NHS England Data Sharing Remote Audit: Our Future Health​

Purpose

This report records the key findings of a remote data sharing audit of Our Future Health (OFH) between 02 and 06 December 2024.  It provides an evaluation of how OFH conforms to the requirements of: 

• the data sharing framework contract (DSFC) CON-640689-Q9J6Q-v2.02 

• the data sharing agreement (DSA) DARS-NIC-411795-X5N2V-v0.9  

• the organisation’s own policies, processes and procedures 

This DSA covers the provision of the following datasets: 

The Controller is OFH and the Processors are Microsoft Azure Limited and DNAnexus Inc. Microsoft Azure Limited provides Cloud storage and DNAnexus Inc provide the Trusted Research Environment (TRE) software functionality.  The DSA allows the Controller to share data with other organisations under a sub-license agreement.  

OFH was formed as part of the UK Life Sciences Industrial Strategy. It is designed to be the UK’s largest ever health research programme with the goal to recruit up to 5 million adult participants from across the UK to create a detailed picture that reflects the whole of the population. 

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

OFH has reviewed this report and confirmed that it is accurate.  

Data recipient’s action plan

OFH will establish a corrective action plan to address each finding shown in the findings table in section 2. The Audit Team will validate this plan and the resultant actions at a post audit review (PAR) with OFH to confirm the findings have been satisfactorily addressed. The PAR 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 is provided for reference only and will not be followed up as part of any PAR.

The following table identifies the 3 agreement nonconformities, 2 observations and 1 point for follow-up raised as part of the audit.

The following table identifies 2 opportunities for improvement which could help an organisation improve its controls and processes.

Use of data

OFH 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

OFH 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.