What They Don't Publish

Digital Health and Care Wales (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 — was not published as a single consolidated figure until FOI/6695830 (28 April 2026, with a supplementary release on 17 May 2026) forced disclosure: £35.7 million through year seven of the original ten-year programme. DHCW's own January 2025 Phase 4 Business Plan, also disclosed only by the supplementary release, restates the 10-year programme cost to £73.6 million and the modelled benefits NPV from £151.5 million to approximately £41 million — a £16 million overspend and a £110 million benefits downgrade DHCW recorded in writing without consultation, notice to Welsh Government scrutiny bodies, or notice to the public. The category and the silent restatement are still not published in any DHCW-controlled public surface — annual report, board minute, IMTP, or website. See National Data Resource: 10 Years Late, £100 Million Short.

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.

Recruitment audit findings

In May 2025, DHCW's Internal Audit reviewed the organisation's recruitment processes and gave a rating of "limited assurance" — indicating significant control weaknesses. The finding was discussed in the private session of the board meeting only. The public minutes record a single sentence; the audit itself has not been published; the nature of the weaknesses has not been disclosed; and the corrective actions are not specified. (DHCW Board Minutes (published), 29 May 2025, item 6.6)

An organisation under Level 3 (Enhanced Monitoring) government intervention, whose leadership appointments have been questioned by multiple independent sources, received its own internal auditors' finding that recruitment processes are inadequately controlled — and classified the finding as private.

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 March 2025, 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.

Active Suppression

The pattern extends beyond non-publication to active suppression through two documented mechanisms:

Blocking the website. DHCW blocks access to carenhs.org — this website — from NHS Wales network devices. The site contains only material sourced from public records: Senedd proceedings, Audit Wales reports, Welsh Government letters, and DHCW's own governance statements. It contains no malware, no harmful content, and no classified information. It contains accountability journalism. By blocking it, DHCW prevents its own staff — the people best placed to verify, challenge, or contribute to the evidence — from reading documented public-record criticism of their employer.

Refusing FOI requests on a technicality. In March 2026, this campaign filed six Freedom of Information requests targeting programme costs, consultancy spending, procurement contracts, cyber security compliance, and total public funding. DHCW refused every request without assessing any on its merits, citing Section 8(1)(b) of the FOI Act — the requests were submitted under a campaign name rather than an individual's name. The response, signed by Marcus Sandberg (Information Governance Assurance Manager), was a single letter covering all five DHCW requests. Welsh Government sent a materially identical refusal for the sixth. The ICO's own guidance states that public authorities should still consider requests where identity is not relevant to the disclosure decision. Requester identity is irrelevant to questions about public expenditure. DHCW chose not to follow that guidance. Read the full analysis.

Block the website. Refuse the FOIs. Publish nothing. This is not a series of unrelated administrative decisions. It is the architecture of unaccountability in operation.

How They Sanitise the Record

The most fundamental form of information control is rewriting what actually happened.

DHCW board meetings are broadcast live on YouTube and recorded. DHCW also publishes minutes. The minutes are, in the organisation's own words, "produced with the support of Co-Pilot" — Microsoft's AI assistant. Someone then edits the AI output before publication.

CareNHS has transcribed DHCW board meeting recordings independently and compared the transcripts against the published minutes. The comparison for the 29 May 2025 board meeting — the first after Level 3 escalation — reveals a systematic pattern:

Candid admissions removed. Claire Osmundsen-Little told the board that DHCW had "run at risk" on WCCIS funding — spending public money on a business case that had not been approved, gambling on retrospective approval. The phrase "run at risk" does not appear in the published minutes. Ifan Evans told the board that the Welsh Government digital policy team overseeing DHCW's escalation was "a little bit under strength" and that DHCW had been "saturating it" with work. This admission — that the watchdog lacks capacity — was omitted entirely.

Emotional responses replaced with positivity. Independent Member Alistair Klaas Neill described the board's reaction to Level 3 as "initial disappointment and frustration." The published minutes replace this with a subheading: "Positive Engagement." The honest reaction to government intervention is erased and replaced with manufactured approval.

Independent member challenges stripped. Board members asked probing, uncomfortable questions. An independent member described 20 years of failure on digital exclusion as an "eternal paradox." Another said NHS affordability was at breaking point — "the knicker elastic won't stretch that far." Another challenged whether a procurement fitted DHCW's forward plan or was ad hoc. In every case, the minutes converted the challenge into a bland assurance: "Members were assured..."

Strategic admissions omitted. The Chair told the board he had described Level 3 escalation to the Cabinet Secretary as "potentially very helpful for us" — revealing that the board was using government intervention as leverage, not treating it as a crisis. The minutes say only that the annual review was "conducted in a friendly and supportive way."

