Does a PCN need to do a DSPT?

We have received a few queries about whether PCNs need to complete a DSPT assessment. The DSPT support section says the following:

If a PCN is a separate organisation to the general practices in the network, is processing health data and taking legal responsibility for the data processing, then it should complete the DSPT.

If the PCN is a not a separate organisation and another organisation, such as the lead general practice, takes legal responsibility for the health data processing of the PCN, then that General Practice should include the PCN data processing in its DSPT submission.

Primary Care Networks should select ‘Other (including charities and NHS Business Partners)’ as their primary sector.