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​NHS England Data Sharing Audit: University of Bristol (UoB)

This report records the key findings of a remote data sharing audit of the University of Bristol (UoB) between 12 – 16 January 2026

Audit summary

Purpose

This report records the key findings of a remote data sharing audit of the University of Bristol (UoB) between 12 – 16 January 2026. It provides an evaluation of how the UoB and its Processor conform to the requirements of:

  • the data sharing framework contract (DSFC)
    • CON-304765-H4P3X (Version 2.03)
  • the data sharing agreements (DSAs)
    • DARS-NIC-748729-Z8B3M-v0.10 (consented)
    • DARS-NIC-420229-G9H9S-v0.20 (section 251 support)
  • the organisations’ own policies, processes and procedures

These DSAs cover the provision of the following datasets:

Dataset Classification of data Dataset period
Cancer Registration Data

Pseudo/Anonymised

Sensitive
Latest available
Civil Registrations of Death

Pseudo/Anonymised

Sensitive
Latest available
COVID-19 General Practice Extraction Service (GPES) Data for Pandemic Planning and Research (GDPPR)

Pseudo/Anonymised

Non-Sensitive
Latest available

COVID-19 Hospitalization in

England Surveillance System

Pseudo/Anonymised

Sensitive
March 2020 to August 2020
COVID-19 SGSS First Positives (Second Generation Surveillance System)

Pseudo/Anonymised

Sensitive
April 2020 to February 2024
Covid-19 UK Non-hospital Antibody Testing Results (Pillar 3)

Pseudo/Anonymised

Sensitive
September 2020 to July 2022
COVID-19 UK Non-hospital Antigen Testing Results (Pillar 2)

Pseudo/Anonymised

Sensitive
April 2020 to February 2024
COVID-19 Vaccination Adverse Reactions

Pseudo/Anonymised

Sensitive
December 2020 to September 2023
COVID-19 Vaccination Status

Pseudo/Anonymised

Sensitive
Latest available
Demographics   Latest available
Improving Access to Psychological Therapies (IAPT) v1.5

Pseudo/Anonymised

Sensitive
April 2012 - March 2021
Improving Access to Psychological Therapies (IAPT) v2

Pseudo/Anonymised Non-Sensitive

April 2021 - March 2025
Medicines dispensed in Primary Care (NHSBSA data)

Pseudo/Anonymised Non-Sensitive

Latest available
Community Services Data Set (CSDS)

Pseudo/Anonymised Non-Sensitive

2015/16 - 2023/24_Q03

2015/16 - 2024/25

2024/25_M08

2024/25_Q03

2025/26_Q01

2025/26_Q02

Emergency Care Data Set (ECDS)

Pseudo/Anonymised Non-Sensitive

2018/19 - 2023/24_Q3

2019/20 - 2024/25

2024/25_M10

2024/25_Q4

2025/26_Q1 - Q3

October 2017 to

March 2018 Final Data
Hospital Episode Statistics Accident and Emergency (HES A and E) Pseudo/Anonymised Non-Sensitive 2007/08 - 2019/20
Hospital Episode Statistics Admitted Patient Care (HES APC) Pseudo/Anonymised Non-Sensitive

1998/99 - 2024/25

2023/24_Q02

2023/24_Q03

2024/25_M10

2024/25_Q03

2024/25_Q04

2025/26_Q01

2025/26_Q02
Hospital Episode Statistics Critical Care (HES Critical Care) Pseudo/Anonymised Non-Sensitive

2008/09 - 2024/25

2024/25_M10

2024/25_Q03

2024/25_Q04

2025/26_Q01

2025/26_Q02
Hospital Episode Statistics Outpatients (HES OP) Pseudo/Anonymised Non-Sensitive

2003/04 - 2024/25

2024/25_M10

2024/25_Q03

2024/25_Q04

2025/26_Q01

2025/26_Q02
Maternity Services Data Set (MSDS) v1.5 Pseudo/Anonymised Non-Sensitive April 2015 - March 2019

Maternity Services Data Set

(MSDS) v2
Pseudo/Anonymised Non-Sensitive

2019/20 - 2024/25

2024/25_Q1

2024/25_Q2

2024/25_Q3

2025/26_Q1

2025/26_Q2

Mental Health and Learning

Disabilities Data Set (MHLDDS)
Pseudo/Anonymised Non-Sensitive 2014/15 - 2015/16

Mental Health Minimum Data

Set (MHMDS)
Pseudo/Anonymised Non-Sensitive 2006/07 - 2023/24

The Controller is the UoB and the Processor is Swansea University.

The DSA allows the Controller to share data with other organisations under a sub-license agreement.

The UoB requires access to NHS England data for the purposes of the UK Longitudinal Linkage Collaboration (UK LLC). The UK LLC is a ‘Trusted Research Environment’ designed to link study data from major inter-disciplinary Longitudinal Population Studies participants, to a wide range of participants’ health and non-health records and other sources.

The UK LLC aims to provide a data linkage resource to its partner studies and to provide a simple one application process to ONS accredited UK based researchers applying to access linked longitudinal data.

This unique resource enables cross-sector research and supporting research responses to immediate situations and future policy needs. The greater availability of large scale, diverse linked data will help provide improved representation, reduce bias and greater statistical power for researchers to study rarer outcomes and seldom reached populations.

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

Operational Management and Control

Sublicensing

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

The UoB has reviewed this report and confirmed that it is accurate.

Data recipient’s action plan

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

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


Findings

The following table identifies the 1 agreement nonconformity and 1 point for follow-up raised as part of the audit.

Ref Finding Link to area Clause Designation

1

The UoB must notify NHS England of any changes to the Data Access Acceptable Use Policy document before implementing any changes. A new version (2.1) was created in December 2025 which UK LLC did not share with NHS England. Use and Benefits

DSA Section 5 Purpose/Methods/Outputs

​​Agreement nonconformity

2 Swansea University Medical School’s Access Control Policy (v1.11) is subject to an annual review. This should have been completed in October 2025. Operational Management  

Follow-up

Opportunities for improvement

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

Ref

Opportunities for improvement

Link to Area 

1.

There is currently no system in place which checks if researchers’ accounts are dormant. Although dormant periods are to be expected, the UoB should consider conducting quarterly checks. Operational Management

Use of Data

The UoB 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

The UoB and Swansea University 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.

Organisation Territory of Use
The UoB UK
Swansea University UK

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: 26 March 2026 1:46 pm