NHS England Data Sharing Remote Audit: Manchester University NHS Foundation Trust

Purpose

This report records the key findings of a remote data sharing audit of Manchester University NHS Foundation Trust (MFT) between 3 March and 7 March 2025. It provides an evaluation of how MFT and its Processor conform to the requirements of:

• the data sharing framework contract (DSFC) CON-324681-Z8K6R 
• the data sharing agreement (DSA) DARS-NIC-656836-T2J0T-v2.3
• the organisations’ own policies, processes and procedures

This DSA covers the provision of the following datasets:

The Controller is MFT and the Processor is The University of Manchester (UoM).

The DSA covers the Multifrequency Bioimpedance in the Early Detection of Lymphoedema Study (BEA study). The study determines how socioeconomic status, obesity and diabetes relate to breast cancer recurrence and death using 1229 female breast cancer patients undergoing Axillary Node Clearance. The aim of the study is to improve survival and reduce unwarranted variations in care for future breast cancer patients.

The original DSA was put in place between MFT and Public Health England (PHE) in 2021. The data was shared with MFT in 2021. The DSA was transferred to NHS Digital (now NHS England) in 2022. No further data is needed from NHS England.

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 4.0.

Audit type and scope

Data recipient’s acceptance statement

MFT and UoM have reviewed this report and confirmed that it is accurate.

Data recipient’s action plan

MFT and UoM 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 MFT 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 Audit Team has identified 2 opportunities for improvement in section 3 which are provided for reference only and will not be followed up as part of any post audit review.

The following tables identify the 3 agreement nonconformities, 2 organisation nonconformities and 1 observation raised as part of the audit. During the audit 2 of these findings were closed.

Use of data

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

Data location

MFT and the UoM confirmed that 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:

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.