NHS Digital Data Release Register - reformatted

Cegedim Rx Ltd projects

Cegedim Rx Ltd 2020

138 data files in total were disseminated unsafely (information about files used safely is missing for TRE/"system access" projects).

Cegedim Rx Ltd 2020 — DARS-NIC-355818-H7T3C

Type of data: information not disclosed for TRE projects

Opt outs honoured: No - data flow is not identifiable, Anonymised - ICO Code Compliant, No (Does not include the flow of confidential data)

Legal basis: Health and Social Care Act 2012 - s261 - 'Other dissemination of information', Health and Social Care Act 2012 s261(2)(a)

Purposes: Yes (Supplier)

Sensitive: Non Sensitive, and Sensitive, and Non-Sensitive

When:DSA runs 2021-01-25 — 2022-01-24 2021.01 — 2024.06.

Access method: Ongoing, One-Off

Data-controller type: CEGEDIM RX LTD

Sublicensing allowed: No

Datasets:

Hospital Episode Statistics Admitted Patient Care
Hospital Episode Statistics Accident and Emergency
Hospital Episode Statistics Critical Care
Hospital Episode Statistics Outpatients
Civil Registration - Deaths
HES:Civil Registration (Deaths) bridge
Civil Registration (Deaths) - Secondary Care Cut
Emergency Care Data Set (ECDS)
HES-ID to MPS-ID HES Accident and Emergency
HES-ID to MPS-ID HES Admitted Patient Care
HES-ID to MPS-ID HES Outpatients
Civil Registrations of Death - Secondary Care Cut
Hospital Episode Statistics Accident and Emergency (HES A and E)
Hospital Episode Statistics Admitted Patient Care (HES APC)
Hospital Episode Statistics Critical Care (HES Critical Care)
Hospital Episode Statistics Outpatients (HES OP)

Objectives:

This data sharing agreement requests the use of Hospital Episode Statistics (HES) and Mortality data to support essential public health, epidemiological, clinical and health economics research, improvements in healthcare service delivery, treatment, technology appraisals and patient safety monitoring that are complementary to the work performed and products supplied by Cegedim Health Data.

Cegedim RX Ltd wish to obtain HES and mortality data to create a secondary healthcare large scale data resource that will enable research providing insight in important disease areas, with national coverage over patient population, time and space to understand the patient healthcare clinical experience. The objective of the data analysis is to provide a deeper understanding of actual clinical pathways as seen implemented in the data for all disease areas with a view to elicit the clinical phenotypes (categories) of patients as they traverse their care pathway and support understanding the variations in the delivery of care. Cegedim RX Ltd will be providing researchers an opportunity to validate their research at a regional level (e.g. CCG/Primary Care Network/Integrated Care System levels). Validation will occur based on Cegedim RX Ltd performing internal analysis on the various HES data sets to provide supporting evidence for researcher studies.
Only substantive employees of Cegedim RX Ltd will have access to the record level, pseudonymised NHS Digital Data. Researchers will only receive an analysis based on HES and Mortality data, not the actual HES and Mortality data itself.

Cegedim Rx Ltd is part of the Cegedim Group, a major supplier of healthcare technology and information services across Europe and is the market leading supplier of software solutions and computer services to UK pharmacies. Cegedim Rx Ltd is a leading supplier of innovative healthcare technology, pharmacy software and data services offering integrated end-to-end service solutions to healthcare professionals, healthcare industries and life science companies.

Cegedim Health Data is a brand of Cegedim Rx Ltd in the UK. Cegedim Health Data provides Real World Data and Evidence (RWD-E) to drive cutting edge improvements in patient outcomes. With a data history of over 25 years and millions of anonymised patient records immediately accessible from the THIN (The Health Improvement Network) European database, Cegedim Health Data is the partner for RWD-E and Advanced Analytics in Europe.
Driving standards across the industry, Cegedim RX Ltd's expertise in IT solutions for healthcare providers and in data management provides; precise, ethical and actionable, fully anonymised patient data. Cegedim RX Ltd support their customers to deliver the application of data, intelligence and reason. This enables vastly improved business, society and patient outcomes.
Proprietary data is used for healthcare research and analysis by healthcare authorities, academics, pharmaceutical companies, and research organisations. More than 1000 scientific papers have been published as a result of evidence derived from their THIN database. Cegedim Health Data provides access to anonymised datasets through a variety of mediums, including analytical dashboards.

