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NHS England Data Sharing Remote Audit: Adelphi Group Limited​

This report records the key findings of a remote data sharing audit of Adelphi Group Limited (Adelphi) between 24 to 28 February 2025.

Audit summary

Purpose

This report records the key findings of a remote data sharing audit of Adelphi Group Limited (Adelphi) between 24 to 28 February 2025. It provides an evaluation of how Adelphi and its Processor conform to the requirements of:

  • the data sharing framework contracts (DSFC)
    • CON-670898-F6X6H
    • CON-290527-P5C0Y  
  • the data sharing agreements (DSA)
    • DARS-NIC-655446-P9K9Q-v0.7
    • DARS-NIC-682583-Z3V2H-v0.7
  • the organisations’ own policies, processes and procedures

 These DSAs cover the provision of the following datasets:

Dataset Classification of data Dataset period
 National Disease Registration Service (NDRS) Cancer Pathway*  Pseudonymised/ Non-sensitive  Latest Available
NDRS Cancer Registrations Pseudonymised/ Non-sensitive Latest Available
NDRS Linked Cancer Waiting Times (Treatments only) Pseudonymised/ Non-sensitive Latest Available
NDRS Linked Diagnostics Imaging Dataset Pseudonymised/ Non-sensitive Latest Available
NDRS Linked Hospital Episode Statistics (HES) Accident and Emergency Pseudonymised/ Non-sensitive Latest Available
NDRS Linked HES Admitted Patient Care Pseudonymised/ Non-sensitive Latest Available
NDRS Linked HES Outpatient Pseudonymised/ Non-sensitive Latest Available
NDRS National Radiotherapy Dataset Pseudonymised/ Non-sensitive Latest Available
NDRS Systemic Anti-Cancer Therapy Dataset Pseudonymised/ Non-sensitive Latest Available

*This dataset is only on DARS-NIC-682583-Z3V2H-v0.7

The joint Controllers are Adelphi and Merck Sharp and Dohme Limited (MSD); the Processor is Box.com (UK) Ltd (Box.com). Box.com do not have access to the data and only provide cloud hosting services. The interviews were limited to Adelphi. Each DSA covered the following:

  • DARS-NIC-682583-Z3V2H-v0.7 provides access to NHS England (NHSE) data for the purpose of the following research project: A retrospective observational study of treatment patterns, resource use and outcomes in patients with early-stage Non-Small Cell Lung Cancer (NSCLC) in England.
  • DARS-NIC-655446-P9K9Q-v0.7 provides access to National Disease Registration Service (NDRS) National Cancer Registration and Analysis Service (NCRAS) data for the purposes of the following project: A retrospective observational study of Patient Characteristics, treatment patterns and healthcare resource utilisation for stage II Melanoma in 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.

Audit type and scope

Audit type 

Focused

Scope areas 

Data Use and Benefits

Access Control

Information Transfer

Operational Management & Control

Restrictions 

Access control - limited visibility of physical controls 

Overall risk statement

Based on evidence presented during the audit and the type of data being shared the following risk has been assigned from the options of Critical - High - Medium - Low

Current risk statement: Low

In deriving this risk, the Audit Team takes into account compliance, duty of care, confidentiality and integrity, as appropriate.

Data recipient’s acceptance statement

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

Data recipient’s action plan

Adelphi will establish a corrective action plan to address each finding shown in the table below. The Audit Team will validate this plan and the resultant actions will be followed up with Adelphi by the IG Risk and Assurance team at NHS England to confirm the findings have been satisfactorily addressed.

The Audit Team has identified 1 opportunity for improvement which is provided for reference only and will not be followed up.


Findings

The following table identifies 1 organisation nonconformity, 1 observation and 2 follow-up items that were raised as part of the audit.

Ref Finding Link to area Clause Designation

 

  1.  

The Adelphi data flow diagram states that the data is held in the UK, however this conflicts with the DSA where the territory of use is England and Wales. This applies to both DSAs

​​Information Transfer

DSA, Annex A, Section 5c

​​ Organisation nonconformity

  1.  

The research outputs agreed in the DSA have changed from what was initially stated in the DSA. Adelphi have produced a presentation and output spreadsheet; however, a report is no longer planned. This applies to DSA NIC-655446-P9K9Q-v0.7.

​​Use and Benefits

DSA, Annex A, Section 5c

 

​​Observation

  1.  

Adelphi have not produced an output report that was expected by quarter 2 2024 as stated in the DSA. The DSA will need to be updated. This applies to DSA NIC-682583-Z3V2H-v0.7es. 

Use and Benefits DSA, Annex A, Section 5c Follow-up
  1.  

The DSA needs to be reviewed and updated to ensure there is no ambiguity regarding end user devices and how they are permitted to process data. This applies to both DSAs

​​Access Control

DSA, Annex A, Section 5b

​​Follow-up

Opportunities for improvement

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

Ref

Opportunities for improvement

Link to Area 

1.

Adelphi should remind staff that any outputs should contain an acknowledgement to NHS England as being the source of the data.. 

Use and Benefits

Use of data

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

Data location

Adelphi 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 the DSA.

Organisation Territory of Use
Adelphi England/Wales

Box.com

England/Wales

Backup retention

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

Organisation Media type Period
Box.com

Cloud 

6 months


Disclaimer

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. 

Last edited: 17 October 2025 2:37 pm