Good TREs work

LANE CLARK & PEACOCK LLP projects

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


NHS data to assess the impact of treatment delays for gynaecological care, ethnic inequalities for patients with coronary heart disease and broader health inequalities in cardiovascular disease — DARS-NIC-683842-M6S8N

Type of data: information not disclosed for TRE projects

Opt outs honoured: Anonymised - ICO Code Compliant (Does not include the flow of confidential data)

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

Purposes: Yes (Legal Sector)

Sensitive: Non-Sensitive

When:DSA runs 2024-04-19 — 2025-04-18 2024.04 — 2024.06.

Access method: System Access
(System access exclusively means data was not disseminated, but was accessed under supervision on NHS Digital's systems)

Data-controller type: LANE CLARK & PEACOCK LLP

Sublicensing allowed: No

Datasets:

  1. Civil Registrations of Death
  2. Hospital Episode Statistics Admitted Patient Care (HES APC)
  3. Hospital Episode Statistics Outpatients (HES OP)

Objectives:

Lane Clark and Peacock LLP (LCP) requires access to NHS England Data for the purpose of providing analytics and consultancy services to clients in the health sector.

LCP provider services to the following types of clients:
• NHS and Public Bodies including the Office for National statistics, Office for Health improvement and Disparities (OHID) and NHS Trusts.
• Royal Colleges (for example Royal College of Obstetrics and Gynaecology).
• The National Institute for Health and Care Excellence (NICE)
• Pharmaceutical and MedTech companies.
• Universities and Research centres.
• Third sector organisations such as the Health Foundation, Macmillan Cancer Support and the British Heart Foundation

The Data will be used to provide the following service areas only:
1) System factors for delays and the clinical impact of treatment delays for gynaecological care
2) Ethnic inequalities in coronary heart disease treatment

LCP has utilised the range of expertise and knowledge within its health analytics teams to develop the projects listed above. LCP employees involved in these projects includes chair of the Royal Society for Public Health and Chair of Health Inequalities Programme Board Northumbria Healthcare NHS Foundation Trust, honorary academics at King’s College London (Honorary Senior Clinical Lecturer, Department of Population Health Sciences) and qualified clinicians. Each of the projects outlined in this agreement will be developed and have oversight from a senior member of the team performing project lead and oversight roles. The rest of the health analytics team who will make up the project teams have expertise as epidemiologists, health economists, data scientists and statisticians. The team support both health care providers and life science organisations to identify and address some of the fundamental challenges and opportunities in health.

LCP will utilise NHS data to support clients from both the NHS and private sector through these projects. Around 25% of the project work of the LCP Health analytics team is with charities, think tanks and other third sector organisations, with the remaining clients being in the life sciences sector – around half of LCP's work with life science clients either directly involves the NHS for patient benefit or is centred around how the life sciences can best contribute to local NHS initiatives, or research with NHS clinicians.

LCP broadly aim to provide analyses to support addressing many of the key public health challenges currently faced by the NHS including:
- incorporating relevant patient level information to support identifying low treatment rates in areas of high prevalence,
- determining the impact of inequalities on health outcomes,
- comparative profiling of geographical areas across health indices and
- quality of care, supporting clinical and operational redesign and improvement by providing data and insight, and data-driven evaluation of resource needs across health geographies.

LCP have provided pro bono support to a range of groups to support public health:
• Royal College of Obstetrics and Gynaecology for their ‘Left for too Long’ report on NHS Waiting Lists (using NHS Consultant led referral to treatment and publicly available Hospital Episode Statistic data),
• Office for National Statistics (ONS) National Health Index explorer
• Current collaborative work through a programme of work with the Chief Medical Officer’s office with OHID, ONS and NHS investigating excess mortality and the indirect impact of the COVID-19 pandemic on cardiovascular disease. (This work utilised Quality Outcomes Framework and publicly available English Prescribing Datasets data) with the first of three outputs published in the Lancet Regional Health
• LCP have partnered with the Institute for Public Policy Research’s (IPPR) to provide analytical input for their Commission on Health and Prosperity, this has thus far included analysis on the societal economic benefits of clearing patients from the NHS waiting lists (utilising NHS Consultant led referral to treatment data)

Lane Clark & Peacock LLP (LCP) is a commercial analytics and actuarial consultancy working across a range of sectors including health, energy and finance. The processing outlined in this agreement is associated with LCP's commercial services provided to public & private health organisations such as forecasting & modelling using specialised analytical methods, health inequality analysis & health economics outcomes research.

