The Ghost Directors and the Shadow Workforce

In any public body, accountability begins with visibility. The public has a right to know who leads the organisations that spend their money. Who makes the decisions. Who is responsible when things go wrong. At Digital Health and Care Wales, this basic principle has been systematically undermined — not through dramatic acts of concealment, but through the quiet, persistent erasure of the people in charge from any form of public view.

This article examines two related phenomena. First, the senior directors at DHCW who hold consequential titles and draw significant salaries but who have no discernible public presence — the ghost directors. Second, the off-payroll workforce of at least 23 individuals earning £245 or more per day who fill senior roles, make operational decisions, and spend public money without appearing in any public record — the shadow workforce.

What follows is drawn entirely from public records: DHCW's published annual accounts, Companies House filings, LinkedIn, DHCW's website, Senedd committee records, and conference attendance lists. We have checked every source available to any member of the public who might want to know who is running their digital health organisation. In most cases, we found nothing.

Part One: The Ghost Directors

Michelle Sell — Director of Programmes and Engagement

Michelle Sell has held three director-level titles at DHCW in four years. She was Chief Operating Officer in 2021. By 2022, she had become Director of Planning, Performance, and Chief Commercial Officer — a title she held through 2024. In 2025, she became Director of Programmes and Engagement.

Three director-level titles in four years. Each represents a different organisational function. COO is responsible for operations. Chief Commercial Officer is responsible for procurement and commercial strategy. Director of Programmes is responsible for programme delivery. These are not minor variations in nomenclature. They are fundamentally different roles with different skill requirements and different accountabilities. The frequency of these changes raises a question that DHCW has never addressed: was each role change the result of a formal appointment process, or were titles reassigned to fit the person rather than the function?

Her salary was disclosed in the 2021/22 annual accounts at £90,000 to £95,000, recorded under her then-title of COO. In the 2022/23 accounts, her salary vanished from the disclosure table — despite the fact that she continued in a director-level role throughout that period. These are formal annual accounts, prepared under accounting standards and subject to external audit. Salary disclosures for senior staff do not vanish by accident. They are either included or they are not, and the decision not to include them is a decision.

We attempted to find any public trace of Michelle Sell beyond DHCW's own organisational structure. There is no LinkedIn profile. There is no biography on DHCW's website. She has made no appearances at Senedd committees. She has not spoken at any digital health conference we can identify. She has not been quoted in any media report. She has not authored or co-authored any published material.

This matters because of what her current title means. As Director of Programmes and Engagement, Michelle Sell is directly responsible for programme delivery at DHCW. In March 2025, the Welsh Government escalated DHCW to Level 3 — the highest tier of government intervention — citing "serious concerns about the ability to deliver major programmes." Nine programmes are under that escalation simultaneously. The person whose job title places her at the centre of that failure cannot be found by anyone looking from outside.

Three director-level titles in four years, and the person responsible for programme delivery at an organisation under government intervention for programme delivery failures cannot be found by anyone looking from outside.

Chris Collis — Digital Transformation Lead

Chris Collis holds the title of Digital Transformation Lead at DHCW. His background, so far as can be determined from public records, is in digital television security and standards development. He holds a degree from the University of Birmingham, the subject of which is not disclosed in any source we have identified.

He is not a board member. He has no profile on DHCW's website. He has not appeared before any Senedd committee. He has not spoken at any digital health conference we can identify. He has no publications in healthcare informatics or digital health.

Digital transformation at DHCW encompasses how the entire NHS in Wales transitions from legacy systems to modern platforms. It is the central strategic challenge facing the organisation. It covers architecture decisions that will shape Welsh healthcare for decades — which systems to replace, which platforms to adopt, how to manage the transition from systems built in the 1990s to modern cloud-based infrastructure.

This function is being led by someone whose professional background, as far as any member of the public can determine, is in digital television. There may be a compelling rationale for this appointment. There may be relevant experience or qualifications that are not publicly visible. But that is precisely the point: no member of the public, no Senedd member, no journalist can verify whether the person leading digital transformation at NHS Wales has the credentials to do so, because no information about those credentials has ever been made available.