Cegedim Rx Ltd
Cegedim Rx Ltd is a limited company incorporated in 1993, which is owned by a holding company (ALLIADIS EUROPE LTD) which in turn is owned and directed by Cegedim SA (France). Cegedim Rx Ltd has an ISO accreditation issued in its name that spans all the shared services across the Cegedim SA Businesses in the UK

The Health Improvement Network (THIN) Ltd
THIN is a limited company directly owned by Cegedim SA (France), with a separate legal entity within the Cegedim Group with its own data environment.

IN PRACTICE SYSTEMS (INPS) Ltd
INPS Ltd is a limited company incorporated in 1984, owned by Cegedim SA. The trading name of INPS is VISION, which provides healthcare IT services to GP practices, shared-care services for different healthcare providers, population health information services, online patient services, and community support services. INPS Ltd is directly owned by Cegedim SA (France) and whose trading name is ‘Vision’

Bluebay Medical Systems
Bluebay Medical Systems has been absorbed by INPS Ltd. This was purchased by the holding company (ALLIADIS Europe Ltd) and then the business, employees, assets and liabilities were transferred to INPS Ltd at the start of 2019.

For the purpose of gaining access to NHS Digital data, the only entity of concern with respect to this application is Cegedim Rx Ltd. At no point will NHS Digital data supplied under this data sharing agreement be shared with IN PRACTICE SYSTEMS (INPS) Ltd, Bluebay Medical Systems, Cegedim SA or The Health Improvement Network (THIN) Ltd in any form other than aggregated with small number suppression applied as per the HES Analysis Guide

NHS Digital Data:
The specific datasets requested in relation to this application are:
- Civil Registration (deaths) - Secondary Care Cut linked to:
- Emergency Care Dataset (ECDS)
- HES A&E
- HES Admitted patient Care
- HES Critical Care
- HES Outpatients

Cegedim RX Ltd requires access to record-level pseudonymised data from the above datasets. The data will be pseudonymised using a HES specific pseudo-identifier provided by NHS Digital.

DATA MINIMISATION:
Data Minimisation will be applied by only requesting the fields which are required to do the minimum level of analysis at an individual patient record level. In addition no data fields have been requested that could potentially lead to patient re-identification with the data set request limited to the last 6 years only.

Cegedim RX Ltd are asking for 6 years of historic data (2014/15 to 2019/20) and current data to the end of the current agreement. This is because Cegedim RX Ltd expect the analysis of disease areas of interest to be impacted by changes in clinical coding guidelines and clinical best practices over the requested period of time. To enrich their understanding of the effect of such changes in epidemiological and ecological studies, Cegedim RX Ltd anticipate to perform pre-change and post-change separate analyses and also to implement models with inclusion of time interaction effects. Examples of the changes and updates Cegedim RX Ltd are seeking to investigate are in the management of Psychosis and Schizophrenia in adults (2015), Metastatic Breast cancer (2016), Non-small-cell Lung cancer that has progressed after/prior chemotherapy (2015), and Dementia (2015 and 2018).

Cegedim RX Ltd have made every effort to ensure that data requested is adequate, relevant but at the same time limited to what is essentially required, in terms of data sets (e.g. Admitted Patient Care, etc.) and period of time included, taking into consideration the changes in clinical coding and clinical best practice over the period of interest. Cegedim RX Ltd have also included only the required level of data in terms of spells and episodes, ensuring that no identifiable or sensitive fields have been selected. Finally, the linkages requested are only those required to fulfil our work (i.e. with Mortality data only).

Also in any outputs will be aggregated and not presented at a patient record level. Any analysis that yields patient numbers of less than 8 will be masked in analysis presentations with an asterix (*) as per the HES analysis guide.

