NHS Communications AI Operating Framework v2 – The NHS Alliance

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Updated (2026) principles, expectations and safeguards to ensure AI is used in ways that are ethical, inclusive, transparent and anchored in trust.
Communications
This operating framework supports NHS communications and engagement professionals to explore and adopt artificial intelligence (AI) in a way that is ethical and effective, and promotes trust, inclusion and transparency.
It offers clear, practical guidance to empower the responsible use of AI tools and technologies, enabling NHS communications and engagement teams to build capability, develop confidence and collaborate effectively with IT, digital, information governance and clinical colleagues. This framework is designed to help professionals advocate for safe access to AI platforms and tools that can enhance patient engagement, improve efficiency and drive more personalised communication.
This is not a policy document, nor a replacement for local protocols. Instead, it offers a shared foundation that NHS communicators can adapt and apply based on local needs, in partnership with other key stakeholders within their organisation. It will be updated regularly (at least every 12 months) to reflect changes in technology, regulation and best practice.
This framework is designed to help professionals advocate for safe access to AI platforms and tools that can enhance patient engagement, improve efficiency and drive more personalised communication.
This framework forms part of the NHS Communications AI Taskforce’s national priorities, supported by the NHS Alliance.
The NHS is committed to remaining at the forefront of responsible artificial intelligence (AI) adoption to ensure its ethical, effective and trusted implementation.
This operating framework provides clear guidelines for the use of AI systems within NHS communications. Its purpose is to ensure the protection of personal data, uphold ethical standards, manage potential risks and enable the effective and responsible use of AI tools to enhance communication efforts.  
This document guides the effective deployment, management and governance of AI systems to support improved communications within the NHS. This is not an official policy document, but it will provide useful guidance to NHS communications professionals. It should be used in conjunction with local organisational policies and procedures on AI.
It is important to note that this framework is not exhaustive and will require periodic updates (at least every 12 months) to reflect technological advancements, evolving regulatory frameworks, and emerging best practices in AI governance. This is the second version of the framework; the first was published in October 2025. 
The rapidly evolving landscape of healthcare presents significant opportunities for AI technologies to transform patient care, streamline administrative functions, improve overall operational efficiency and enhance the way the NHS communicates with staff and patients. The NHS recognises the potential of AI and is committed to its ethical, transparent, and responsible use.
The purpose of this framework is to establish clear guidelines for the development, implementation and monitoring of AI systems to protect personal data, uphold ethical standards and mitigate potential risks. It is essential that AI is used in a manner that complies with legal and regulatory requirements, respects patients’ rights and maintains the trust and confidence of our patients, staff and stakeholders.
This framework outlines the key principles and procedures that should be followed when deploying or using AI technologies.
NHS organisations and their communications teams are encouraged to actively adopt the principles outlined within this framework. They should work collaboratively with their local digital and information governance teams, as well as other relevant departments, to ensure that the implementation of AI within communications meets the specific needs of their staff, patients, and the wider population they serve. This collaborative approach will help tailor the framework’s guidance to local contexts and existing policies.
This framework outlines the key principles and procedures that should be followed when deploying or using AI technologies. By implementing these guidelines, the NHS aims to foster a culture of responsible AI use that maximises its benefits while minimising potential risks, especially in communications.
Ethical use of AI grounds the thinking throughout this document. With that in mind, this latest version of the operating framework includes a dedicated section on the ethical use of AI in NHS communications, with links to practical tools that teams may find helpful.
A glossary of AI-related terms and how they apply to communications, is available in section 14 of this framework.
In September 2026, the National Commission into the Regulation of AI in Healthcare, commissioned by the MHRA, concluded that public support for AI in healthcare is strong but conditional on organisations demonstrating transparency, accountability, human oversight and clear governance arrangements. The commission emphasised that trust in AI cannot be assumed and must be actively earned through safe, responsible and transparent use.
For NHS communications teams, this reinforces the importance of maintaining clear human accountability for all AI-assisted outputs, ensuring appropriate transparency when AI is used, investing in AI literacy and capability, monitoring the impact of AI-enabled activities, and considering inclusion, accessibility and public confidence in all deployments. These principles align closely with those set out in this operating framework.
As national policy, regulation and assurance arrangements continue to develop, future editions of this operating framework are expected to provide more detailed guidance on transparency, accountability, workforce capability, incident reporting, public engagement and governance requirements, reflecting emerging guidance from the MHRA, NHS organisations and wider regulators
The following principles provide practical guidance for applying the five overarching principles set out above.
While collaboration across various roles is essential for responsible AI use, there are some duties, accountabilities and responsibilities that are specifically for communications.
Director of communications (responsible director): Oversees the strategic direction and responsible implementation of AI within the communications function.
Communications and engagement teams:
All communications employees and authorised users:
The procurement or installation of any software should not take place without explicit permission from your IT department. 