LCP will charge users of the outputs produced as a result of the processing under the purpose areas specified above.
To date LCP has produced numerous examples of bespoke work and visualisations that are publicly available whose core functionalities are accessible free of charge. LCP has worked with public sector organisations to produce these publicly available outputs within several areas aimed at supporting healthcare intelligence. These include the Health Index Explorer, working with the Office for National Statistics (ONS) Health Index aimed at enabling commissioners, and healthcare professionals to easily identify areas with low Health Index Scores to allow for data-driven decision-making in public health programs.

LCP envisions that utilising the Data for analyses and incorporating it in conjunction with other public health datasets will yield significant benefits to the NHS, public health bodies, and commissioners by improving existing products, and increasing the scope and granularity of the analytical projects and publications. Through the utilisation of the Data, LCP aim to provide further insight into potential solutions or aspects that contribute to key public health challenges currently faced by the NHS. Including, incorporating relevant aggregated patient level information to support identifying low treatment rates in areas of high prevalence, determining the impact of inequalities on health outcomes, comparative profiling of geographical areas across health indices and quality of care, supporting clinical and operational redesign and improvement by providing data and insight, and data-driven evaluation of resource needs across health geographies.

The following NHS England Data will be accessed for these specific projects:
• Hospital Episode Statistics Admitted Patient Care & Outpatient Data - necessary to provide information on hospital admissions of individuals and pathways through care to permit LCP to assess service usage, waiting times and treatment delivery across different regions & characterise varying patient outcomes in those areas.
• Civil Registrations of Death - providing LCP with the necessary information to assess significant levels of mortality as an outcome to help identify what health conditions pose a greater risk to patients & further what treatment areas are closest to those patients to lower this risk.

LCP have formed a dedicated internal governance and ethics committee to ensure responsible and appropriate use of the Data in these projects. Whilst the LCP Health Management Group (senior members of the health analytics team) are responsible for procuring new work for the LCP Health analytics team, the internal governance and ethics committee consists of senior members of LCP with expertise in clinical practice, public health, and data protection specialists. The Committee has considered the use of the Data for the three projects to assess any potential ethical risks, the outcome of these assessments concluded that the projects and processing of Data were ethical and did not pose any further ethical risks to the data subjects.

The three different projects which are outlined below are:

1) System factors for delays and the clinical impact of treatment delays for gynaecological care.

LCP have been commissioned by the Royal College of Obstetrics and Gynaecology (RCOG), building on previous pro-bono work conducted by LCP regarding waiting lists and gender-based health inequalities. LCP conducted work in April 2022 which identified that gynaecology is the speciality which has had the greatest relative increase in the number of people on waiting lists since the onset of the Covid-19 pandemic. The work estimated the number of women who did not come forward for elective care (i.e. those with an unmet health need) over the course of the pandemic, using the NHS Consultant led referrals to treatment dataset. The work also used publicly available Hospital Episode Statistic data to understand the case mix of those women being treated and how this has varied over time.

The LCP analysis was used for the ‘Left too long’ report by the RCOG, which highlighted the need to understand where in the system the delays are to identify solutions that will address the problem. The report was used as evidence to inform national policy discussion, including for a UK parliament debate in the House of Commons on the size of waiting lists for gynaecological services. In the report the RCOG used the LCP analysis to help make the following recommendations:

• prioritising care considering wider societal impact;
• re-prioritising gynaecology within the health service;
• addressing the unequal growth of gynaecology waiting lists compared to other specialities;
• focusing on the geographic disparities

RCOG, who are now partnering with Theramex, a life sciences company dedicated to supporting the health needs of women have commissioned LCP for further work within this area. LCP have been commissioned by RCOG to develop the project further, the new analysis will make use of patient level data to explore further inequalities in the gynaecology patient case mix in more details. LCP would use the Data to analyse the following areas:

• Provider availability: The number of providers offering gynaecological care & how this has varied over time.
• Service provision and efficiency: the number of admissions, length of stay, number of consultations and procedures per provider per stay by condition at ICD level.
• Outpatient service provision: The number of consultations and procedures per provider per day by condition.
• Demographic breakdown including ethnicity, age, rural/urban areas, deprivation, and their association with greater waiting times.
• Overall cost of care: broken down by age and deprivation groups for admitted patient care, outpatient care, specific treatments and care pathways
• Estimate the healthcare savings possible through targeted prevention measures
• The delay across the pathway looking at time to diagnosis and procedure
• Association of delay with demographic breakdown including ethnicity, age, rural/urban areas, IMD.
• Complication rates: Agree complications of each condition and measure how this varies as treatment delay increases.
• Incidence of advanced cervical cancer: Number of patients diagnosed with late-stage cervical cancer over time and how this has varied as waiting lists have increased.

