Re: NHS
Your concerns about making a company the custodian of NHS patient data are understandable, but they really are the last of our worries. It's like smoking 40 a day for 50 years, then worrying you'll get cancer because of the cigar you puffed on at your 70th birthday do. Similarly, I wouldn't worry about the NHS in respect of our idiot lawmakers trying to break encryption - the NHS would have to use it properly first, and there is scant evidence for that!
Having worked extensively with NHS organisations on data, systems and infrastructure projects, I am intimately familiar with their typical approach to data security. For central gov and NHS digital platforms, the approach is OK(ish), but at regional and local levels it's like the wild west. The security at many large NHS trusts I've worked with is so egregiously bad it would take me hours to explain properly.
Two or three years ago I consulted for a large trust who were introducing a whole new clinical systems platform (where they store ALL sensitive patient data). This involved auditing their current setup, what we found was diabolical, but sadly not uncommon. A few findings:
Restricted access to medical records is required by police, social workers, courts etc. This trust gave out remote access accounts to this data like giving out sweets. When a new SW or cop needed access, they created an account (usually generically named, NOT named to a user!). These accounts were given remote access to the unrestricted clinical records for ALL patients. Once created, the accounts remained active and weren't monitored. They had been doing this for years and by the time I saw it, there were over 800 live accounts providing full remote access to ALL data for ALL patients. When I told them we had to disable these and give out new per-user creds with RBAC to data, they said it was impossible, because they had no idea who these accounts were used by and no way of contacting the users!!! They didn't even have email addresses, even for the rare examples that resembled a person's name! This is YOUR data people!
A network audit showed that on ALL clinical system servers SMB1 was running as a service, and accessible to anyone on the network. I could enumerate shares while unauthenticated. Worse still, where physical firewalls were used, SMB1 was allowed between ALL networks and hosts! This is exactly what Wannacry (which happened 3 years prior), and tons of other nasties, uses to spread.
Another beauty was that their Clinical databases were exposed to the internet using ODBC! This was to provide trust employees with the convenient facility of compiling patient data reports from home.
Honestly, I could keep going here....
Eventually, they agreed in principle that the aforementioned remote accounts would need to be expunged and recreated properly (although they still had no idea how to contact the users!!!). I strongly advised that all accounts on the new platform should implement 2FA. They said no - didn't want to inconvenience users (esp the precious doctors). I therefore insisted that ALL remote accounts enforce 2FA, they said no again. I told them, in that case I'm walking - this is a disaster waiting to happen and I want nothing to do with it. This was escalated all the way to the CEO of the trust! I had to attend a meeting of their board to convince them that paying 2 quid per user per month (and then only for external access) was a price worth paying to keep our private clinical data safe. At no point did I get any backing from their IT or 'security' teams.
I eventually got the CEO to agree to 2FA, but ethical obligations were not the decisive factor. Instead, I had to emphasise the embarrassment and professional / reputational impact a leak might have on individual board members! And again I had to reiterate that I would be walking after the meeting if they didn't relent (I really was ready to just go).
I have several stories like this, stories so bad that I wouldn't believe them if I hadn't seen things first hand.
The level of negligence, ignorance and disinterest in information security within the NHS is barely believable. The complacency and willful ignorance of those responsible is mind-blowing, and this is why you don't need to worry about a single commercial custodian for NHS data. I am convinced of the fact that ALL our clinical data is possessed by, or accessible to, any state-level bad-actor you can think of. There are likely hundreds of breached systems in the NHS, each of which the bad guys will have full control of. It would not surprise me in the slightest if these systems are being curated and managed as strategic assets, ready to be exploited when the time is right.