In addition no data fields have been requested that could potentially lead to patient re-identification with the data set:

HES CC
• The data requested has been limited to the last 6 years only.
• Any fields associated with a specific time have not been requested to ensure that specific patients could not be re-identified.

HES APC
• Limited to 6 years historic data
• No Method of admission
• No Source of admission
• No Electoral ward
• IMD limited to Index of Multiple deprivation, Decile Group and overall rank

HES A&E
• Only 6 years requested
• No fields that are identified as high risk* or identifiable have been selected.
• Times of admissions and discharges not selected, only dates
• Location of incident leading to admission not requested

HES OP
• ensuring only the last 6 years worth of data is requested, to ensure any potential outputs are relevant to today's healthcare climate
• Patient's marital status not requested
• IMD has been limited to : Index of multiple deprivation ; IMD decile group and IMD overall ranking.
• No fields that are identified as high risk* or identifiable have been selected.

ECDS
• All fields relating to any specific time of admission or treatment for the patient, limited to date only
• All fields relating to location of the patient's injury (geographical).
• No fields that are identified as high risk* or identifiable have been selected.
• Any reference to a patients preferred language has not been requested

Civil Registrations (Deaths) - Summary Care Record
• Data minimisation will be implemented by ensuring that the data fields requested are limited to the locality of a Strategic Health Authority.
• No fields that are identified as high risk* or identifiable have been selected.

* HIGH RISK is as defined in the field selection criteria through DARS, deemed sensitive data.

Hospital admissions, outpatients care, Critical Care, A&E and mortality are fundamental data sets to achieve the objectives of this work. To achieve this aim while ensuring that the data set is accurate, relevant and limited to what is necessary for any particular project or research; Cegedim RX Ltd will ensure that no single variable can be directly related to a group of less than 6 patients, including diagnosis code (e.g. rare diseases) and year of birth .

The requested data will underpin essential public health, epidemiological, clinical and health economics research, improvements in healthcare service delivery, treatment, technology appraisals and patient safety monitoring, performed by academic bodies, government and regulatory agencies, and industry. The linked HES and Mortality data resource will be used in a standardised manner, fully complaint to the ethical, regulatory and data protection current legal frameworks, thus enabling trustworthy, standard-based, quality assured and scale-able approach to research.

Cegedim RX Ltd are asking for 6 years of historic data (2014/15 to 2019/20) and current data to the end of the current agreement. This is because Cegedim RX Ltd expect the analysis of disease areas of interest to be impacted by changes in clinical coding guidelines and clinical best practices over the requested period of time. To enrich their understanding of the effect of such changes in epidemiological and ecological studies, Cegedim RX Ltd anticipate to perform pre-change and post-change separate analyses and also to implement models with inclusion of time interaction effects. Examples of the changes and updates Cegedim RX Ltd are seeking to investigate are in the management of Psychosis and Schizophrenia in adults (2015), Metastatic Breast cancer (2016), Non-small-cell Lung cancer that has progressed after/prior chemotherapy (2015), and Dementia (2015 and 2018).

The secondary healthcare large scale data resource will enable research providing insight in important disease areas, with national coverage over patient population, time and space that is fundamental for the understanding of the patient healthcare clinical experience. This type of research will underpin decision-making in the continual improvement of clinical management of patients and service delivery at national and local levels. The geographical coverage of the data set will also provide the actionable evidence required to drive equity in the provision of care and optimise the utilisation of resources. This resource will offer new opportunities to ascertain the strength of previous evidence, providing a test bed for validation of public health, epidemiological and clinical research. It will also aim to measure and improve the quality of the research data stock in the United Kingdom. This processing will be used to perform essential public health, epidemiological, clinical and health economics research, supporting improvements in healthcare service delivery, treatment, technology appraisals and patient safety monitoring, using statistical, epidemiological and computational methods.