This analysis may help stakeholders across the healthcare system identify the challenges faced and create actionable recommendations to address them. The analysis performed will aim to assess the indirect impacts of the Covid-19 pandemic on patient care on changes in outcomes for patients and highlighting which patient groups have been impacted most. LCP are requesting data across England such that robust analysis on health inequalities (for example, regional comparisons) can be conducted.

Data used for this analysis will be minimised to:
• Limited to data between April 2017 to Latest Available to provide sufficient baseline data for comparable analysis.
• Limited to records that specifically relate to gynaecological conditions through selected ICD-10 codes.

2) Ethnic inequalities in coronary heart disease treatment (project for the British Heart Foundation)

LCP have been commissioned by the British Heart Failure (BHF) to integrate and visualise results from their collaboration identifying inequalities in coronary heart disease (CHD) by ethnicity across England.

The collaboration is conducting analytical work into inequalities by ethnicity across the coronary heart disease (CHD) pathway. LCP have been commissioned to work within the project, aiming to analyse how ethnic inequalities persist in CHD care and how this varies across services within England. LCP will use the data to:

• Map care for CHD by ethnicity, ICB and provider and analyse time trends, including the number of admissions, length of stay, number of consultations and procedures per provider per stay
• Benchmark inequalities in CHD care by provider and ICB, identifying best practices across England and where care can be improved.
• Create heat maps to easily understand and communicate CHD metrics
• Estimate the healthcare savings possible through targeted prevention measures for those ethnicities with poorer levels of CHD care

Data used for this analysis will be minimised to:
• Limited to data between April 2017 to Latest Available to provide sufficient baseline data for comparable analysis.
• Limited to records that specifically relate to CHD through selected ICD codes.

LCP is the controller as the organisation responsible for ensuring that the Data will only be processed for the purpose described above. NHS England are named as a Data Processor as they provide support for the Secure Data Environment (SDE).

The lawful basis for processing personal data under the UK GDPR is:

Article 6(1)(f) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. LCP has determined the processing is necessary for its legitimate interests as LCP will be providing tools and services that will be of benefit to the NHS, patients, and the healthcare system.

The lawful basis for processing special category data under the UK GDPR is:
Article 9(2)(j) - 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. The processing is in the public interest for the reasons stated above, in summary, better understanding of patient needs, improved access to health care for disadvantaged groups and better value for money for patients, the NHS and society. These benefits cannot be realised without interrogation of real-world evidence datasets.

Expected Benefits:

The outputs provided by LCP help clients to better understand patient’s needs, allow them to identify efficiency and quality gaps and establish ways to provide better value for money for the NHS. LCP's work has particular focus on healthcare inequalities across patient groups, as well as across geographical regions. This allows clients to better address the needs of all patients, focusing on the most disadvantaged groups. For example, identifying which patients benefit from a new drug/change in care improves the overall outcomes and helps to redistribute the healthcare resources in an efficient way.

The use of the Data when written into a whitepaper for the RCOG and Theramex may help to influence decision making at governmental (national and local) and NHS levels. The benefits for gynaecological care could be:
• help the system to better understand the health and care needs of women.
• advance understanding of regional and national trends in health and social care needs.
• lead to the identification or improvement of treatments or interventions, or health and care system design to improve health and care outcomes or experience.
• inform planning health services and programmes, for example to improve equity of access, experience and outcomes.
• inform decisions on how to effectively allocate and evaluate funding according to health needs.
• provide a mechanism for checking the quality of care. This could include identifying areas of good practice to learn from, or areas of poorer practice which need to be addressed.
• Support knowledge creation or exploratory research (and the innovations and developments that might result from that exploratory work)

Coronary heart disease (CHD) is being analysed for the BHF, NHS Race Observatory and Strategy Unit project as previous studies have highlighted that people of South Asian ethnicity may have higher incidence of the disease. There remains further work to explore how care processes affect inequalities in outcomes and identifying key opportunities to address and mitigate these inequalities with focused measures. Cardiovascular disease more broadly has been selected as the clinical specialty for the Population Health Hub due to it affecting seven million people in the UK and being responsible for one in four premature deaths in the UK and one of the five clinical conditions of focus in the NHS England Inequalities initiative Core20PLUS5.

