The ongoing NHS project for the development of a UK-wide electronic health records service, also known as the ‘Spine’, raises many controversial issues and technical challenges concerning the security and confidentiality of patient-identifiable clinical data. As the system will need to be constantly adapted to comply with evolving legal requirements and guidelines, the Spine’s authorisation policy should not be hard-coded into the system but rather be specified in a high-level, general-purpose, machine-enforceable policy language.

We describe a complete authorisation policy for the Spine and related services, written for the trust management system Cassandra, and comprising 375 formal rules. The policy is based on the NHS’s Output-based Specification (OBS) document and deals with all requirements concerning access control of patient-identifiable data, including legitimate relationships, patients restricting access, authenticated express consent, third-party consent, and workgroup management.

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