NHS England Data Sharing Remote Audit: University of Bristol

Purpose

This report records the key findings of a remote data sharing audit of the University of Bristol (UoB) between 22 and 30 January 2024. It provides an evaluation of how UoB and its Processor conform to the requirements of:

• the data sharing framework contracts (DSFC):
  • UoB: CON-304765-H4P3X-2.02
  • Royal Devon University Healthcare NHS Foundation Trust (RDUH): CON-306176-T4X6H-v2.02
• the data sharing agreement (DSA) DARS-NIC-134719-D5W2Y-v0.17
• the organisations’ own policies, processes and procedures

This DSA covers the provision of the following datasets:

The Joint Controllers are UoB and and RDUH. The Processor is the University Hospitals Bristol and Weston NHS Foundation Trust (UHBW). UHBW’s role is limited to providing IT hosting services.

RDUH is the sponsor for this study and has oversight of the processes. RDUH do not have access to NHS England (NHSE) data and they will only see the aggregated outputs with small numbers suppressed in line with the NHSE analysis guidelines. For this reason it was agreed prior to the audit that RDUH would not participate, despite being named as a Joint Controller.

The UK Cohort Study to Investigate the Prevention of Parastomal Hernia (CIPHER) study is an ethically approved study with patients providing consent to participate. Participants understand how their data will be used and why. This study collected data about key technical surgical steps used during stoma formation and followed up participants to establish the incidence of symptomatic and clinically confirmed Parastomal Hernia (PSH). Modification of the technical aspects of surgery may reduce the incidence of PSH and could lead to improvements in health of patients, better quality of life, a reduction in stoma appliance and accessory costs and fewer PSH repairs.

The CIPHER study aims to establish the incidence of symptomatic and clinically confirmed PSH during a minimum of 2 years follow up, and to evaluate key technical surgical steps and the risk of developing a PSH when a stoma is created.

The interviews during the audit were conducted through video conferencing.

This is an exception report based on the criteria expressed in the Data Sharing Audit Guide version 4.

Audit type and scope

Data recipient’s acceptance statement

UoB and UHBW have reviewed this report and confirmed that it is accurate.

Data recipient’s action plan

UoB and UHBW will establish a corrective action plan to address each finding shown in the findings tables below. The Audit Team will validate this plan and the resultant actions at a post audit review with UoB and UHBW 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 tables identify the 6 agreement nonconformities, 2 organisation nonconformities, 2 observations, 6 opportunities for improvement and 3 points for follow-up raised as part of the audit. During the audit 1 of these findings was closed.

Use of data

The UoB 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 UoB and its Processor confirmed that the processing and storage locations, including disaster recovery and backups of the datasets, were limited to the locations 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 area of good practice:

• The UoB was able to clearly demonstrate the value the data supplied under this DSA has had towards benefitting the provision of health and social care in England, specifically in identifying risk factors that cause PSH.

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.