Contributor Participation, Data Sharing and Consent Policy

This policy governs participation in clinical audit, quality-improvement, service-evaluation and related projects using Lazomis QI. It explains contributor responsibilities, access, confidentiality, attribution, project outputs, necessary processing and optional consent for wider uses of project information.

It applies to project owners, leads, collaborators, data collectors, reviewers, supervisors, administrators and other invited contributors. It should be read with the Privacy Policy, Terms of Use, Data Protection & Information Governance statement, Artificial Intelligence Policy, customer Data Processing Agreement and applicable organisational policies.

This policy does not itself authorise the use of patient information, override the relevant healthcare organisation's decisions, create research approval, or determine professional authorship for a specific publication.

A person becomes a contributor when an authorised project owner or organisation invites them, assigns a role, or records an approved contribution. Merely viewing public material, receiving a project link or being named without authority does not create contributor status.

• Project owners and clinical or QI leads.
• Data collectors and authorised reviewers.
• Supervisors, mentors, analysts or subject-matter advisers.
• Organisation administrators supporting governance or oversight.
• People who provide a documented substantive contribution to defined project work.

Contributors must be adults authorised to use the Service. A contributor acting for an employer or organisation must follow that organisation's policies and instructions.

Before joining or contributing, each person must receive or be able to access this policy, the relevant privacy information, the project purpose, their role and the applicable local governance requirements. Participation must be limited to work they are authorised and competent to perform.

• Use an individual account and keep credentials secure.
• Enter accurate information and correct known errors promptly.
• Use only the approved dataset and avoid unnecessary identifiers or free text.
• Respect access permissions, confidentiality and professional duties.
• Review outputs within the limits of the assigned role.
• Report suspected misuse, data loss, inappropriate access or conflicts promptly.
• Do not represent participation as formal authorship, approval or endorsement unless separately agreed.

Lazomis QI may record a contributor's name, professional details, organisation, project role, invitations, membership, activity, comments, approvals, timestamps and other audit-trail information. This supports access control, accountability, collaboration, project governance and generation of professional outputs.

Contribution records should reflect actual involvement and must not be falsified, inflated or assigned without a reasonable basis. The project owner should correct mistaken attribution and manage disputes fairly. Audit and security records may be retained even after access ends where necessary for governance, legal obligations or claims.

Lazomis QI may identify contributors in project reports, presentations, portfolio summaries or acknowledgement sections where the feature is enabled and the project owner has authority. Contributors should be able to review how their name and role will appear before an external output is finalised.

• Credit must be proportionate to the contribution actually made.
• Honorary, guest or coercive authorship is not permitted.
• Administrative access alone does not establish authorship.
• Contributors must disclose relevant conflicts and funding where the output requires it.
• No person should be named publicly without appropriate authority and notice.

Project access is limited to authorised contributors and administrators on a need-to-know basis. Contributors may see information belonging to the relevant organisation, other contributors or people represented in project data. They must use it only for the authorised project purpose and not disclose it through personal email, unauthorised storage, social media or other unapproved routes.

Projects should use anonymous or appropriately pseudonymised information wherever possible. Lazomis QI is not the authoritative patient record. Names, NHS numbers, full addresses, identifiable images and unnecessary clinical narratives must not be entered merely because a custom field or attachment permits them.

Ownership of project content depends on the contributor's employment, commissioning, contract, organisational policy and applicable law. This policy does not transfer ownership that belongs to an employer, organisation, patient, third party or other rights holder.

As between the user and Flux Medical, the relevant rights holder retains rights in User Content. Flux Medical receives the limited licence described in the Terms of Use to host and process that content to provide, secure and administer the Service. Contributors must not upload material they are not authorised to use or disclose.

The following activities are normally necessary to provide and govern the project and are not presented as optional wider-use consent:

• Create and secure accounts, authenticate users and manage permissions.
• Invite contributors and record roles, activity, approvals and project history.
• Store, validate, analyse and display authorised Project Data.
• Generate requested dashboards, reports, presentations and other project outputs.
• Provide support, investigate errors, maintain security and prevent misuse.
• Meet legal, contractual, audit, incident and records-management obligations.

The applicable lawful basis is determined by the controller and circumstances. Consent is not used where the processing is necessary for a contract, legal obligation, legitimate task or another more appropriate basis. Contributors receive transparency whether or not consent is the lawful basis.

Flux Medical may invite a contributor or responsible organisation to permit specified wider uses of suitably anonymised project information. These choices are separate from necessary project processing and refusal does not reduce the core Service.

Where Flux Medical relies on consent for an optional use of personal data, the consent must be freely given, specific, informed and unambiguous, provided through a clear affirmative action and capable of being demonstrated. Explicit consent is obtained where the law requires it.