Cegedim RX Ltd will be providing researchers an opportunity to validate their research at a regional level (e.g. CCG/PCN/ICS levels). Validation will occur based on Cegedim RX Ltd performing internal analysis on the various HES and mortality data sets to provide supporting evidence for researcher studies. Researchers will only receive an analysis based on HES and mortality and not the actual HES and mortality data itself. Cegedim RX Ltd expect the following industries to be recipients of any HES and mortality data outputs as described in an aggregated and suppressed form:

- Academia,
- Independent researchers/epidemiologists,
- Pharmaceutical companies,
- Management consulting companies,
-Public health bodies,
- Medical Charities.

N.B: Cegedim RX Ltd does not engage with Insurance companies.

Examples of how the aggregated and suppressed data will be useful for analysis include scenarios such as:

- A view of the referring organisation for a patient and which speciality/organisation they have been referred into and then aggregated up to CCG/PCN/ICS
- Practices treat patients like X have an outcome of X, and practice treat patient like Y have outcome Y analysis may provide instances where care sits outside of NICE guidelines or in relation to Quality Outcome Framework (QOF) performance

Further examples of specific projects that Cegedim have previously been requested to perform by the above permitted clients include:

1. Venous Thromboembolism (VTE) and Surgeries: to describe the clinical journey of patients of patients experiencing VTE after surgeries (low and high risk), comparing standard with fast-track surgery designs with a view to gather evidence to inform patient recommendations and best clinical practice.
2. Natural History of Parkinson’s Disease: to study the incidence, morbidity, mortality and clinical journey of Parkinson’s Disease patients in secondary care to inform clinical decision making around adjuvant therapy and enrich understanding of patterns of utilisation of therapies.
3. Acute Respiratory Distress Syndrome: to study the incidence, morbidity, mortality associated with patient that experience Acute Respiratory Syndrome, including a descriptive analysis of the disease trajectory leading up to the event and patterns of care.

Cegedim RX Ltd also want to be able to add secondary care analysis as part of its services. Cegedim RX Ltd's researcher base are moving more into secondary care analysis, Cegedim RX Ltd having access to the above stated level of HES data will enable them to provide assistance to these organisations.

HES and Mortality data from NHS Digital will still be required to be provided to Cegedim RX Ltd at the patient level to be able to conduct such analysis for various regions. This also provides potential to identify areas of unwarranted variation of care e.g. length of time to diagnosis and referral to secondary care.

Patients with rare diseases and in general any patient with very specific clinical circumstances would be excluded from any analysis to reduce the risks of re-identification. In addition patients who present in any given CCG and where the total of that diagnosis or disease area count is <8, these figures and patients will be masked and not be available for analysis, as per the HES Analysis Guide.

Processing of the data requested under this agreement will be conducted under the legal basis set out by the General Data Protection Regulation (GDPR). 'Processing is necessary for the purposes of the legitimate interests pursued by the controller...' [Article 6(1)(f)]. Cegedim RX Ltd shared a copy of its Legitimate Interests Assessment (LIA) with NHS Digital. NHS Digital have assessed this response against the ICO’s checklist (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/legitimate-interests/) and are content that the requirements are met. The NHS Digital data sought will be used to support essential public health, epidemiological, clinical and health economics research, improvements in healthcare service delivery, treatment, technology appraisals and patient safety monitoring that are complementary to the work performed and products supplied by Cegedim Health Data. The pseudonymised NHS digital data will be processed internally by Cegedim RX Ltd for the purpose of producing aggregated tabulations/analysis with small number suppressed as per the HES analysis guide for specific projects for members form the aforementioned industry sectors.

Processing of special category data will be carried out in line with Article 9(2)(j) of GDPR - 'Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

Expected Benefits:

The use of HES and mortality data will explicitly be used for benefits to UK Health and Social Care whether this is directly or indirectly related to patient outcomes. Expected measurable benefits can be but not limited to:

• service pathway improvements
• technology appraisals
• early disease diagnosis
• identification of unmet need and variation in NHS policy implementation within primary and secondary care
• understanding of disease burden

The expectation is that the HES and mortality data set resource will feed new research that will underpin public health policy, clinical patient management drug efficacy and safety measure, and decisions of healthcare delivery. The impact of the result of the outputs will range from national level, when informing public health policy and clinical patient management, to local communities when the evidence will serve to optimise the delivery of care at CCG or care provider level. The initial measure of success will be the utilisation of the resource, in terms of number of applications, for public health, epidemiological and clinical research. Subsequent measures of success will be obtained from the number of scientific publications, policy documents, and clinical guidance that have been the result of using the resource.