Post-meeting private sessions undisclosed. The recording captures the Chair telling board members to return for a private briefing from Sam Hall after the public meeting closed. The minutes record only: "The meeting closed at 14:03."

The published minutes are not a record of what happened at the board meeting. They are a curated version — edited after the fact, with uncomfortable material removed and positive framing inserted. The YouTube recordings capture what was actually said. The minutes capture what DHCW wanted the public to believe was said.

What They Classify as Private

Non-publication is one mechanism. Another is classification: presenting information to the board but ensuring it never reaches the public record.

Recruitment audit findings. In May 2025, Internal Audit gave "limited assurance" on DHCW's recruitment processes — significant control weaknesses. Discussed in the private session only. The audit was not published. The weaknesses were not specified. (DHCW Board Minutes (published), 29 May 2025, item 6.6)

Staff survey results. The May 2025 board was briefed on staff survey results in a private board development session. The results were not presented at the public meeting. The public has never seen them. (DHCW Board Minutes (published), 29 May 2025, item 4.1)

Corporate risk register. Of the 17-18 risks on DHCW's corporate risk register, two to three are consistently classified as private and discussed only in the closed session of the Digital Governance and Safety Committee. The public cannot see what risks the organisation considers too sensitive to disclose. (DHCW Board Minutes, Feb 2026 and May 2025)

The pattern: when a finding is favourable, it is published and promoted. When it is damaging, it is classified as private. The BCS "Best Place to Work" award appears in annual report headlines. The "limited assurance" rating on recruitment appears as a single sentence on page 19 of a 20-page document.

How They Frame What They Do Publish

The most sophisticated form of information control is not suppression — it is selective presentation. DHCW publishes data. It publishes it in ways designed to mislead.

Sickness absence: headline vs reality. DHCW reports a sickness absence rate of 2.9% and claims it "benchmarks very favourably across NHS Wales." The same annual report, in the back-page tables, shows 15,846 days lost — an 82% increase in three years — with stress and anxiety as the leading cause and 53.25% of staff absent during the year. The 2.9% is the number in the headlines. The 15,846 is the number in the tables. (See Best Place to Work(-Related Stress) for the full analysis.)

The misleading benchmark. NHS Wales sickness absence rates are dominated by clinical workforces — nurses, paramedics, hospital staff — doing physically demanding shift work. DHCW is a desk-based IT organisation. Comparing its absence rate to frontline healthcare is structurally misleading. DHCW knows this. It publishes the comparison anyway.

97% satisfaction from 230 tickets. At the February 2026 board meeting, Chris Darling cited "97% of our service desk satisfaction is positive" from "over 230 service desk tickets a year" as evidence that stakeholder perceptions were improving. 230 feedback responses from an organisation serving the entire NHS in Wales is a negligible sample. It was presented without that context. (DHCW Board Meeting, 2 February 2026)

Engagement score: the decline they buried. DHCW's 2023 internal staff survey reported 80% satisfaction. By 2024, the NHS All Wales Staff Survey showed the engagement score had fallen to 76%. DHCW described this as having "reduced slightly." In the same year, it was shortlisted again for "Best Place to Work in IT." The decline is in the annual report. The shortlisting is in the headlines.

Atos review: actioned but not measured. DHCW paid £207,100 for the Atos stakeholder review. It converted the 27 recommendations into 75 deliverables. By May 2025, 15 were complete — 20%. When asked how the impact would be measured, Ifan Evans told the board the engagement was "not being measured formally." Progress was claimed anyway. (DHCW Board Minutes (published), 29 May 2025, item 5.3)

Programme failures: passive voice, external blame. When LIMS was declared "no longer feasible" for 2025-26 delivery, the minutes recorded it in the passive voice: "delivering and implementing all the disciplines within 2025-26 is no longer considered feasible." No one failed. It was simply "no longer considered feasible." When four programmes were behind schedule, the board was told they were not progressing "due to matters out of DHCW's control." When 100 additional milestones were added mid-year, Evans described it as externally imposed scope: "some of this is out of our control." (DHCW Board Meetings, May 2025 and February 2026)

The data is published. The context is stripped. The favourable numbers lead. The unfavourable numbers are buried in back pages. The failures are attributed to external forces. The responsibility is never accepted.

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.

What You Can Do

This evidence exists because someone looked. You can help make sure it leads to change:

• Write to your MS — ask what they will do about DHCW's failures
• Share this page — the more people who see this evidence, the harder it is to ignore
• Submit what you know — if you have evidence of waste, misconduct, or the suppression of concerns
• Support the FOI campaign — 54 Freedom of Information requests targeting DHCW's hidden data

Related pages:

• What They Said — their own words on the public record
• Toxic Culture — zero whistleblowing data, zero disciplinary data
• Financial Waste — six of nine programmes with no published costs
• Governance Reform — mandatory transparency proposals