Sam Lloyd — Executive Director of Operations

Sam Lloyd holds the position of Executive Director of Operations at DHCW. This is a board-level role. His salary is disclosed in the 2023/24 annual accounts at £125,000 to £130,000, with total remuneration including pension contributions of £150,000 to £155,000.

We have been unable to identify any publicly disclosed academic qualifications for Sam Lloyd. This does not mean he has none — it means that for a board-level director of a national public body, earning over £150,000 in total remuneration, no qualifications are visible to anyone conducting due diligence from outside.

His professional background, as far as can be determined from publicly available sources, is entirely in English public health agencies. We have identified no prior experience in the Welsh NHS before his appointment to DHCW.

This distinction matters more than it might appear. The Welsh NHS operates under different legislation than NHS England. It is governed by different commissioning structures. Its digital infrastructure is different. Its governance framework is different. The relationship between health boards and national bodies is different. Operational leadership at DHCW requires an understanding of these Welsh-specific structures — not because English experience is irrelevant, but because the assumption that NHS experience in England transfers directly to Wales has been a recurring source of failure in Welsh public services.

The Level 3 escalation cited "serious concerns about ability to deliver major programmes." Programme delivery is an operational function. It falls within the remit of the Executive Director of Operations. The Welsh public is entitled to understand the background and qualifications of the person whose job it is to ensure that programmes are delivered — particularly when those programmes are under the highest level of government intervention.

The Vanishing Salary

Return to the question of Michelle Sell's salary disclosure. In the 2021/22 annual accounts, her remuneration was reported at £90,000 to £95,000 under her then-title of COO. In the 2022/23 accounts, she does not appear in the senior staff remuneration table, despite holding a director-level role throughout that period.

Annual accounts are prepared in accordance with the NHS Wales Manual for Accounts and are subject to external audit by Audit Wales. The remuneration report has specific requirements for which staff must be disclosed. If a director-level employee's salary is disclosed in one year and not the next — while they remain in a director-level role — there are only a limited number of explanations. Either the accounting treatment changed, or the role was reclassified in a way that removed the disclosure obligation, or the omission was an error that survived external audit.

We do not know which explanation applies. We note only that whichever it is, it has never been explained, and the effect is that a director-level employee's remuneration became invisible to the Welsh public at the same time as her title changed. In an organisation where transparency is already minimal, this disappearance warrants an explanation that has never been provided.

Part Two: The Shadow Workforce

The Numbers

DHCW's annual accounts disclose that the organisation employs at least 23 off-payroll workers at a rate of £245 or more per day. This is the reporting threshold — the minimum rate that triggers a disclosure obligation. It tells us only that these individuals earn at least £245 daily. It does not tell us what they actually earn.

Market rates for senior digital health interims in the United Kingdom — programme directors, technical architects, commercial advisers, transformation leads — range from £500 to £800 per day, and in some cases higher. If we apply a conservative estimate of these market rates to the 23 disclosed off-payroll workers, the collective cost to the Welsh taxpayer is in the range of £1.5 million to £4.5 million per year.

Now compare this to DHCW's declared consultancy expenditure. In its published accounts, DHCW reports total consultancy spending of £757,000. The off-payroll workforce — a category that does not appear in the consultancy line — likely costs between two and six times the declared consultancy figure. The headline consultancy number, the figure that Senedd members and journalists would naturally look to when asking how much DHCW spends on external expertise, understates the true picture by a factor of several multiples.

Stuart Davies — The Sole Identifiable Example

Of the 23 off-payroll workers disclosed in DHCW's accounts, we have been able to identify precisely one by name: Stuart Davies.

His identification was not the result of any DHCW disclosure. It was the result of corporate filings at Companies House. Stuart Davies is engaged through Hafod Interim Limited, a personal service company registered at Companies House. The connection to DHCW was established through company filings, not through any transparency mechanism operated by DHCW itself.

