A legal and ethical architecture for a surgical video data registry in England

Surgical video is an emerging, high-value data source for quality improvement, education, and AI-enabled innovation, yet existing legal and ethical frameworks have not been designed with its distinctive properties in mind. In this perspective we propose a governance architecture for a surgical video data research registry in England that clarifies how surgical video should be classified across health law and data protection law, and how these regimes intersect over the data lifecycle. Firstly, we analyse the legal status of surgical video and associated metadata at key processing stages, highlighting when it constitutes confidential patient information, personal data, and special category health data. Secondly, we outline a two‑tier pathway for registry development differentiating between retrospective and prospective inclusion. Thirdly, we describe a registry model that relies on pseudonymisation, accredited secure data environments, independent oversight, and proportionate access controls to enable EHR linkage while minimising re-identification risk and preserving public trust. While developed in the context of the English National Health Service, this architecture offers a transferable template for health systems globally seeking to responsibly harness high-dimensional intraoperative data for AI development and learning health-care, while maintaining robust protections for privacy, confidentiality, and accountability.