NHS England Data Sharing Remote Audit: University of Oxford

Purpose

This report records the key findings of a remote data sharing audit of University of Oxford (UoO) between 16 and 29 May 2024.  It provides an evaluation of how the UoO and its Processors conform to the requirements of:

• the data sharing framework contract (DSFC) CON-319043-Y2R5H-v2.03
• the data sharing agreement (DSA) DARS-402963-P0Y5D-v1.8
• the organisations’ own policies, processes and procedures

 This DSA covers the provision of the following datasets:

The Controller is the UoO and the Processors are Public Health Scotland (PHS), the University of Edinburgh (UoE) and the University of Liverpool.

The Coronavirus Clinical Information Network (CO-CIN) has collected data for the International Severe Acute Respiratory Infection Consortium (ISARIC) Coronavirus Clinical Characterisation Consortium through a commission from the Chief Medical Officer. ISARIC conduct Urgent Public Health Research to provide evidence that informs public health policy in response to the COVID-19 emergency. ISARIC is a global federation of clinical research networks, providing a proficient, coordinated and agile research response to outbreak-prone infectious diseases.

The ISARIC Coronavirus Clinical Characterisation Consortium is a UK-wide consortium of leading experts in outbreak medicine with a proficient, coordinated, and agile research response to COVID-19. Their purpose is to prevent illness and deaths from infectious disease outbreaks. 

PHS provides research services to ISARIC through their Electronic Data Research and Innovation Service (eDRIS) and the National Safe Haven (NSH) which is a secure environment where project data is uploaded, stored and accessed. The NSH is hosted by the Edinburgh Parallel Computing Centre (EPCC) based at the UoE.

The interviews during the audit were conducted through video conferencing.

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

Audit type and scope

Data recipient’s acceptance statement

The UoO, PHS and UoE have reviewed this report and confirmed that it is accurate.

Data recipient’s action plan

The UoO will establish a corrective action plan to address each finding shown in the findings tables in section 2. The Audit Team will validate this plan and the resultant actions at a post audit review with the UoO to confirm the findings have been satisfactorily addressed.

The Audit Team has identified 1 opportunity for improvement in section 3 which is provided for reference only and will not be followed up as part of any post audit review.

The following tables identify the 1 agreement nonconformity, 1 organisation nonconformity, 3 observations, and 3 points for follow-up raised as part of the audit.

UoE

The following table identifies 1 opportunity for improvement which could help an organisation improve its controls and processes.

Use of data

The UoO confirmed that the datasets were only being processed and used for the purposes defined in the DSA and were not being linked with another dataset.

Data location

The UoO 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 section 2c of the DSA.

Backup retention

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

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.