• Consent is separate from account registration, project participation, Terms acceptance and contributor acknowledgement.
• Each materially different purpose has its own unticked choice.
• A clear ‘No additional use’ option is available with equal prominence.
• The request identifies the controller, purposes, information involved, intended recipients or recipient categories, and withdrawal route.
• Refusal or withdrawal does not remove ordinary access, credit or contributor recognition.
• Consent is refreshed if a purpose, data type, controller or material processing activity changes.
• The system retains the wording and policy version, choices, timestamp, account, project scope and withdrawal status.

Creating anonymous information from personal data is itself processing and requires an appropriate lawful basis, authority and safeguards. Information is treated as anonymous only after an assessment of whether anyone could reasonably identify a person using the released data alone or with other available information.

The assessment considers direct and indirect identifiers, rare conditions, small numbers, dates, geography, free text, linkage, recipient knowledge, motivated-intruder risk and the intended environment. Aggregation, suppression, generalisation, removal of free text and controlled access may be used.

Pseudonymised information remains personal data. Calling a dataset ‘de-identified’, replacing a name with a code or separating a key does not automatically make it anonymous.

Consent to optional wider use does not turn an audit or QI project into approved research and does not authorise a publication. Before a new research use begins, the responsible parties must determine classification, controller roles, lawful bases and Article 9 conditions, confidentiality route, sponsorship, protocol, ethics, data-management plan, national data opt-out, contracts, security and publication arrangements.

Research participation consent, confidentiality consent and UK GDPR consent are related but legally distinct. A study may use a lawful basis other than UK GDPR consent, particularly where withdrawal of data cannot realistically be guaranteed. The chosen basis and participant information must accurately describe the position.

External outputs must be checked for re-identification, small-number disclosure, accuracy, intellectual-property rights, conflicts, funding, contributor acknowledgement and required organisational approval.

AI may help draft, organise, map, summarise or analyse project material. AI output requires competent human review and does not determine authorship, contribution credit or permission for wider reuse.

• Do not submit sensitive Project Data to an AI feature unless the use is supported, necessary and approved.
• Exclude direct identifiers and unnecessary confidential text.
• Record and assess the AI supplier, purpose, retention, data location and human oversight.
• Do not use customer Project Data to train general-purpose models unless separately assessed, transparently explained and lawfully agreed.
• Clearly disclose material AI assistance where a publication, conference or professional rule requires it.

A person may withdraw consent for future consent-based processing at any time through the account control or by contacting privacy@lazomis.co.uk. Withdrawal must be as easy as giving consent and does not affect the lawfulness of processing before withdrawal.

• Stop the relevant future consent-based use as soon as reasonably possible.
• Record the withdrawal and notify relevant processors or recipients where required.
• Do not remove necessary project records processed under another valid basis solely because optional consent is withdrawn.
• Explain that information already irreversibly anonymised is no longer personal data and normally cannot be linked back for removal.
• Assess completed analyses, submissions and publications individually; do not promise reversal where it is impossible or another lawful basis applies.

A contributor may leave or be removed from a project by the project owner or organisation. Access ends when authority ends. Their previous contributions, approvals and audit-trail entries may remain where needed for project integrity, governance, attribution, security, legal obligations or claims.

Before removal, the project owner should consider outstanding work, handover, attribution, exports and whether contributor details should remain in future outputs. Leaving a project does not automatically withdraw optional consent; the contributor must be offered a clear route to manage that consent separately.

Contributors may have rights under data-protection law, including access, correction, erasure, restriction, objection, portability, withdrawal of consent and safeguards concerning automated decisions. Rights are not absolute and depend on the processing and lawful basis.

Patient-identifiable or other sensitive information should not be sent through ordinary email unless a secure, authorised route has been agreed.

Flux Medical maintains records necessary to demonstrate the version of this policy and consent wording presented, the choices made, time and method, relevant project or organisation scope, later changes and withdrawals. Access to consent records is restricted and retention follows the Privacy Policy and internal schedule.

New purposes are not treated as covered by old consent. Material changes require governance review, a DPIA where indicated, updated transparency and fresh consent where consent remains the basis. This policy is reviewed at least annually and after material legal, research, supplier or product changes.

A1. Required contributor acknowledgement

The acknowledgement is required for participation because it records responsibilities. It is not consent to optional wider use and must not be labelled as such.

A2. Optional data-sharing choices

The following choices are unticked by default and independently selectable. The interface names Flux Medical Limited and links to this policy and the Privacy Policy.

A3. Authority confirmation for organisation-controlled projects

Where authority is absent or uncertain, optional sharing remains disabled and the request is referred to the responsible organisation.

A4. Withdrawal notice