Good TREs work

• Good TREs work, and can be seen to work safely — any project secrecy is a choice;
• Different TRE approaches are optimal for different tasks for different reasons — Five safes vs custom outputs.
• Transparency must cover all users — internal and external — and differences of process between them must be visible.

Good “Trustworthy Research Environments” Work; bad environments are like toxic waste seeping through the data ecosystem. There’s eternal pressure to turn good governance into weak governance so those who don’t qualify today can get data tomorrow.

Every project in every TRE should be listed in a public data uses register, and all of the data available to any project should be publicly listed. NHS England and OpenSAFELY both do this. NHS England has spent the last couple of years building a network of “Secure Data Environments”, partial lists are published of the different data they hold.

Name	Consensual	Safe	Transparent (how many projects; notes)
National
NHSE (interactive)	? variable (partial)	✅	✅ (many; only some)
OpenSAFELY	✅ Yes for GPDOO	✅	✅ (many) (best)
MHRA CPRD	Yes (GPDOO & NDOO)	Not yet, but beginning	incomplete (many)
Regions
East of England	✅ Yes (respects NDOO)(has no GP data?)	unclear	✅ (1)
Kent, Medway and Sussex	Unclear? (so no? has GP data)	unclear	✅ (2)
London (has GP data, ignores GPDOO; unclear on NDOO)	❌ no	unclear	Limited detail (tens)
North East and North Cumbria	✅ Yes (respects NDOO)	unclear	✅ (2)
Thames Valley and Surrey	❌ No (ignores NDOO; has no GP data?)	unclear (possibly no)	No (0)
West Midlands	✅ Yes (respects NDOO and GPDOO)	unclear	✅ (4)
Wessex	✅ Yes (respects NDOO, has no GP data?)	unclear	✅ (1)
Yorkshire and  Humber	✅ Yes (respects NDOO, has no GP data?)	unclear	✅ (many)
(as of the 24 March 2025 none of the other regions are listed as operational).
NHSE’s Federated Data Platform	❗No (mostly used for direct care – publicly at least, but it is not an informed choice by patients)	Potentially (entirely policy)	❌ No (but possible)
Non-NHS Environments
ONS Secure Research Service	❌ No (no for most data, no for most NHS data, but yes for GP Data)	yes	Yes
ONS Integrated Data Service	❌ No (no for most data, no for most NHS data, but yes for GP Data)	Yes	Partial (gov/ONS projects not listed) (24)

Notes:

It is unclear how the regional environments make decisions, and how there is accountability between them. In practice they may degrade into a race to the bottom as they run out of funds (as London demonstrates)

The London SDE has been running for longer than the others, has agreed with their commercial customers to limit what information they make public about projects, and is the only one to not disclose whether opt outs apply to data. It may also have run out of money and stalled after leadership left.

It is curious that environments have chosen to make the datasets they hold on the “HDR gateway” but publish no information about projects or published papers through the same mechanism…

Environments relying upon the HDR/DARE designed system would get an immediate “unlikely” on “safe” until an audit had confirmed their entire configuration after every upgrade. 

Regional environments that suggest they will mix direct care with secondary uses and GP data can not do both without significant infrastructure that the regional environments do not possess, so they are either using data on people who have objected, or are excluding people from direct care in breach of the terms of the opt out promised by the NHS.

It is unclear how the regional environments make decisions, and how there is accountability between them. In practice they may degrade into a race to the bottom as they run out of funds (as London demonstrates)

The London SDE has been running for longer than the others, has agreed with their commercial customers to limit what information they make public about projects, and is the only one to not disclose whether opt outs apply to data. It may also have run out of money and stalled after leadership left.

It is curious that environments have chosen to make the datasets they hold on the “HDR gateway” but publish no information about projects or published papers through the same mechanism…

Environments relying upon the HDR/DARE designed system would get an immediate “unlikely” on “safe” until an audit had confirmed their entire configuration after every upgrade. 

18 organisations were TRE only.