The use of the Data in the form of interactive dashboards for cardiovascular care could help:

• Identifying best practice of disease management at ICS, sub-ICB and local health and social care organisations can implement improvements. This will involve analysis of efficiencies (or lack of) of clinical pathways and services.
• Analysis of patient pathways using the requested datasets can cover a wide set of factors and patient outcomes, thus better reflecting the totality of patients’ health needs and the impacts on health systems.
• Costed pathway projects can estimate per patient costs and interactions with health systems in defined populations to identify between and within population trends in healthcare utilisation. These estimates provide evidence of which patient groups have the highest unmet need and therefore would benefit most from targeted intervention, ultimately improving patient health and reducing economic burden.
• Understanding unmet need can not only help the NHS to focus resources but it can also help life sciences companies understand where they can help to address inequalities (such as by ethnicity) in the health care system,
• Providing an easy to use and understand evidence base that equips decision makers with the best insight to health inequalities on a national, regional and local scale. Evidence can be shown as time trends to show if performance is improving or getting worse.

Outputs:

The outputs from processing of the data will not contain NHS England Data and will only contain aggregated information with small numbers suppressed as appropriate in line with the relevant disclosure rules for the dataset(s) from which the information was derived.

Where appropriate, LCP will share outputs with the wider health community to ensure benefits are realised in the health and social care system. Outputs may vary in format depending on the project.

Project 1
The project commissioned by the RCOG and Theramex will have a report that will form part of a broader whitepaper and online dashboard. Both the dashboard and the whitepaper, (whitepaper is expected to be similar to that which the RCOG published in April 2022 https://rcog.shorthandstories.com/lefttoolong/ using LCP analysis), will be used to communicate the findings to politicians, NHS stakeholders and other health system professionals. The project output will include:
• A report of findings for the client
• Whitepaper (developed from the initial client report)
• Web-based dashboard (to aid public dissemination of findings)
• Potential for academic publications

Project 2
The project commissioned by the BHF will have an online web based interactive dashboard. The BHF will use the dashboard to help lead conversations around importance of addressing ethnic inequalities in CHD with policy experts and healthcare system professionals. The project output will include:
• A report of findings for the client
• A public report of the findings
• Web-based dashboard (to aid public dissemination of findings)
• Potential for academic publications

Other outputs that could be included across the projects may include (but are not limited to) the following:
• A report of findings to the client.
• Contributions to academic publications.
• Public reports
• Presentations or slide decks provided to clients of the service.
• Analytical models.
• Outputs will include charts figures and tables for optimal result dissemination.
• Dashboards & PDF reports

Processing:

This application is for online access to the record level datasets via the NHS England Secure Data Environment (SDE). The system is hosted and audited by NHS England meaning that large transfers of data to on-site servers is limited and NHS England has the ability to audit the use and access to the data.

The Secure Data Environment (SDE) is a data storage and access platform that enables approved users to access de-identified data and analytical tools for approved projects. Users must identify themselves via a multi-factor authentication mechanism and are only able to access the datasets detailed within this agreement. Users can request that aggregated outputs are exported from the system following approval by trained NHSE staff. The access and use of the system is fully auditable, and all users must comply with the use of the data as specified in this agreement.

Users can produce aggregate outputs from the system, however, record level extracts are not permitted. As record level data cannot be extracted from SDE, the system accommodates a variety of technical tools for data analysis.

No cohort data will flow to NHS England for the purposes of this Agreement.

NHS England data will provide the relevant records from the HES and Civil Registration (deaths) datasets to LCP. The Data will contain no direct identifying data items. The Data will be pseudonymised and individuals cannot be reidentified through linkage with other data in the possession of the recipient. There are no further flows of data from LCP. Analysts from LCP will process the Data for the purposes described above.

The Data will not leave England.

The Data will be accessed by authorised personnel only. All personnel accessing the Data have been appropriately trained in data protection and confidentiality.

There will be no requirement and no attempt to reidentify individuals when using the Data. The Data will not be linked with any other data.

All individuals who have access to the record level data are substantive employees of LCP. Only designated individuals will have access to the Data. The SDE platform has functionality including monitoring and logging of system usage to allow the review of user activity to determine if the data policies are being adhered to. All users will be fully aware of these auditing capabilities. All LCP employees have Multi-Factor Authentication (MFA) turned on their company devices.

Following similar principles to those adopted by the SAIL Databank for Wales and the Scottish National Data Safe Haven (https://www.isdscotland.org/Products-and-Services/EDRIS/Use-of-the-National-Safe-Haven/), only summary, aggregate results data are exported from the SDE by LCP, subject to the approval of NHS England’s trained output checkers. This ensures that no output contains information which could be used either on its own or in conjunction with other data to breach an individual's privacy.