The Cegedim RX Ltd Communication and Dissemination Strategy seeks to address the concerns of healthcare stakeholders in terms of public health, epidemiological and clinical research, drug efficacy and safety, and methodological research into the risk of re-identification of patients in the use of electronic health record data. With over 1000 publications, The Health Improvement Network (THIN Ltd – a Cegedim Company) has extensively contributed in providing evidence-based diagnostic and treatment recommendations, underpinning public health policy and clinical care. An important recent example is the “Dementia: comorbidities in patients - data briefing" by Public Health England for the use of health commissioners and providers of primary care and community services supporting patients with dementia . The current Communication and Dissemination Strategy will build on top of these achievements and further extend the breadth and depth of the current communications channels.

Benefits to patients will include a range of research projects that aim to understand more about disease risks and causes, improve diagnosis, develop new treatments, prevent disease, plan NHS services and improve patient safety. HES and mortality data will also benefit patients through understanding of treatment and consequently researchers having the ability to improve patient outcomes from these treatments/procedures. Overall, Cegedim RX Ltd expect this to result in recommendations to the various healthcare authorities with respect on reducing a patient’s number of bed days and occupancy.

As well as the above, Cegedim RX Ltd expect to be able to identify optimisation of processes and to help CCGs to implement NHS Rightcare pathways, therefore facilitating reduction in health inequalities in the country through research.

The Communication and Dissemination Strategy will address fundamental concerns of the public such as the secure, trustworthy and privacy-preserving use of electronic health records for public health, epidemiological and clinical research. In addition, the research output will provide evidence-based diagnostic and treatment recommendations, ascertain drug safety, and inform optimal planning of healthcare resources.

Cegedim RX Ltd anticipate studies looking at primary care data (THIN) alongside HES and mortality data will enable the identification at a regional level (CCG/ICS) of incidents of unwarranted variation of care. It is noted that HES and mortality data will be held in a separate location to the THIN data and no attempts to link either data set will be permitted. The analysis of both data sets separately will help provide validation of care occurring within primary care and subsequently secondary care and then back into the primary care setting.

This is expected to ignite conversations at the health policy level on how a population is treated and managed. A good example of such a study is a publication looking at Atrial Fibrillation diagnosis and the associated treatment and management within the healthcare settings https://www.bmj.com/content/361/bmj.k1717

Outputs:

The output will consist of secondary care data studies looking at understanding actual clinical pathways aimed at supporting essential public health, epidemiological, treatment and clinical research. The outputs will be in the form of reports, submissions to peer reviewed journals, presentations, papers for conferences, tabulations and analysis. Any aggregations resulting in small numbers will be appropriately suppressed using current NHS Digital HES Analysis guide rules for suppressing small numbers i.e. any numbers smaller than 8 replaced with '*'.

Cegedim RX Ltd's Dissemination and Communication Strategy will prioritise key disease areas based on their clinical importance and service delivery demand. They are Cardiovascular Disease, Neurodegenerative diseases, Cancer, Upper and Lower Respiratory Diseases, Diabetes, Kidney Disease and other diseases of the Urinary system, COVID-19. For each area Cegedim RX Ltd will perform a study extracting data-driven clinical pathways based on well-established methodologies, identifying clinical phenotypes at each pathway stage.

Examples of potential projects/Studies include:
1. Venous Thromboembolism (VTE) and Surgeries: to describe the clinical journey of patients of patients experiencing VTE after surgeries (low and high risk), comparing standard with fast-track surgery designs with a view to gather evidence to inform patient recommendations and best clinical practice.
2. Natural History of Parkinson’s Disease: to study the incidence, morbidity, mortality and clinical journey of Parkinson’s Disease patients in secondary care to inform clinical decision making around adjuvant therapy and enrich understanding of patterns of utilisation of therapies.
3. Acute Respiratory Distress Syndrome: to study the incidence, morbidity, mortality associated with patient that experience Acute Respiratory Syndrome, including a descriptive analysis of the disease trajectory leading up to the event and patterns of care.

