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