9 Access to health data at UCLH - 5 safes
Contents
Five Safes at UCLH overview
Safe people
Safe projects
UCL UCLH Joint Research Office checklist
Safe settings
Safe outputs
Safe data
Data access checklist
9.1 Five Safes at UCLH overview
Data access at UCLH is judged using the ‘5 safes’ framework. This summarises our local implementation.
Safe people
all individuals have substantive contracts or educational relationships with higher education or NHS institutions
those working need to have evidence of experience of working with such data (e.g. previous training, previous work with ONS, data safe havens etc.) or they need a supervisor who can has similar experience
those working need to undergo training in information governance and issues with statistical disclosure control (SDC)
Safe projects
projects must serve the public good
projects must meet relevant HRA and UCLH research and ethics approvals
service delivery work mandated as per usual trust processes
Safe settings
working at UCLH in the NHS on approved infrastructure
UCLH local and remote desktops
UCLH Data Science Desktop
EMAP
Safe outputs
outputs (e.g. reports, figures and tables) must be non-disclosing
outputs should remain on NHS systems initially
a copy of all outputs that are released externally (documents) should be stored in one central location so that there is visibility for all
Safe data
direct identifiers (hospital numbers, NHS numbers, names etc) should be masked unless there is an explicit justification for their use
data releases are proportionate (e.g. limited by calendar periods, by patient cohort etc.)
further work to obscure or mask the data is not necessary given the other safe guards (as per the recommendation by the UK data service)
We will now give more details for each of the 5 safes.
9.2 Safe people
We suggest you measure yourself against the following criteria. When you are ready, then please submit your evidence here
9.2.1 Your role
A user should either
- Hold an Honorary or Substantive contract with UCLH
- An NHS research passport or a letter of access
9.2.2 Your technical skills
A user should either
- hold a clinical qualification (in medicine, nursing, or the allied health professions) and have demonstrable experience in the management and analysis of health care data
- or hold a relevant undergraduate degree (or higher) in a field of study using quantitative data
- or be able to demonstrate at least three years quantitative research, audit or business intelligence experience
- or have a named supervisor who meets the above criteria and confirms sufficient time to support the user
9.2.3 Your training
A user should demonstrate all of the following
- Current information governance training
- UCLH mandatory IG training certificate
- or the MRC’s Research, GDPR and confidentiality training certificate
- Good Clinical Practice training
Microdata is information at the level of individual. All data derived from an electronic health record is by definition microdata unless later aggregated.
9.2.4 Your microdata experience
A user should demonstrate one of the following 1. Demonstrable experience using microdata. Suggested supporting evidence would include: - the microdata used (e.g. ONS list cleaning, EHRS queries on Caboodle/Clarity) - the source of the microdata (e.g. UCLH) - the project - your role in the project (e.g. analyst, Chief Investigator) - statistical techniques used - measures used to protect confidentiality (e.g. examples of statistical disclosure control) - statistical or development software used - Completed assessments from the Data access training module derived from material provided by the Safe Data Access Professionals Working Group
9.3 Safe projects
We have adopted and adapted the ONS Data Ethics Advisory Committee’s application form.
Where you have an existing IRAS form, we have indicated the sections that can be directly copy-and-pasted into this application.
The UCLH version can be downloaded here.
The project application headings are summarised below
Application Type: Research or Exploratory analysis Most applications will require formal research approval, but there are circumstances where the work will be exploratory. This will need to be justified to the UCLH data access committee.
Project Lead Name and details with comment on whether the lead will also view the data or just the derived outputs
Researcher Team Name and details of all members plus guidance as to whom the project lead is deputising
Research Sponsor Have you been commissioned to perform this research for another organisation?
Title of the research project And estimated duration of the project
Abstract of the research project Include a short description of the project and its benefits, in no more than 100 words. or IRAS Section A6-1 “Summary of the study” (300 words)
Purpose of Research Project Provide a detailed description of the purpose for which the data are requested, describing the aims of the study/research in no more than 500 words. Where research is part of a larger programme please include details below. or IRAS Section A12. “What is the scientific justification for the research?”
Research Methodology Provide details of the research protocol or methodology (e.g. data linkage or matching, statistical modelling etc) and how you intend to use the data, in no more than 1000 words. or IRAS Section A13. “Please give a full summary of your design and methodology”
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Data Required
List the data sources, the patient cohorts and the timer periods you wish to examine. Give as much detail as possible on the exact data items you require.
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Describe what portions of the data will be or might be identifiable using the framework below. For example, you might require hospital number to link to other data items (a direct identifier). However, you might also require date of birth to define age, this might be an identifying with other information.
Direct identifiers e.g. names, NHS number, hospital number etc.
Indirect identifiers e.g. date of birth, diagnosis, the first 3 letters of a postcode etc.
Non-identifying variables e.g. heart rate, creatinine, urine volume
Free text Where under normal circumstances de-identification is not guaranteed
Other data sources If you intend to bring in any data for your project, give details of the data including who the owner is and provide evidence that the owner has given permission for their data to be used by you for this research.
Justification for access to this rather than existing or public data Explain why access to legally protected (unpublished) data is needed. Please state what other data sources have been considered and why they are not sufficient for your purposes.
