​NHS England Data Sharing Audit: Cambridge University Hospitals NHS Foundation Trust

Purpose

This report records the key findings of a remote data sharing audit of Cambridge University Hospitals NHS Foundation Trust (CUHFT) and University of Cambridge (UoC) where the interviews were conducted between 20 and 23 October 2025. It provides an evaluation of how CUHFT and UoC conform to the requirements of:

• the data sharing framework contract (DSFC)
  •  CON-314354-C8S4C-v2.02 (CUHFT)
  •  CON-321529-Q1B0S-v2.02 (UoC)
• the data sharing agreement (DSA) NIC-662465-L3R5W-v0.3

• the organisations’ own policies, processes and procedures

This DSA covers the provision of the following datasets: 

The Joint Controllers and Processors are CUHFT and UoC.

The primary objective of the Pragmatic randomised trial of High Or Standard PHosphAte Targets in End-stage kidney disease (PHOSPHATE) research study, is to test the hypothesis that phosphate lowering treatment to reduce serum phosphate level towards the normal level reduces fatal and non-fatal major cardiovascular events in patients receiving dialysis compared to a strategy of liberalised phosphate control with phosphate-lowering treatment for serum phosphate levels.

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

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

Data recipient’s action plan

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

The Audit has identified 4 opportunities for improvement, which are detailed in table after the findings, and are provided for reference only and will not be followed up.

The following table identifies the 6 observations, and 2 points for follow-up raised as part of the audit.

The following table identifies 4 opportunities for improvement which could help an organisation improve its controls or processes.

Use of Data

CUHFT 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

CUHFT and UoC 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.