NHS England Data Sharing Audit: Hull University Teaching NHS Trust
This report records the key findings of a remote data sharing audit of Hull University Teaching NHS Trust (HUTH) where the interviews were conducted between 27 April – 1 May 2026.
Audit summary
Purpose
This report records the key findings of a remote data sharing audit of Hull University Teaching NHS Trust (HUTH) between 27 April – 1 May 2026. It provides an evaluation of how HUTH conform to the requirements of:
- the data sharing framework contract (DSFC) CON-322914-N9K2Q (Version 2.02)
- the data sharing agreement (DSA) number DARS-NIC-719601-J7Z2S-v0.12
- the organisations’ own policies, processes and procedures
This DSA covers the provision of the following datasets:
| Dataset | Classification of data | Dataset period |
|---|---|---|
|
Civil Registrations of Death |
Pseudo/Anonymised Sensitive |
Latest available |
|
Emergency Care Data Set (ECDS) |
Pseudo/Anonymised Sensitive |
2020/21 - 2023/24 2024/25_M09 |
|
Hospital Episode Statistics Accident and Emergency (HES A and E) |
Pseudo/Anonymised Non-Sensitive |
2011/12 - 2019/20 |
|
Hospital Episode Statistics Admitted Patient Care (HES APC) |
Pseudo/Anonymised Non-Sensitive |
2011/12 - 2023/24 2024/25_M09 |
HUTH is the Controller and the Processor.
HUTH requires access to NHS England data for the purpose of the following research project: Assessing Diabetes’ Influence on Cardiovascular Health: A Machine Learning Analysis of National Institute for Cardiovascular Outcomes Research (NICOR) Database Patients.
The study's objective is to use various machine learning algorithms to understand the Relative Influence of diabetes on survival, stent-stenosis, and recurrent myocardial infarction in people with cardiovascular disease.
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 5.
Audit type and scope
|
Audit type |
Focused |
|---|---|
|
Scope areas |
Information Transfer Access Control Data Use and Benefits Operational Management and Control |
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: Medium
In deriving this risk, the Audit Team takes into account compliance, duty of care, confidentiality and integrity, as appropriate.
Data recipient’s acceptance statement
HUTH has reviewed this report and confirmed that it is accurate.
Data recipient’s action plan
HUTH will establish a corrective action plan to address each finding. The Audit Team will validate this plan and the resultant actions at a post audit review with HUTH to confirm the findings have been satisfactorily addressed. The post audit review will also consider the outstanding evidence at which point the Audit Team may raise further findings.
The Audit Team has identified 3 opportunities for improvement which are provided for reference only and will not be followed up as part of any post audit review.
Findings
The following table identifies the 4 agreement nonconformities, 1 organisation nonconformity, 1 observation, and 5 points for follow-up raised as part of the audit.
| Ref | Finding | Link to area | Clause | Designation |
|---|---|---|---|---|
|
1 |
No publicly accessible privacy notice for the study was available at the time of audit. |
Operational Management |
DSA Section 4 |
Agreement nonconformity |
| 2 |
Access to data is not in line with the specific requirements outlined within the DSA. |
Access Control |
DSA Section 5b |
Agreement nonconformity |
| 3 |
A Data Protection Impact Assessment (DPIA) has not been undertaken with respect to the data supplied by NHS England. A DPIA screening performed by HUTH concluded a DPIA to not be required, which is being reconsidered. |
Operational Management |
DSFC, Schedule 3, General Data Protection Regulation (UK GDPR) |
Agreement nonconformity |
| 4 |
Log files on file access were not available on the server as logging had not been enabled. |
Access Control |
DSFC, Part 2, Schedule 2, Section A, Clause 4.3 |
Agreement nonconformity |
| 5 |
No evidence was provided to confirm that HUTH internal requirements for encryption deviations had been met for the server being used to store data provided by NHS England. |
Access Control |
GP72 - S6.3.1 and 6.3.3 |
Organisation nonconformity |
| 6 |
Incident reporting processes were in place; however, they do not clearly specify immediate notification to NHS England for incidents involving NHS England data in line with the DSA. |
Operational Management |
DSFC, Part 2, Schedule 2, Section B, Clause 4.7 |
Observation |
| 7 |
At the post audit review, the Audit Team will review the updates due to be made to the outdated internal policies identified during the audit. |
Operational Management |
DSFC, Part 2, Schedule 2, Section A, Clause 3 |
Follow-up |
| 8 |
In future, HUTH’s Information Governance Committee needs to be sighted on any new applications for NHSE data. |
Operational Management |
DSFC, Part 2, Schedule 2, Section A, Clause 3 |
Follow-up |
| 9 |
At the post audit review, the Audit Team will review the upcoming changes to HUTH’s Asset Management standard practices. |
Access Control |
DSFC, Part 2, Schedule 2, Section A, Clause 4.7 |
Follow-up |
| 10 |
At the post audit review the Audit Team will review the submission of the annual compliance report, which is due by October 2026. |
Access Control |
DSA Section 6 |
Follow-up |
| 11 |
At the post audit review, the Audit Team will review evidence of the published outputs from the study as recorded in the DSA. |
Use and Benefits |
DSA Section 5c |
Follow-up |
Opportunities for improvement
The following table identifies 3 opportunities for improvement which could help an organisation improve its controls or processes. HUTH should consider:
|
Ref |
Opportunities for improvement |
Link to Area |
|---|---|---|
|
1. |
Reviewing the six week completion period for induction and mandatory Information Governance (IG) training. This creates a potential exposure window where staff may undertake duties prior to receiving essential training. |
Operational Management |
| 2. |
Aligning its password policies to be in line with current National Cyber Security Centre (NCSC) guidance. |
Access Control |
| 3. |
Strengthening its technical controls around data leakage. |
Access Control |
Use of Data
HUTH 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
HUTH 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.
| Organisation | Territory of Use |
|---|---|
|
HUTH |
England / Wales |
Backup Retention
The duration for which data may be retained on backup media is:
| Organisation | Media Type | Period |
|---|---|---|
|
HUTH |
Media |
60 days |
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: 24 July 2026 4:26 pm