step before you’re deploying the technology? Is it really being able to sort of consistently across all of primary care, consistently be able to sort of classify, if you like, what specifically do we mean when we say digital and how many layers beneath that are they?
And the other thing is around sharing that learning. Interestingly enough, from the research, there was a strong culture around learning from the digital clinical safety instance that had occurred within sort of a local tertiary but not necessarily sharing outwardly beyond that. And I think there’s something to be had around a national look at the picture and are there any trends? Is there any other support? But one final point on this, not sort of traditionally reporting for reporting’s sake, reporting because we want to actually learn from it in order to move forwards with the next piece that we deploy.
Closing Reflections
Andy Brooks
Thanks, Jo. When we surveyed our members, The survey showed that digital confidence was a bigger barrier to digital access. So, the fact that we’ve been able to listen to your experience and your enthusiasm and knowledge of this topic has been fantastic and that goes a long way to answering our members’ concerns. You’ve certainly raised our awareness. given us some important concepts to look at. We will be putting those on the website.
Certainly, increased my confidence in terms of this important area. As you said, you’ve reminded us about how care delivery is all about the patient. We need to be embracing digital technology, but it’s all about delivering great care in the end and how digital fits as a really important component of all that we do. And again, I was really struck by your comments around AI that it’s going to be increasing and use more and itself is going to be becoming more complex. And therefore, all the more important that we address the important features you described, both in terms of the statutory guidance, the governance, how we incorporate it, how we recognise the messy way that care delivery happens, but that doesn’t mean that we can’t put this really important subject to one side.
So, a big thank you, Jo, for not only the time you spent here, but all the work you’ve been doing to bring this knowledge and expertise to us. And thanks everyone for listening to our podcast and please watch out for our next episode.