By the end of the first year Cegedim RX Ltd will create the first technical report of the project for all priority disease areas and produce an dynamic info-graphics (tabulations) publicly available directed to relevant stakeholders. By the end of the second year, they will produce the data-driven clinical phenotypes for at each stage of the clinical pathways and produce the corresponding technical report. The dynamic info-graphics (tabulations) will be updated to display such clinical phenotypes and disseminated to key stakeholders. The outputs of each stage on the development will be published in relevant international conference first (years one and two), and then evolved into scientific publications during the second and third year.

All of the above mentioned outputs will be made available to those interested at CCG level.

The aim of the Dissemination and Communication Strategy is to effectively and efficiently reach the relevant stakeholder groups in the use of the research outputs, namely, public health agencies, academic community, patients and the public at large, industry, government decision makers, non-profit organisations and strategic partners. For each stakeholder group, an issue or problem-oriented mission approach will be implemented, making the communication relevant to the stakeholder group. Once the target audience and issue are identified, a series of targeted vehicles of communication and dissemination will be implemented, appropriate for the target audience, such as short-films, peer reviewed publication, conference posters, presentations, press releases, seminars, and demonstration events. Following the Cegedim RX Ltd dissemination and communication plan, there will be a quarterly delivery of dissemination and communication artefacts targeting different stakeholder groups.

Finally, researches will agree by contractual agreement to publish the result of their research in open access publications and deposit code list of implementing their results in public repositories, in order to foster transparency and reproduce-ability of research (applicable to permitted clients where research and discovery are the main aims of their function).

Processing:

No data will be submitted to NHS Digital by Cegedim RX Ltd for the purpose of this agreement. Cegedim RX Ltd is requesting access to the below minimised data sets.

DATA REQUESTED:
Record-level pseudonymised data for :
• ECDS – one drop of historic ECDS AR for 2019/20 and Q1 2020, and thereafter Q2, Q3 and Q4 for 2020/21, and Q1 for 2021/22 (to the end of the DSA).
• HES APC - one drop of historic data AR 2014/15 to 2019/20, and Q1 2020, and thereafter Q2, Q3 and Q4 for 2020/21, and Q1 for 2021/22 (to the end of the DSA).
• HES CC - one drop of historic data AR 2014/15 to 2019/20, and Q1 2020, and thereafter Q2, Q3 and Q4 for 2020/21, and Q1 for 2021/22 (to the end of the DSA).
• HES OP - one drop of historic data AR 2014/15 to 2019/20, and Q1 2020, and thereafter Q2, Q3 and Q4 for 2020/21, and Q1 for 2021/22 (to the end of the DSA).
• HES A&E - one drop of historic data AR 2014/15 to 2018/19 plus 2019/20 M12 (data set discontinued thereafter)
• HES: Civil Registration (Death) bridge
• Civil Registrations (Deaths) – Summary Care Record linked to historic and quarterly HES data to end of DSA.

DATA ANALYSIS METHODOLOGY
1. NHS Digital pseudonymised data will be transferred to Cegedim RX Ltd via Secure Electronic File Transfer (SEFT).
2. Cegedim RX Ltd will download the data into their secure data environment. Once downloaded, the data will be stored in a query-ready state. UK based researchers (Cegedim Rx Ltd substantive employees) will build queries using the HES Data Dictionary for descriptions of various coding.
3. The data will be accessed by approved substantive employees of Cegedim RX Ltd only to perform analysis on the data to produce outputs in line with bespoke requests analysis to be produced.
Outputs will include: Tabulations, Dashboards, Maps and outputs through Power BI. All outputs will be aggregated with small number suppression applied as per the HES Analysis Guide.
4. These outputs will be placed within a separate protected server for holding. Cegedim RX Ltd will received bespoke requests for analysis of data. Cegedim RX Ltd will perform the data analysis in-house and only provide outputs to researchers in forms of a presentation or other mediums and no record level pseudonymised HES or mortality data will be transferred outside the Cegedim Rx Ltd organisation.

