What They Don't Publish

DHCW is a publicly funded body. It is subject to the Freedom of Information Act, the NHS Wales governance framework, and accountability to the Senedd. It produces annual accounts, holds board meetings, and has a website.

And yet the volume of information it withholds from public view is extraordinary. What follows is a systematic inventory — a category-by-category mapping of the data that DHCW either does not publish, does not collect, or has actively suppressed. Every item on this list has been identified through analysis of DHCW's published documents, annual accounts, FOI disclosures, Senedd proceedings, and publicly available records.

Financial Data Not Published

Consolidated programme-level spending

DHCW spends in excess of £78 million per year. A significant proportion of this expenditure is allocated to specific programmes: the National Data Resource, the NHS Wales App, WCCIS, LIMS/LINC, the radiology system (RISP), OpenEyes, and others. Yet consolidated programme-level spending figures — the total cost of each programme across all years, including staff time, contractor costs, licences, and infrastructure — are not published.

Costs are fragmented across funding streams. Welsh Government grant funding, DHCW's baseline allocation, and health board contributions are reported in different places, in different formats, using different category definitions. The effect is that no member of the public, no Senedd member, and no journalist can answer the basic question: "How much has been spent on Programme X in total?"

This fragmentation is not accidental. Consolidated programme costs are calculated internally — they must be, for programme management and business case purposes. The decision not to publish them is exactly that: a decision.

Contract values for major procurements

DHCW has entered into contracts worth tens of millions of pounds with commercial suppliers. The contract values for several of the most significant procurements are not publicly disclosed:

These are not minor purchases. They are strategic investments that commit the Welsh NHS to particular suppliers, platforms, and approaches for years. The public has no way of knowing what it paid.

Off-payroll worker identities and individual costs

At least 23 off-payroll workers earn £245 or more per day. Their identities, roles, daily rates, and engagement durations are not disclosed in any public document. The collective cost, estimated at £1.5-4.5 million per year, is distributed across budget lines in a way that prevents it from being identified as a single figure. See The Shadow Workforce for full analysis.

Cost of the Primary Care double migration

General practices in Wales were migrated from the VISION clinical system to EMIS. Subsequently, issues with the EMIS implementation led to a further migration — effectively doing the work twice. The total cost of this double migration, including direct procurement costs, practice disruption, data migration, training, and lost productivity, has not been published as a consolidated figure.

National Data Resource total expenditure

The National Data Resource (NDR) is one of DHCW's flagship programmes. Its total expenditure across all financial years — including development, staffing, infrastructure, and contractor costs — is not published as a single consolidated figure.

Operational Data Not Published

Programme status dashboards

DHCW's major programmes have internal status tracking: RAG (Red/Amber/Green) ratings, milestone schedules, delivery dates, risk registers. These are reported to the board through board papers. They are not published in a format accessible to the public in a timely fashion.

For an organisation under Level 3 government escalation specifically for programme delivery failures, the absence of public programme status data is remarkable. The public cannot see which programmes are on track, which are delayed, what the revised delivery dates are, or what risks have been identified.

Board papers

DHCW board papers are not routinely published in a timely fashion. When they are published, there can be significant delays between the meeting date and public availability. Redactions are applied. The practical effect is that the board's oversight of DHCW's executive team — or lack thereof — is not visible to the public in real time.

HR and Culture Data Not Published

Whistleblowing disclosures

Number received: Not published. No annual figure for the number of whistleblowing disclosures or concerns raised under DHCW's whistleblowing policy is publicly available.

Categories: Not published. There is no public data on the nature of whistleblowing concerns — whether they relate to patient safety, financial impropriety, bullying, procurement, or other matters.

Outcomes: Not published. There is no public data on what happened after a whistleblowing concern was raised — whether it was investigated, upheld, dismissed, or referred externally.

Zero data. Not limited data. Not redacted data. Zero data. An organisation with over 400 staff, operating under significant stress and subject to government intervention, publishes no information whatsoever about whether its whistleblowing processes are functioning.

