NHS England Data Sharing Remote Audit: NHS Cheshire and Merseyside Integrated Care Board

Purpose

This report records the key findings of a remote data sharing audit of NHS Cheshire and Merseyside Integrated Care Board (ICB) and Graphnet Health Limited (Graphnet) between 12 and 20 September 2022.  It provides an evaluation of how the ICB and Graphnet conforms to the requirements of both:

• the data sharing framework contract (DSFC) CON-331374-L9K3P-v2.01
• the data sharing application in progress (DSA) DARS-NIC-396095-H1P1D-v3.4

This DSA covers the provision of the following datasets:

The Controller is ICB, and the Processors are Graphnet and Microsoft Limited. Microsoft Limited are the cloud storage providers for Graphnet. The Audit Team acknowledge that the ICB came into formation on the 1 July 2022, following the merger of the Clinical Commissioning Groups.

The DSA declares a number of processors and processing activities; however, this audit was limited to Graphnet and the processing undertaken on behalf of the ICB.

The overarching purpose for this application is to support a set of COVID related population health analytics designed to inform both population level planning for COVID recovery and to support the targeting of direct care to vulnerable populations across the ICB.

A set of automated dashboards have been developed in the areas of COVID site reporting covering Capacity and Demand, Epidemiology, and Population Stratification have been made available to authorised end users. The dashboards will enable end users to support the local system including the COVID recovery cells, public health teams, Hospital and Out of Hospital cells across the Cheshire and Merseyside estate as well as local GPs with COVID planning, which includes support to General Practice and Primary Care Networks in intelligence required.

Graphnet were able to demonstrate that 3 out of 4 dashboards were displaying aggregated data, the remaining dashboard was offline. The ICB are liaising with Data Services for Commissioners Regional Office (DSCRO) to find a solution to perform re-identification through the DSCRO platform (see finding 10).

This report also considers whether the ICB and Graphnet conform to their own policies, processes and procedures.

The interviews during the audit were conducted through video conferencing. As these interviews took place before the merger of NHS Digital and NHS England, this report references both organisations.

This is an exception report based on the criteria expressed in the Data Sharing Remote Audit Guide version 1.

Audit type and scope

Data recipient’s acceptance statement

The ICB has reviewed this report and confirmed that it is accurate. 

During the audit, Graphnet informed the Audit Team that the DSA and DSFC had not been received prior to the audit from the ICB, which was confirmed by the ICB. Therefore, findings were raised which would have been expected to be addressed if Graphnet was aware of the requirements. See findings 1 and 2 for details. 

Data recipient’s action plan

The ICB will establish a corrective action plan to address each finding shown in the findings table below. The Audit Team will validate this plan and the resultant actions at a post audit review with the ICB to confirm the findings have been satisfactorily addressed. The post audit review will also consider the outstanding evidence at which point the Audit Team may raise further findings.

The following table identifies the 4 agreement nonconformities, 4 opportunities for improvement and 4 points for follow-up raised as part of the audit.

Use of data

The ICB confirmed that the datasets were only being processed and used for the purposes defined in the DSA and were only being linked with those datasets explicitly allowed in the DSA.

Data location

The ICB confirmed that processing and storage locations, including disaster recovery and backups, of the datasets were limited to the location shown in the following table.  These locations conform with the territory of use defined in clause 2c of the DSA.

Backup retention

The duration for which data may be retained on backup media is:

Good Practice

During the audit, the Audit Team noted the following areas of good practice:

• the value of the data supplied under this DSA was demonstrated through the use of the dashboards that have been developed under instruction of the ICB
• the data held by Graphnet on the cloud storage is geo-replicated within England and Wales in order to provide high availability. 

The audit was based upon a sample of the data recipient’s activities, as observed by the Audit Team. The findings detailed in this audit report may not include all possible nonconformities which may exist. In addition, as the audit interviews were conducted through a video conference platform, certain controls that would normally be assessed whilst onsite could not be witnessed.

NHS England has prepared this audit report for its own purposes. As a result, NHS England does not assume any liability to any person or organisation for any loss or damage suffered or costs incurred by it arising out of, or in connection with, this report, however such loss or damage is caused. NHS England does not assume liability for any loss occasioned to any person or organisation acting or refraining from acting as a result of any information contained in this report.