Reference 14-327 – Privacy Notice – last updated 30th April 2020

Data Controller

The sole Data Controller is Civil Eyes Research.  There is no other Data


There are no joint Data Controllers and data are not transferred to or processed by any third parties.


Civil Eyes Research does not undertake automated decision making or profiling.


The Data Controller contact details are:

Civil Eyes Research (West Midlands)

Priors Lee Cottage

Frog Lane

Welford on Avon

Warwickshire CV37 8EQ


Telephone: 01789 751221


The Data Protection Officer details are:

Geoff Bick


Civil Eyes Research (West Midlands)

Priors Lee Cottage

Frog Lane

Welford on Avon

Warwickshire CV37 8EQ


Telephone: 01789 751221


Level of Data Collected

Civil Eyes Research analyses Hospital Episode Statistics (HES) data which are obtained from NHS Digital.   HES data are a compilation of organisational, administrative and selected clinical information that is derived from hospitals’ Patient Administration computer systems.

Data are in pseudonymised form and are never linked with other datasets which could allow re-identification of HES data.  These data are categorised by the GDPR as sensitive.

Purpose for which the Data are Processed

The objective of Civil Eyes Research is to provide analysis and interpretation of performance and quality issues within healthcare to doctors, clinicians and managers of NHS and Social Care providers using benchmarking of HES data alongside the deployment of Civil Eyes Research’s (CER’s) own accumulated healthcare expertise over thirty years, within CER and elsewhere.

Civil Eyes Research has principal directors who have long and significant track records within the healthcare sector where they have held a range of roles.  They joined Civil Eyes Research in 2005 to provide services whereby doctors and managers could use data to understand service provision and effectiveness.

Civil Eyes Research is commissioned by Chief Executives and Medical Directors of healthcare organisations to provide analysis and advice in order to promote discussion and action on efficiency, productivity, effectiveness, quality and access to services.  Engagement with doctors and managers results in higher commitment to better coding, improved understanding of case mix and more robust use of information in the health service.

Civil Eyes Research requires HES data for use in its Benchmarking Clubs where hospitals work together to review and understand the data and performance; they are: Medical Productivity within NHS organisations, Pathology networks and Specialist Children’s Hospitals.

The members of the clubs are drawn from teaching, district general and Specialist Children’s Hospitals across the UK.

The funding stream for the work consists of subscriptions paid by participating hospitals.

The benchmarking work was initiated through a combination of the CER directors offering services to healthcare organisations and also the original involvement of the Association of University Hospitals in the UK.

Client engagements are either long-standing from Civil Eyes Research’s inception, as a result of the directors’ previous work within healthcare services, or have occurred by “word of mouth” recommendation.

The aim of the work is to improve patient care, pathways, healthcare services and value for money, specifically:

  • Improvement in patient care due to increased clinical productivity and the reduction in variability across the healthcare system in England.

  • Enhanced efficiency within clinical services improving capacity and access to services for patients.

  • Evaluation and benchmarking of NHS organisations helping to increase quality and outcomes for patients.

  • Providing insights and evidence to support providers in developing local services to provide the best care possible for their patients.

  • Better use and understanding of information within the NHS for all disciplines, specialties and hospitals with which Civil Eyes Research works.


The Medical Productivity and Specialist Children’s Hospitals workstreams have been taking place for twelve years, while the Pathology network benchmarking has been taking place for five years.

Civil Eyes Research has been using HES data for fourteen years.


England-wide data from NHS Digital is required to see the entirety of patients’ encounters with health services within a healthcare network, to look at patterns of care across providers such as readmissions and extended lengths of stay, to provide peer groups and to derive comparative provider and population-based performance measures.

Civil Eyes Research is required by clients to:

  • Provide evidence of national best practice

  • Provide performance within a national or local context

  • Provide information on patient flows to tertiary, regional or national services and centres

  • Provide local market reviews of comparable providers


Civil Eyes Research uses HES data to provide analysis of clinical performance and benchmarking information to hospitals covering areas such as lengths of stay, day case rates, readmissions, same day operations, depth of clinical coding and clinical performance within specialties.


Civil Eyes Research organises national workshops and local meetings for service managers and lead clinicians at specialty or function level.  At these events there is multi–disciplinary discussion using benchmarked activity data, best national practice and local experiences.   Service managers and lead clinicians are then invited to submit their recommended service changes to their local management teams.


In addition, Civil Eyes is asked to visit hospitals and other healthcare organisations to share workshop analysis for in-depth review with local management teams.


CER has used and plans to continue to use four HES datasets:

  • Admitted care

  • Outpatients

  • Accident & Emergency

  • Critical Care


These datasets provide good coverage of hospitals’ activities and enable the benchmarking work to be undertaken.

The legal basis of the data processing

The legal basis for data processing is:

General Data Protection Regulation (GDPR) Article 6, paragraph 1 (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child;



GDPR Article 9, paragraph 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.

Legitimate Interests

Civil Eyes Research has undertaken a legitimate interest assessment.  This includes the statements:

  • That the processing activity is important as it provides hospitals with a way to scrutinise and compare clinical services with peers.

  • Members of the public may reasonably expect that hospitals use a range of tools and methods to review and monitor the quality and efficiency of the services that they provide.

  • HES data is the prime, comprehensive record of hospital activity across England.

Data Sharing

The sole Data Controller is Civil Eyes Research. 

Reports are only issued in aggregate form to clinicians and managers of NHS organisations within the UK.  No record level data is shared with any third party organisation in any format.

Data Storage and Retention

Data will be stored for five years for the purpose of identifying trends in healthcare activity.  After this period data will be deleted using a secure data destruction method.

Data are downloaded from NHS Digital via its secure electronic file transfer system to an encrypted, password protected laptop.  Data are then transferred to, processed and held on a prime database server dedicated to the sole use of Civil Eyes Research; the server is not connected to a network.  The data will be stored and processed at the single address specified.


The storage and processing address is:

Civil Eyes Research (West Midlands)

Priors Lee Cottage

Frog Lane

Welford on Avon

Warwickshire CV37 8EQ


The processing activities are the same for all Benchmarking clubs and activities.


There are no flows of data from Civil Eyes Research to NHS Digital.

HES data are in pseudonymised form and do not allow the identification of individuals.


National Data Opt-Out Programme

Individuals should be aware of the National Data Opt-Out Programme, details of which can be found at the NHS Digital website at .


Individuals have the right to complain about data handling and processing to a supervisory authority.  Concerns about an organisation's information rights practices should be reported to the Information Commissioner by following this link .


CER requests and uses only de-identified, pseudonymised data from Hospital Episode Statistics.


In addition, more information about individual rights is available at the website of NHS Digital.  The following link - - covers a range of areas including:

  • The right to be informed

  • The right of access

  • The right to rectification

  • The right to erasure

  • The right to restrict processing

  • The right to data portability

  • The right to object

  • Rights in relation to automated decision making and profiling.


Civil Eyes Research Ltd
PO Box 59509
London SE21 7WL


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