You should be aware:
When procuring and implementing artificial intelligence products or systems that include AI features, there are a number of things you should do:
To ensure the responsible and effective use of AI in NHS communications, staff must be equipped not only with technical understanding but with the professional judgement to apply AI in ways that align with NHS values and local context.
Training should not be viewed as a one-off requirement, but as a core component of long-term professional development. Evidence from across the NHS and wider public sector consistently shows that generic, one-time training has limited impact. Effective AI capability building requires role-differentiated learning, structured progression, and regular refresher as tools and guidance evolve.
Recommended competency tiers for NHS communications staff:
The NHS Alliance, supported by the NHS Communications AI Taskforce, is helping to coordinate national training efforts. This will include workshops, seminars and toolkits, mapped to the tiers above. 
Training should build both confidence and competence. We encourage organisations to share learning, feedback and resources that support a thriving, connected communications community as AI capabilities continue to evolve. 
Communications and public relations are vocations that are fundamentally about changing the thoughts, feelings and actions of target populations. Across all industries, but particularly in an area like the NHS, practitioners must constantly be alive to issues around ethics. Engagement activity shares this strong ethical dimension, with questions of who you are listening to (and who you are ignoring), what information you are sharing, what methods you are using, and how much power you are sharing, all requiring significant ethical focus.
We should regularly evaluate all of our approaches and tools from an ethical perspective, from paid advertising in newspapers and the social media platforms we use to the stalls we run at community events, regardless of AI use. However, it is clear that the tools related to AI require specific attention:
The NHS Alliance, supported by the NHS Communications AI Taskforce, is helping to coordinate national training efforts. This will include workshops, seminars and toolkits, mapped to the tiers above. 
Training should build both confidence and competence. We encourage organisations to share learning, feedback and resources that support a thriving, connected communications community as AI capabilities continue to evolve. 
This section provides principles, checklists and links to further resources to guide ongoing ethical discussions and adoption within teams.
The CIPR and PRCA both have codes of conduct. The following principles have drawn on these codes, as well as the work of a designated working group of NHS communications professionals, to offer a simple and clear set of ethical principles for NHS communications teams to discuss and consider in their everyday use of AI.
Training should not be viewed as a one-off requirement, but as a core component of long-term professional development
As this framework provides guidance and is not a prescriptive policy, adherence to its principles at an organisational level will be decided by each NHS organisation’s communications director or communications lead. They will ensure compliance within their respective communications departments, as appropriate, through robust mechanisms including staff awareness initiatives, the diligent completion of data protection impact assessments, regular spot-checks, and internal audits. The NHS Communications AI Taskforce will maintain a high-level oversight of the overall progress and adoption of AI in communications across the NHS, but it will not be responsible for direct organisational-level monitoring or compliance enforcement. 
This framework will be reviewed every 12 months by the NHS Communications AI Taskforce. It was first published in October 2025 and has been updated and re-published in October 2026. Due to the pace of change in AI technology, earlier review may be required in response to exceptional circumstances, organisational change or relevant changes in legislation/guidance.
We would highly recommend that communications staff keep up to date with the latest developments in AI technology and relevant legislation and guidance, as this field is rapidly evolving.
The framework will be published on the NHS Alliance website and sent to NHS communications leads.  
In developing this framework, an equality impact analysis (EIA) will have been undertaken by September 2025. The framework applies to all staff, regardless of protected characteristics. However, AI systems have been criticised for exhibiting racial or gender bias. Therefore, when assessing new technology, NHS organisations should build in inclusion and diversity into AI design by ensuring the right data is used to train AI systems and that outputs are ‘sense checked’ by a human. This is particularly pertinent when using AI to generate images or other communication content, where visual representation and messaging should be inclusive and free from bias. 
…when assessing new technology, NHS organisations should build in inclusion and diversity into AI design…
The UK General Data Protection Regulation (GDPR)/Data Protection Act 2018 includes the requirement to complete a data protection impact assessment for any processing that is likely to result in a high risk to individuals. Consideration should be given to any impact the framework may have on individual privacy; please consult your organisation’s information governance team. If you are commissioning a project or undertaking work that requires the processing of personal data, you should complete a data protection impact assessment. The NHS is committed to ensuring that all personal information is managed in accordance with current data protection legislation, professional codes of practice and records management and confidentiality guidance. For more information speak to your organisations data protection lead. 
The legal and regulatory landscape for AI and data has continued to evolve since this framework was first published. NHS communicators and their information governance colleagues should be aware of the following:
Download the pdf: NHS Communications AI Operating Framework v2
This framework forms part of a wider project being led by the NHS Communications AI Taskforce in partnership with the NHS Alliance. The taskforce provides strategic leadership and oversight for all the workstreams that are outlined in this report.
The NHS Alliance is the independent membership body that represents and supports the health and care system in England, Wales and Northern Ireland.
Address: 2nd Floor, 18 Smith Square, Westminster, London, SW1P 3HZ
Tel: 020 7799 6666
Email: enquiries@thenhsalliance.org

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