Hmm - pondering a technicality?
I may be mistaken but ... any business transacted under DoH funding under banner headline of NHS has data that are belonging to the NHS.
A contractor (say a GP surgery) conducting business for and on behalf of NHS records data for and on behalf of NHS - the data are belonging to NHS. No?
So any organisation/contractor doing DoH funded work under NHS banner cannot massage, mine or manipulate such data without express permission of NHS and patient. (There are four parties to the arrangement: patient, contractor, NHS & DoH - it could be argued that NHS data are belonging to DoH).
An aside: woeful laments about why UK registered social landlords are all publicly funded inspired. BBC observed no great level of private registered social landlords here as in US or Europe.
My take: no wonder the way UK Treasury & Whitehall in particular sequester mega-millions from rents received with both central and local governments taking huge bites from rents received depending upon whim, fad or thin wallet syndrome. Private RSLs are likely to stay away in droves.