Stuart Davies does not appear on DHCW's board. He has no confirmed job title in any public document. He has not appeared before any Senedd committee. He has no profile on DHCW's website. The only reason we know he exists is that Companies House records made the connection visible.

One name, out of 23. Identified not through transparency, but through forensic examination of corporate registrations. The other 22 remain entirely invisible.

The Accountability Gap

The structural problem with off-payroll workers at DHCW is not their existence — many organisations use interim and contract staff. The problem is that they fall into an accountability void.

They are not employees. They are not subject to DHCW's performance management framework, its codes of conduct, or its disciplinary procedures. If an off-payroll worker makes a poor decision, there is no formal mechanism for holding them to account through the organisation's own governance structures.

They are not board members. They are not subject to the governance disclosures required of directors — no register of interests, no remuneration disclosure, no public biography, no appearance at board meetings.

They are not formal contractors engaged through published procurement processes. Their engagement does not appear in contract registers. Their terms of engagement are not published. The procurement process by which they were selected — if there was one — is not visible.

Yet these individuals fill roles of genuine consequence. Programme directors who oversee multi-million-pound initiatives. Technical architects who make decisions about systems that will serve the Welsh NHS for decades. Commercial advisers who influence procurement decisions worth tens of millions. They make decisions. They influence strategy. They spend public money.

And no one outside DHCW knows who they are, what they are paid, what they do, or how they were selected.

Wales vs. England

This level of opacity is not inevitable. It is a choice.

In England, NHS trusts are required to publish off-payroll engagement data that goes significantly beyond what DHCW provides. The Cabinet Office's transparency requirements for arm's-length bodies include specific provisions for identifying and reporting on off-payroll engagements, including the results of IR35 assessments and the duration of engagements.

Wales has no equivalent practice. DHCW discloses the number of off-payroll workers above the £245 threshold. It does not disclose their names, their roles, their actual rates, their duration of engagement, their IR35 status, or the procurement process by which they were selected. The disclosure that exists is the minimum required to satisfy accounting standards. It is not designed to enable public scrutiny, and it does not.

The Welsh Government could require DHCW to match English transparency standards for off-payroll workers. It has not done so. The Senedd could request this information through committee inquiry. It has not done so. DHCW could voluntarily publish it, as a matter of good governance. It has not done so.

The Full Picture

Consider what the Welsh public is being asked to accept.

An organisation under the highest tier of government intervention for programme delivery failures. The director responsible for programme delivery has held three titles in four years and cannot be found by anyone outside the organisation. The person leading digital transformation has a background in digital television and no visible healthcare credentials. The executive director of operations has no disclosed qualifications and no prior Welsh NHS experience. A director-level salary disappeared from published accounts without explanation.

Alongside these ghost directors, a shadow workforce of at least 23 off-payroll individuals — earning collectively between £1.5 million and £4.5 million per year — fills senior roles, makes decisions, spends public money, and answers to no one outside the building. Only one can be identified by name, and that identification required searching Companies House, not reading any DHCW disclosure.

Twenty-three people, earning at least £245 a day each, collectively costing millions of pounds per year. Not one named. Not one called to account. Not one visible to the public whose health service they are supposed to be building.

This is not an organisation that has accidentally fallen short of transparency standards. This is an organisation that has constructed a leadership structure in which the people making the most consequential decisions are the people least visible to the public. That structure did not arise by chance. It was built, maintained, and defended — and it serves the interests of those inside it at the expense of everyone else.

All figures in this article are sourced from DHCW's published annual accounts (2021/22, 2022/23, 2023/24), Companies House filings, LinkedIn, DHCW's official website, Senedd committee records, and publicly available conference and publication databases. Where information could not be found, we state that explicitly. Absence of evidence is not evidence of absence — but when a national public body makes it impossible to verify the credentials of its own leaders, the absence itself is the evidence.