The HES and mortality data are planned to be held and collated within the Cegedim RX Ltd secure environment, with only named substantive employees of Cegedim RX Ltd having access to querying the data to answer a legitimate research question. The environment is regulated through strict security measures and governance procedures prior to access being granted. These procedures include, but are not limited to: Evidence of online completion of patient data governance and the importance of GDPR in healthcare and research settings, evidence of mandatory internal Cegedim RX Ltd training. Access and administration rights are held by only 2 or 3 named individuals within the Cegedim RX Ltd organisation.

Cegedim RX Ltd staff accessing, working with or speaking to third parties about the data must undergo regular information governance training. Staff will have have regular information governance training. Cegedim RX Ltd ensures that only their substantive employees are processing the data in preparation for requests from researchers. Access is controlled via AD group. Only employees who are granted access may view data. The data can be accessed externally via VPN, but must be logged on as an authenticated user. There are no upload and download restrictions as user access to this area is for approved employees only for specific purposes.

Cegedim RX Ltd have mandatory training including:
• Cegedim UK Group GDPR Compliance
• Cegedim UK Group Data Protection and Security
• GDPR/DPA Awareness

Cegedim RX Ltd also have a range of security and information governance training packages available within their in-house UDEMY Learning Paths Package. Cegedim RX Ltd promote awareness via Cyber Security Bulletins on a ‘Message of the Week’ basis that include Cyber Security and Information Governance topics.

Cegedim RX Ltd back up their data regularly to encrypted tapes which are stored off-site by Iron Mountain. Iron Mountain (UK) Services Limited do not access data held under this agreement as they only supply the building for storage of back-up tapes. Therefore, any access to the data held under this agreement would be considered a breach of the agreement. This includes granting of access to the database[s] containing the data.

Patient privacy will be protected by pseudonymisation (HES specific ID) to reduce the risk of inadvertent re-identification, and security and governance policies that explicitly prohibit those accessing the data from releasing data publicly or attempting to identify patients. Cegedim RX Ltd will adhere to the required governance frameworks and protocols as stated in any potential data sharing agreement or conditions imposed as a result of this application.

All recipients of the data outputs (tabulations/visualisations/analysis) must also comply with contractual and information governance requirements as set out in the relevant data sharing agreements as well as complying with all conditions imposed. Outputs must not be distributed beyond the institution unless aggregated with small number suppression applied as per the HES Analysis guide.

Data provided by NHS Digital will not be linked to any other data held by Cegedim RX Ltd for the purpose of this processing. There must be no attempt to link the outputs with other data sources without specific ethical approval and amendment to this data sharing agreement.

ROLLING DELETION OF DATA
Cegedim RX Ltd have agreed to holding a maximum of 6 years of NHS Digital data at any one time. On an annual basis deletion of data will be performed by Cegedim RX Ltd to ensure that only 6 years of NHS Digital data is held at any one time at the point of renewal. Cegedim RX Ltd will complete a Data Destruction Certificate and provide NHS Digital with it upon renewal of this agreement. When performing this task Cegedim RX Ltd agree to comply with the National Cyber Security Centre guidance.

HES and ECDS DISCLOSURE CONTROL / SMALL NUMBER SUPPRESSION
In order to protect patient confidentiality, when presenting results calculated from HES record level data, outputs will contain only aggregate level data with small numbers suppressed in line with HES Analysis Guide. When publishing HES data, you must make sure that:
· cell values from 1 to 7 are suppressed at a local level to prevent possible identification of individuals from small counts within the table.
· Zeros (0) do not need to be suppressed.
· All other counts will be rounded to the nearest 5.
Data will not be made available to any third parties other than those specified except in the form of aggregated outputs with small numbers suppressed in line with the HES Analysis Guide.