NHS Digital Data Release Register - reformatted

Sanofi Pasteur projects

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

Study of Recombinant Protein Vaccines with Adjuvant as a Primary Series and as a Booster Dose against COVID-19 in Adults 18 Years of Age and Older — DARS-NIC-526363-C3M1K

Opt outs honoured: Identifiable (Consent (Reasonable Expectation))

Legal basis: Health and Social Care Act 2012 – s261(2)(c)

Purposes: Yes (Commercial)

Sensitive: Non-Sensitive

When:DSA runs 2021-07-20 — 2022-07-19

Access method: One-Off

Data-controller type: SANOFI PASTEUR

Sublicensing allowed: No


  1. Permission to Contact


This Data Sharing Agreement authorises the use of information voluntarily provided to NHS Digital by individuals who have given permission to be contacted about potential participation in COVID-19 vaccine clinical trials. The data will be processed on behalf of the data controller, Sanofi Pasteur, by NHS Digital as a data processor for the purpose of supporting recruitment to participate in a COVID-19 vaccine trial being run by Sanofi Pasteur.

The following provides background to the Permission to Contact (PtC) Service:

NHS Digital has agreed to work in partnership with the National Institute of Health Research (NIHR) to build and host a first of type online Permission to Contact (PtC) Service on nhs.uk where members of the public can register their details and give their permission to be contacted by researchers working on NIHR approved UK coronavirus vaccine trials about participating in those trials. This PtC Service, which is called “Sign Up to be Contacted about Coronavirus Vaccine Studies” on the nhs.uk website was launched as a national service on 20th July 2020.

This Service enables participants to:
• Provide permission for NHS Digital to share an individual’s details provided through the Service with the researchers undertaking COVID-19 UK vaccine trials for the purposes of researchers contacting that individual about taking part in those trials.
• Provide their permission to be contacted by NHS Digital about progress and outcomes from CV19 vaccine studies and in relation to the development of the PtC Service, including to inform them of opportunities to participate in other types of health research.

The data collected from individuals who sign up includes sufficient information to achieve the following purposes:
• Matching potentially eligible participants to eligibility criteria provided by the vaccine trials for their specific studies. This data will comprise of age, sex, geographic locations, type of employment, and a number health question e.g. about whether they have long-term health conditions.
• Providing relevant details of potentially eligible participants which have been obtained through the Service to researchers. This will allow the researchers to contact the participants with a view to discussing their taking part in a trial and if so, to obtain their further permission to take part in the trial.
• NHS Digital will provide access to the information obtained from individuals through the Service via the existing Data Access Request Service (DARS) process available to researchers working on UK COVID-19 vaccine trials sponsored by the National Institute of Health Research. The Service will only provide researchers with the data collected directly from individuals themselves through the Service.

The contact details will be used to invite potentially eligible individuals to undertake an eligibility assessment and, if eligible, to give informed consent to participate in this trial. NHS Digital, as data processor acting on behalf of Royal Free London NHS Foundation Trust., will be sending the email to eligible participants.

This request relates specifically to a vaccine trial. This is a Study of Recombinant Protein Vaccines with Adjuvant as a Primary Series and as a Booster Dose against COVID-19 in Adults 18 Years of Age and Older. It’s full title is ‘Immunogenicity and Safety of SARS-CoV-2 Recombinant Protein Vaccines with AS03 Adjuvant in Adults 18 Years of Age and Older as a Primary Series and Immunogenicity and Safety of a Booster Dose of SARS-CoV-2 Adjuvanted Recombinant Protein Vaccines (two Monovalent and one Bivalent)’.

There has been particular emphasis on developing variant strain vaccines to protect against the B.1.351 variant. Ongoing evolution of SARS-CoV-2 variants, especially in light of the growing prevalence of vaccination and the selection pressure that this may exert raises the strong public health requirement for SARS-CoV-2 vaccines, including those protective against emergent variants of concern.

To address the emergence of variant strains, Sanofi Pasteur is developing monovalent (contains one antibody) and bivalent vaccines (contains two antibodies).

