Strengthening ESG Data Governance: Leveraging the Federated Data Platform to Build on a Solid Foundation

The National Health Service (NHS) has made significant progress in establishing a robust framework for environmental, social, and governance (ESG) data governance. The Health and Care Act 2022 marked a pivotal moment, embedding net zero targets into legislation and placing duties on NHS organisations to contribute towards statutory emissions and environmental targets. Building on this solid foundation, the NHS is now poised to further enhance its ESG data governance practices, ensuring sustainability efforts remain data-driven, transparent, and accountable.

The NHS has established mechanisms for the development of ESG data standards and metrics, including requiring trusts and integrated care systems to develop Green Plans outlining their carbon reduction objectives and delivery plans. These plans are signed off by the Trust Board, with a board-level 'net zero lead' overseeing their delivery. Statutory guidance, including "The Delivering a Net Zero NHS" report and the "Net Zero Supplier Roadmap," supports organisations in meeting these duties.

To further strengthen ESG data governance, the NHS should focus on ensuring the quality and consistency of data reported in Green Plans. Implementing automated data quality checks, conducting regular audits, and establishing clear data management protocols will help maintain the integrity of ESG data, bolstering the credibility of sustainability efforts and facilitating benchmarking across organisations.

Transparency is a cornerstone of effective ESG data governance, and the NHS has demonstrated its commitment by publicly reporting its carbon footprint since 2008 and continuously improving monitoring methods. To build on this foundation, the NHS is considering aligning its reporting with widely recognised ESG reporting frameworks, such as the Global Reporting Initiative (GRI) or the Sustainability Accounting Standards Board (SASB), enhancing the comparability and credibility of ESG disclosures.

The NHS has also taken steps to drive accountability by embedding net zero targets into legislation and requiring board-level oversight of Green Plans. Integrating ESG metrics into performance management systems and setting clear improvement targets can further strengthen accountability and ensure sustainability remains a top priority across the NHS.

As the NHS continues to refine its ESG data governance framework, leveraging technology will be crucial in streamlining data collection, analysis, and reporting. The launch of the Greener NHS Data Collection in April 2021 marked a significant step forward, enabling more granular calculation of carbon footprints at regional, ICS, and trust levels.

This is where the Federated Data Platform (FDP) comes into play. The FDP, a software platform designed to connect disparate data sets across the NHS, presents a unique opportunity to enhance ESG data governance. By leveraging the FDP, NHS organisations can bring together operational data, such as bed availability, waiting list sizes, staff rosters, and medical supply availability, into one secure environment. This streamlined access to data will support use cases aligned with ESG goals, such as improving resource efficiency, promoting health equity, and reducing waste.

The FDP's federated architecture ensures that each NHS trust and integrated care system (ICS) has its own instance, allowing for a standardised yet flexible ESG data governance framework across the NHS. The platform's robust data protection measures, including privacy-enhancing technologies (PET) and clear rules on data access and confidentiality, will help build trust with stakeholders and demonstrate the NHS's commitment to responsible data governance.

Furthermore, the FDP's marketplace feature will enable the development and sharing of best-in-class ESG data management tools across the NHS, accelerating the adoption of sustainable practices, reducing duplication of efforts, and fostering a culture of continuous improvement in ESG performance.

To fully realise the potential of the FDP for ESG data governance, the NHS must invest in building the necessary skills and capabilities among its workforce. Training staff on ESG principles, data management best practices, and the effective use of the FDP platform will be essential in fostering a data-literate and sustainability-minded workforce.

By leveraging the FDP’s capabilities to connect disparate data sets, streamline data access, and embed robust data protection measures, the NHS can create a more transparent, accountable, and data-driven approach to sustainability. As the FDP progresses, engaging with stakeholders, building workforce capabilities, and sharing best practices will be crucial in fully harnessing the platform's potential for driving ESG performance improvement across the NHS.