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Data linkage Does your project include any linking of data sources (as defined within the application guidance)? If yes, provide the following details below:
- description of the data sources(s) to be linked
- summary of the key variables;
- summary of the linking methodology; and
- the justification for the linking.
Ethics You will need to provide evidence of an ethics consideration for your research project. Have you had ethical approval for this project from your organisation or elsewhere?
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Public Good
Please describe how your research project will provide a public good. Complete all the sections that apply (e.g. Provide an evidence base for health care including direct patient or health system benefit)
Have any risks to public benefit been identified? What are they and how have they been mitigated?
Duration of access What is your best estimate of the last time you will need access to the unpublished data? Note: if applying for exploratory analysis, access will be granted for a maximum of 12 months
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Publications In order to access unpublished data for research purposes, you must promise that your findings will be made publicly available. Exemptions may only be granted in exceptional circumstances. Note: If you are applying for exploratory analysis, no publications are permitted.
- How do you intend to make your research available to the public?
- Which specific journals, websites or reports do you intend to use to publish this research?
- What is your best estimate of the project publication date. - What, if any, are the circumstances that mean you need an exemption from making your results publicly available? or IRAS Section A51. “How do you intend to report and disseminate the results of the study”
9.3.1 UCL UCLH Joint Research Office checklist
Starting a new study There are typically three stages of approval that must be considered before conducting clinical research:
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Evidence of peer review
Draft protocol for an observational study on a JRO template
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Applicable draft participant documents (where patients are being consented)
Participant Information Sheet
Consent forms
GP letters
CV of the Chief Investigator (HRA template)
Draft Organisation Information Document and Schedule Of Events
Evidence of funding (where applicable)
Details of any collaborations with external parties, including commercial entities and suppliers
Any conflicts of interest
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Research Ethics
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GDPR
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HRA
Complete a research application form on the Integrated Research Application System (IRAS)
Book your application in through theOnline Booking Service
E-submit yourapplications in IRAS.
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UCLH feasibility (aka NHS Site Assess, Arrange and Confirm)
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Checks
General feasibility assessment as required by the HRA
Clinical director authorisation
Finance review to ensure costs are identified and covered
Where required, a Contract review and negotiation
Honorary research contracts or Letters of Access where required for non-UCLH researchers to carry out research activity on site. Please contact the JRO on uclh.jro-communications@nhs.net
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Core documents
Copy of IRAS Form (combined REC and R&D form) as submitted for HRA Approval Protocol
Any substantial or non-substantial amendments
Participant information and consent documents
Statement of Activities relevant to the participating NHS organisation (non-commercially sponsored only) or delegation log (commercially sponsored only)
Relevant template contract/model agreement (if needed in addition to the Statement of Activities)
Costing template (commercially sponsored only) or Schedule of Events (non-commercially sponsored only)
Any other documents that the sponsor wishes to provide to the site to support the set up and delivery of the study
Copy of HRA Initial Assessment letter (if one is issued) and (when issued) HRA Approval letter, and final versions of study documents.
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Links
9.4 Safe settings
You should confirm that you are working at UCLH on approved infrastructure. For example,
UCLH local and remote desktops
or UCLH Data Science Desktop
or a Generic Application Environment provisioned through EMAP
9.5 Safe outputs
You should confirm that
outputs must be non-disclosing
outputs must remain on UCLH systems until suitable publication clearance can be demonstrated
outputs will be archived as per any internal processes mandated by any of UCLH Information Services, Clinical Research Informatics Unit or the UCL/UCLH Joint Research Office
Outputs include
manuscripts or reports containing prose, tables and figures
software applications
statistical models (e.g. machine learning, artificial intelligence or similar)
data (electronic or otherwise)
9.6 Safe data
You are expected to explain in your Safe projects application :
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any requirement for access to
direct or indirect identifiers otherwise a pseudonymised identifier will be provided
sensitive information (e.g. HIV status, drug and alcohol history, mental health history etc.)
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how your data request is proportionate. We suggest you provide clear limits by
calendar period
patient cohort
data content
Further work to obscure or mask the data should not be necessary given the other safeguards.
9.7 Data access checklist
Safe people
all individuals have substantive contracts or educational relationships with higher education or NHS institutions
those working need to have evidence of experience of working with such data (e.g. previous training, previous work with ONS, data safe havens etc.) or they need a supervisor who can has similar experience
those working need to undergo training in information governance and issues with statistical disclosure control (SDC)
Safe projects
projects must 'serve the public good'
projects must meet relevant HRA and UCLH research and ethics approvals
service delivery work mandated as per usual trust processes
Safe settings
-
working at UCLH in the NHS on approved infrastructure
UCLH local and remote desktops
UCLH Data Science Desktop
EMAP
Safe outputs
outputs (e.g. reports, figures and tables) must be non-disclosing
outputs should remain on NHS systems initially
a copy of all outputs that are released externally (documents) should be stored in one central location so that there is visibility for all
Safe data
direct identifiers (hospital numbers, NHS numbers, names etc) should be masked unless there is an explicit justification for their use
data releases are proportionate (e.g. limited by calendar periods, by patient cohort etc.)
further work to obscure or mask the data is not necessary given the other safe guards (as per the recommendation by the UK data service)