The aim is to recruit 550 participants for the trial. The initial mailout will aim for around four / five times the number of potential participants to be recruited and therefore the estimate is for around 2,200 individuals to be contacted.

The data will be used in support of the development of a commercial vaccine that, should the research prove successful, will generate income for Sanofi Pasteur to cover both the development costs of the vaccine but also generate profit for that organisation.


The information from NHS Digital will be used to facilitate contact with individuals who are potentially eligible and who have indicated willingness to potentially participate in studies/trials of COVID-19 vaccines.

This is expected to result in individuals entering the trials screening process with a view to them participating in the trial with fully informed consent.

The main results from this trial are expected to inform development of a safe and effective multiple vaccine combination against COVID 19.


NHS Digital will extract a list of patients meeting the following criteria, where that criteria can be ascertained using the PtC registry:

Personal Information:

Sex at birth
Ethic Group

Health questions:

Flu Jab
Lung conditions
Liver conditions
Heart conditions
Cancer treatment
Bleeding disorders
Immune system disorders

The inclusion and exclusion criteria noted above is based on the information provided by cohort members on the permission to contact dataset (where it can be obtained from this dataset), and is not collected from other NHS data sources. Some of the above inclusion and exclusion criteria will be used by the sites during the Screening phase.

NHS Digital will identify all individuals within the PtC dataset meeting the relevant criteria and will extract their names, email addresses and postcodes.

It is not known in advance how many individuals meeting the above criteria will have records in the PtC dataset. The number may be amended and the process may be repeated depending on the level of response. This could encompass any part of the criteria, depending on how the recruitment progresses.

NHS Digital will write to the individuals in the subset inviting them to participate within the trial using ethically approved text provided by Sanofi Pasteur. The email will remind the individuals of the background of the permission to contact programme and give them the opportunity to state that they do not wish to be contacted again. The email will also direct volunteers to NIHR’s Be Part of Research website to access study information and regional contact information. Individuals will not be contacted multiple times under this Agreement and NHS Digital will record the fact that the individuals have been contacted to ensure compliance with the maximum number of contacts outlined as part of consent. Furthermore, in order to ensure that NHS Digital are able to update the register with which participants are registered with an active trial, and therefore prevent them from being invited to any further trials, NHS Digital will be provided with regular updates of those registered participants who have consented. This sharing of information is built into the Permission to Contact signing up information and will also be added to the trial consent and participant information.

Pharm Research Associates (UK) Ltd will supply individual recruitment sites with the IDs of those patients who have gone through the pre-screener in order to invite them for further screening. Individual trial recruitment sites will supply NHS Digital with details of those who have signed up to take part in their trial so that NHS Digital can suitably capture this information within the Permission to Contact registry. All data that flows to NHS Digital in this context falls under the controllership of Sanofi Pasteur. Once it is received at NHS Digital then NHS Digital become controller for that data in their existing role as controller of the Permission to Contact Registry.

Due to the nature of trial recruitment sites, they often only become confirmed as sites very close to recruitment, and so NHS Digital will leave the responsibility with the lead site / data controller to appointment data processors themselves under their own due diligence. This practice aligns with their obligations under GDPR as a data controller and the emphasis will be on the lead site / data controller to appoint appropriate data processors on their behalf. Ordinarily NHS Digital would carry out these checks, but attempting to do so for this service would cause unnecessary delay to the initial application, as well as potentially multiple and costly amendments thereafter. Therefore all recruitment sites / data processors and their processing activities will be covered under a suitable processing agreement between themselves and the lead site / data controller which does not require NHS Digital’s inclusion. Specific details of recruitment sites, such as key contact, location, will therefore not be made known to NHS Digital unless there is a specific reason to do so.

Additionally, Sanofi Pasteur have an appropriate data processing agreement in place with Pharm Research Associates (UK) Ltd to support the recruitment into the trial under Sanofi Pasteur’s controllership

No other processing of the data will take place and the data will not be linked with information from any other sources.

Sanofi Pasteur will not have access to any of the data being disseminated by NHS Digital under this agreement.