This absence is itself evidence. A former senior employee raised concerns through internal channels that ultimately reached an employment tribunal. The matters raised touched on procurement practices, management conduct, and organisational culture. The absence of any published whistleblowing data makes it impossible to determine whether this case was an anomaly or part of a wider pattern.

Disciplinary actions

Zero data published. No information on the number of disciplinary proceedings initiated, their categories, their outcomes, or the seniority of individuals involved. In an organisation where allegations of bullying and management misconduct have surfaced in tribunal proceedings, the absence of disciplinary data is not a gap — it is a wall.

Leavers analysis

Staff departures from DHCW are not analysed in any published document. The number of leavers by grade, department, and reason for leaving is not disclosed. In an organisation where cultural problems have been identified — including by the Welsh Public Accounts Committee, which described the culture at DHCW's predecessor NWIS as "the antithesis of open" — the suppression of leavers data prevents any external assessment of whether the culture has changed.

Exit interview themes

Exit interviews, if conducted, are not published in any form — not even in anonymised, thematic summary. The insights of departing staff about the organisation's management, culture, and working conditions are captured (if at all) and locked inside DHCW, invisible to the public or to oversight bodies.

Staff turnover by grade and department

Overall headcount figures are published in the annual accounts. Turnover rates by grade and department are not. This prevents any analysis of whether departures are concentrated in particular teams, at particular levels of seniority, or under particular managers — precisely the kind of pattern analysis that would reveal management problems.

Governance Data Not Published

Identity of the independent digital expert

When Welsh Government imposed Level 3 escalation on DHCW in 2024, part of the intervention framework included the appointment of an independent digital expert to provide external scrutiny and assurance. The identity of this individual has never been publicly disclosed.

This is a person appointed to oversee an organisation spending £78 million per year of public money, at the most serious level of government intervention. The public has no way of assessing whether they are qualified, independent, or free from conflicts of interest.

Options appraisals and technical recommendations

Major procurement decisions are preceded by options appraisals — structured assessments of alternative approaches, suppliers, and technical architectures. These documents, which contain the reasoning behind decisions worth tens of millions of pounds, are not published. The public sees only the outcome: a contract awarded to a particular supplier. The reasoning — why this supplier, why this architecture, what alternatives were considered and rejected — is hidden.

Internal audit reports and findings

DHCW's internal audit function produces reports on financial controls, governance, programme management, and risk. These reports are not routinely published. Their findings, recommendations, and management responses are visible only to the board and to Welsh Government — not to the public.

Identity of the RISP radiology supplier

The radiology system procurement (RISP) is one of DHCW's largest programmes, with an estimated value of £47-56 million based on figures cited in Senedd proceedings. The identity of the primary supplier has not been found in publicly accessible sources. A public body has committed an estimated £47-56 million of public money to a supplier it has not publicly named.

Salary Data Anomalies

Vanishing disclosures

In at least one case identified through comparative analysis of DHCW's annual accounts across multiple years, a director-level individual's salary disclosure disappeared from the published accounts while they continued in post. Salary disclosures in NHS accounts are prepared under statutory requirements and are subject to external audit. They do not vanish through administrative error. See The Ghost Directors for further analysis.

Rebecca Cook — Chief Data Officer

Rebecca Cook holds the title of Chief Data Officer at DHCW. Despite the seniority implied by this title — "Chief" officer roles are typically board-level positions — she does not appear to hold board-level status at DHCW. As a result, her salary is not individually disclosed in the annual accounts. The public has no way of knowing the remuneration of the person responsible for DHCW's data strategy.

The Pattern

Every item listed above could be published tomorrow. The data exists inside DHCW. Programme costs are tracked. Contract values are known. Off-payroll workers have names. Whistleblowing cases have outcomes. Exit interviews capture themes. The independent digital expert has an identity. The radiology supplier has a name.

The decision not to publish this information is a choice — a choice that serves the interests of DHCW's leadership and no one else.

This is not poor record-keeping. It is the architecture of unaccountability.